Final Basic Impact Assessment UPGRADING of CLARKSON SEWAGE NETWORK and WASTE WATER TREATMENT WORKS Koukamma Local Municipality

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Final Basic Impact Assessment UPGRADING OF CLARKSON SEWAGE NETWORK AND WASTE WATER TREATMENT WORKS Koukamma Local Municipality, Sarah Baartman District Municipality, Eastern Cape

COMMENTS AND RESPONSE REPORT 20 November 2019

This document records the comments received from Interested and Affected Parties (IAPs) in terms of the EIA regulations of the National Environmental Management Act (Act 107 of 1998) as well as the responses provided by the Environmental Impact Assessment Practitioner and the proponent.

A public participation process is being carried out in accordance with Section 24J of the NEMA; the following activities were carried out:  Placing poster at entrance to site and in the town of Clarkson on 7 June 2019  Distribution of notice on the intent to submit an application and background information document (BID) to identified landowners, surrounding landowners and organs of state on 7 June 2019 to encourage participation in the process. These parties have been automatically registered for the process (Refer to Appendix E2 – Full register of interested and affected parties).  Placing an advertisement in the herald on 7 June 2019  Allowing for a 30 day registration and comment on the BID  Record of registration and comments received in response to the notices and BID  Distribution of the draft basic assessment report (BAR) to registered IAPs on 15 October 2019  Allowing for a 30 day comment period on the daft BAR; comment period ended 14 October 2019

The comments and responses received to date are provided in Table 1. All updates are indicated in blue.

The draft Basic Assessment Report was distributed to registered IAPs on 15 October 2019 where they were provided with a 30 day period in which to review the report and provided further comments. The closing date for submission of comments on the Draft bar was 14 November 2019. One comment was received from the Department of Water and Sanitation on 15 November 2019, dated 31 October 2019. A record of the meeting held on 4 October 2019 with DEDEAT and project managers is also included in this updated Comments and Response Report

See Table 1 for the updated Comments and Responses dated 20 November 2019.

See the following attached appendices for details of public participation activities carried out: Appendix E1: Notices, BID, Adverts and Comments Received Appendix E2: Full Register of interested and affected parties

Comments and Response Report Final Basic Impact Assessment UPGRADING OF CLARKSON SEWAGE NETWORK AND WASTE WATER TREATMENT WORKS Koukamma Local Municipality, Sarah Baartman District Municipality, Eastern Cape

November 2019

1 Table 1: Comments and Responses, 20 November 2019 Name Organisation / Role City / Comment Response Town MORAVIAN CHURCH IN SOUTH AFRICA Landowner Cape Town Letter of Consent received. Not applicable Farm 654 C03400000000065400000 See Appendix G1 Portion 0 (RE) Farm 654 Portion 0 (RE)

Mr. L. Mcubusi President of the church

Reverend G. Cunningham Head of Church REPUBLIEK VAN SUID-AFRIKA Eastern Cape Roads and Public Works - Marius Keyser PE 041 403 6043 [email protected] / Farm 373 [email protected] Portion 0 Prov. Department of Transport & Public Works - Mzi Mafani [email protected]

C03400000000037700000 National Department of Transport & Public Works – Farm 377 Brian Stander Portion 0

C03400000000078800001 Farm 788 Portion 1 Chumisa Njingana SANRAL PE Good day Claire Noted. Statutory control process application forms sent Statutory Control Administrator to GG and G for completion Hope all is well.

Please find the attachment for your attention, for your below enquiry.

Have a blessed day.

Kind regards Chumisa

Sarah Ted Pillay Sarah Baartman DM MM Baartman I support the development NA CT Good Morning Thank you

Thank you for informing SAHRA of this Mr Makhanya has been notified. proposed development, however by law Nokukhanya Khumalo SAHRA SAHRA is unable to comment on any Kind Regards

November 2019

2 Name Organisation / Role City / Comment Response Town developments located in the Eastern Cape. Therefore, all applications must be directed to the Eastern Cape Heritage Resources Authority. The contact person is Mr Sello Makhanya and his email address is [email protected]

Kind Regards, Nokukhanya Khumalo

Good day Claire,

Thanks for the information – it’s all in order.

Sincere Regards

PE Dear colleagues,

Herewith please find for your attention.

Regards Mzukisi Maneli Department of Water Affairs NA Saadiq Agherdien GG&G Consulting Engineers (Pty)Ltd PE Good day Claire, NA

Thanks for the information – it’s all in order.

Sincere Regards

Marissa Bloem Department of Water and Sanitation PE From a water resource management Noted perspective, this Office has no objection on the anticipated upgrades of the Clarkson Wastewater Treatment Works to be undertaken, provided that the following will be noted and complied with: As contemplated in the report, "the This recommendation has been included in the final emergency ponds located nearby the two basic assessment report (BAR) and construction pump stations at Clarkson are currently environmental management programme (EMP) overflowing into the water resource" a operational EMP. provision should be made in ensuring  Spillages currently emanating from the water resource contamination by the emergency ponds are to be ceased spillages emanating from the emergency immediately

November 2019

3 Name Organisation / Role City / Comment Response Town ponds is ceased immediately and during  Emergency ponds at pump stations are to operational phase of the works, early be lined with impermeable linings. warning systems are implemented to  Construct an earthen berm/bund wall safeguard the recurrence of spillages thereto; around the emergency ponds  Construct an earthen berm / bund wall around the pumping station to ensure that any unavoidable spills are limited to the ponds and/or pumping station areas.  Installation of controls to equally cycle both pumps, and wireless level warnings (at maximum/inlet level and overflow level) with alarm systems (e.g. via GSM uplink) to alert controllers, supervisors and/or management are recommended A baseline analysis of the final effluent at This recommendation has been included in the final the works should be provided, having BAR and construction and operational EMPs. ascertained that the maturation ponds will  Baseline and monthly monitoring of the be constructed with an outflow channel effluent will be required to ensure with the aim of controlled discharge of final compliance to the applicable limits. effluent into the environment, although not specified the type of environment (i.e. be it  Irrigation with effluent may only take place if a water resource or irrigation of the land), effluent is treated to the General limit this office is hereby uncertain whether the values given in the Government Gazette, final effluent is complaint and/or will be “Revision of General Authorisation in terms complying with the discharge quality of Section 39 of the National water Act, standards; 1998 (Act 36 of 1998)”, 6 September 2013, Table 2.1: “Wastewater limit values applicable to discharge of wastewater into a water resource”. Other alternatives of effluent disposal could Re-use of effluent has been considered. Due to lack of be explored such as re-use in the form of electricity on site, and natural gradient of the site, re-use irrigation where the land is available to of effluent is difficult without pumping. minimize or control the amount of effluent being discharged into the water resources, The following measure is included in the final bar and however, taking into account the applicable EMP’s: guiding principles or legislation for the  Irrigation with effluent may only take place if activity; effluent is treated to the General limit values given in the Government Gazette,

November 2019

4 Name Organisation / Role City / Comment Response Town “Revision of General Authorisation in terms of Section 39 of the National water Act, 1998 (Act 36 of 1998)”, 6 September 2013, Table 2.1: “Wastewater limit values applicable to discharge of wastewater into a water resource”.

The inlet works and outlet channel so to be Monitoring of flow has been included in the final BAR constructed shall also cater for the and operational EMP. installation of inflow and outflow measuring  The installation of flow measuring devices devices which are ascribed as a must be done at the inlet works and outlet requirement in daily operations of the channel for measuring of inflow and wastewater treatment works; outflow.

All mitigation measures and precaution Measures to manage stormwater and water containing must be undertaken to collect stormwater waste are included in the BAR and EMPs. runoff containing waste or wastewater emanating from the proposed upgrades as well as associated activities and/or infrastructure activities susceptible to pollute water resources and be retained for disposal; All designs shall adhere to the required Mitigation measures are included in the final BAR and wastewater facility engineering designs as EMPs. such, the anaerobic oxidation pond system  Existing leaks and overflows need to be should ideally be lined with concrete slab to attended to immediately. limit any seepages and/or percolation of  An investigation of existing ponds must be groundwater resource by contaminants and done; lining of all existing ponds is required. the series of other ponds be lined with The DWS have provided the following geosynthetic liners etc.; comment ” the anaerobic oxidation pond system should ideally be lined with concrete slab to limit any seepages and/or percolation of groundwater resource by contaminants and the series of other ponds be lined with geosynthetic liners etc”  Detailed designs of all project components must be approved prior to commencement of construction. Ablution and/or sanitation facility for the This recommendation has been included in the final workers/ contractors on site shall be BAR and EMPs. provided during construction phase to

November 2019

5 Name Organisation / Role City / Comment Response Town ensure the environment and health of CEMP population is not negatively impacted, and • Ablution and/or sanitation facilities must be the service schedule must be drawn and provided for the workers/ contractors during construction consequently adhered to; phase and adequately serviced and maintained for the duration of construction. • The construction camp and necessary ablution facilities meant for construction workers must be beyond the 42m of any of the watercourses and 56m of the wetlands.

OEMP • Ensure the provision of maintenance facilities / equipment is provided including, inter alia, storage and ablutions, spare pumps (stored off-site for safety), lifting equipment (davits, block and tackle etc.), and cleaning supplies/equipment (rakes, nets, bins, brooms etc.)

Implementation of mitigation measures to Mitigation measures have been included in the final safeguard dust over spraying of the BAR and construction EMP. exposed soil during construction activities  Topsoil should be cleared in a phased in order to limit possibilities of soil erosion manner to avoid large areas of that may result into overloading of unconsolidated soils. sediments into water resources;  Topsoil and subsoil stockpiles should be covered and wetted and stabilised to prevent wind erosion and dust generation.  As necessary, dampen exposed soil areas on very windy days (>45 km/hr wind speeds) to prevent soil erosion by wind. A water cart or sufficient watering equipment should be available to wet soils during windy days if wind-blown sand and dust becomes a problem. During strong wind conditions it may be necessary to halt operations until conditions improve.  Once structures and infrastructure are in place, rehabilitate open areas with indigenous seeds and topsoil.

The water use activity to dispose of waste A water use license application has been lodged. and water containing waste will trigger

November 2019

6 Name Organisation / Role City / Comment Response Town Section 21 g of the National Water Act (NWA), 1998 (Act 36 of 1998). Therefore a Water Use Licence Application (WULA) must be lodged on the electronic Water Use Licence Application and Authorisation System (e-WULAAS) with the Department; On commissioning of Clarkson WWTW, the This recommendation has been included in the final Koukamma Local Municipality is mandated BAR and construction EMP. to undertake rigorous monthly samples of  Baseline and monthly monitoring of the the final discharged effluent to the effluent will be required to ensure environment in order to determine if the compliance to the discharge limits as works adheres to the discharged limits as qualified by the National Water Act (Act 36 qualified by the National Water Act (Act 36 of 1998) and its relevant regulations; of 1998) and its relevant regulations; The Office reserves the right to amend the Noted initial comments and add more information when deemed necessary, strictly to protect water resources from contaminants. Please note that any use of water without Noted an authorization is a contravention as in accordance with Section 151 of the National Water Act, 1998 (Act 36 of 1998).

November 2019

CEN INTEGRATED ENVIRONMENTAL MANAGEMENT UNIT

Environmental and Rural Development Specialist

Record of Meeting Phasing of the Upgrade of Clarkson sewage infrastructure and WWTW (EC09/C/LN1&3/M/45-2019)

A meeting was held at the Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) to discuss proposed project.

Date of meeting: 4 October 2019 Time of meeting: 11 am

The meeting was held between representatives of:

• Department of Economic Development, Environmental Affairs and tourism o Mr Leon Els o Mr Andries Struwig • Koukamma Local Municipality o Mr P.M Kate • GG & G Consulting Engineers (Pty) Ltd o Mr Saadiq Agherdien • CEN IEM Unit o Ms Claire De Jongh

1. Purpose of meeting

A meeting was held in response to a query submitted to DEDEAT on 17 September 2019 on whether the proposed upgrading of the Clarkson sewage network be implemented in two phases; and to determine whether phase 1 can proceed, whilst phase 2 will only proceed after the integrated environmental authorisation and waste management license has been issued. 2. Description of project

A brief description of the proposed upgrade of the sewage network and WWTW was provided.

Phase 1 would entail replacing the gravity mains (160mm) in the residential areas. The septic tanks and small-bore house connections will not be replaced in Phase 1. The gravity line and house connections will be developed mostly within existing footprints (i.e. roads, paved areas). Phase 2 would include the remaining upgrade of the sewage network and waste water treatment works and will include the area where the gravity line crosses watercourses. Phase 1 and 2 are indicated below in Figures 1 and 2. The green area represents phase 1.

Figure 1: Phase 1 area indicated in green

Figure 2: Phase 1 area indicated in green

3. Discussion

Due to budget related matters (i.e. financial years), the applicant (Koukamma Local Municipality) is enquiring if phase 1 can proceed, whilst phase 2 will only proceed after the integrated environmental authorisation and waste management license has been issued by the DEDEAT.

Phase 1 would not trigger listed activities (NEMA, NEMWA, NWA). However, it was decided that the project will not be phased due to the following reasons: 1. Phase 1 is dependent on licensing and authorisation of Phase 2; If Phase 1 is not approved, then Phase 2 cannot be fully implemented. 2. The application includes phase 1 and 2. A new application would need to be submitted if the two phases are split. This would increase time frames for decision making.

Additional items discussed:

• If an integrated WML and EA is received for the project, sludge removed from conservancy tanks can be treated at Clarkson WWTW • It was confirmed that management of Screenings and grit (burying in unlined trenches, treating with lime and covering) will it trigger Category B7 (Disposal of any quantity hazardous waste to land) and therefore a full EIA will be required. • The decision making time frame for the Department of Water and Sanitation to make a decision on the water use license in 300 days. A similar meeting is recommended to be held with DWS regarding decision making timeframes.

4. Conclusion

Due to budget constraints, the engineering team and the environmental consultant will endeavour to submit the final basic assessment before the required timeframe (11 December 2019).

The draft and final BAR will contain all required information to make an informed decision.

The DEDEAT will not need to use the maximum time permitted (107 days) to make a decision.

Conditions that may be included in the WML and EA (i.e. final designs, geotechnical studies, method statements) will try and be submitted with the final BAR so that preconstruction requirements can be met soon after the EA and WML is issued, and construction can commence soon after an authorisation is received.

The application includes phase 1 and 2. A new application would need to be submitted if the two phases are split. This would increase time frame. Appendix E1: Site Notices, BID, Adverts and Comment Received

Site notices, notifying the public of the intent of the developer to apply for environmental authorisation, were placed on at entrance to the Clarkson WWTW and in Clarkson town (on fence of the local school). The Site notices were placed on 7 June 2019. Notices were also dropped in post boxes. Interested and Affected Parties were requested to register by 7 July 2019.

Site notices were place on either side of 2nd Avenue, located outside the access point of Erf 3783.

4 Advert was placed in the Herald on 7 June 2019. Registration closed 7 July 2019.

5 Distribution of notice and BID on 11 June 2019 requesting registration / comment by 15 July 2019

6 BACKGROUND INFORMATION DOCUMENT Upgrading of Waste Water Treatment Works at Clarkson Cool! Koukamma Local Municipality Sarah Baartman District Municipality

11 June 2019

PURPOSE OF THE BACKGROUND INFORMATION DOCUMENT

Koukamma Municipality is proposing to replace the existing small-bore sewerage network and upgrade the existing waste water treatment works at Clarkson.

The purpose of this Background Information Document (BID) is to provide stakeholders with additional information, the opportunity to register as Interested and Affected Parties and to obtain their initial comments on the proposed upgrading of the Clarkson waste water treatment works (WWTW) located in Kou-Kamma local municipality of the Eastern Cape Province. The following is required before the project may commence: • Environmental authorisation (EA) from Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) in terms of the NEMA 2014 EIA Regulations (as amended, 2017) 2549

• Waste management license (WML) from DEDEAT in terms of Regulation 921 of the

National Environmental Management: Waste Act (Act 59 of 2008) (NEMWA)

086 504 • Water Use License Authorisation (WULA) from the Department of Water and Sanitation (DWS) in terms of Section 21 of the National Water Act, 1998 (Act No. 36

Fax: of 1998) / The purpose of the environmental assessment is to identify potential impacts associated with the proposed project and to recommend measures to avoid or reduce adverse 2983 -

rt Elizabeth 6070 Elizabeth rt impacts and enhance beneficial or positive impacts. 581

If you would like to participate in the process, please register yourself and/or your [email protected]

36 River Road River 36 organization: as an Interested and Affected Party. Submit issues that you feel need to be addressed in the assessment by completing the response form or in a letter or by email mail -

to:E

Walmer, Po Walmer, Claire de Jongh, CEN IEM Unit 36 River Road, Walmer Telephone: 041 Port Elizabeth, 6070 mailto:[email protected]

All comments must be submitted within 30 days (excluding public holidays and/or period between 15 December and 2 January) of the date of this notice. Date of Notice: 12 June 2019 CEN Integrated Environmental Management Unit Management Environmental CEN Integrated Closing Date for comments on BID: 15 July 2019

1. THE PROPOSED PROJECT

1.1. Location Clarkson is located on Farm 654 in the Koukamma local Municipality, Sarah Baartman District Municipality in the Eastern Cape province. The Clarkson WWTW is accessed via the R102 and is positioned approximately 500 m south of R102 and 80m north of the N2. The Central coordinates of the WWTW site: 34° 1'26.80"S; 24°20'55.64"E.

Figure 1: Location of Clarkson WWTW

1.2. Design and Layout The existing Clarkson WWTW is a 0.33 Mℓ/day oxidation pond system. The WWTW is proposed to be upgraded by providing one new maturation pond, one new drying bed, inlet works with hand-raked screens and degritting facilities and an onsite storage room. Access to the plant site will be improved. Note: The addition of a drying bed is subject to approval by Koukamma Municipality Technical Services and may be removed from scope, owing to limitations on available operational costs relating to management and maintenance. Resultingly, should the sludge lagoon/drying bed be excluded, sludge will need to be removed and disposed of offsite by registered permit holders (i.e. during desludging at implementation and during operational stage). Replacing the existing sewerage network will entail replacing existing septic tanks with house connections (±9.1km pipelines), replacing existing sewer lines (±6.6km), installing precast manholes (±85) and upgrading two existing pump stations.

Figure 2: Proposed upgrading of Clarkson WWTW

Figure 3: Proposed upgrading with sewer network indicated

Overview of Environment Farm 654 is approximately 600 hectares in extent; the existing footprint of the WWTW is approximately 1.1 ha in extent. According to the Vegetation Map (Mucina and Rutherford, 2012) the natural vegetation mapped on site is Tsitsikamma Sandstone Fynbos, falling within the Fynbos biome and eastern fynbos-renosterveld bioregion. The conservation status of Tsitsikamma Sandstone Fynbos is vulnerable (conservation target: 23%); the protection status is poorly protected (NBA, 2011). Tsitsikamma Sandstone Fynbos is not listed on the National List of Ecosystems that are threatened and in need of protection, published in terms of the National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004). Farm 654 falls within a terrestrial critical biodiversity area (CBA) 1 as mapped by the Eastern Cape Biodiversity Conservation Plan, 2007 (ECBCP). The site falls within quaternary catchment M20A. In terms of the ECBCP, 2007, the project site falls within an aquatic CBA. The site is not situated within 500 m of any wetlands or rivers mapped by National Freshwater Ecosystem Priority Areas (NFEPA).

Figure 4: National Vegetation (Mucina and Rutherford, 2012)

Figure 5: Project site falls within terrestrial CBA1 (ECBCP) and within 5km of protected area

Figure 6: Project site located within aquatic CBA 1 (ECBCP)

2. ENVIRONMENTAL ASSESSMENT PROCESS

2.1. National Environmental Management Act and 2014 EIA Regulations (amended, 2017) The Minister of Environmental Affairs has in terms of Sections 24 and 24D of the National Environmental Management Act (Act No. 107 of 1998) (NEMA), as amended, listed the activities that require an environmental assessment. In terms of the 2014 Environmental Impact Assessment Regulations (as amended, 2017) the proposed development triggers activities listed in GNR. 327 and 324 and are subject to an assessment. The competent authority is the Eastern Cape Provincial Department of Economic Development, Environmental Affairs and Tourism (DEDEAT). See Table 1. Table 1: Commencement of unlawful activities in terms of NEMA Listed Activities Listing Notice 3 of 2014 EIA Regulations, as amended, 2017 GNR. 324 Project site falls within aquatic and terrestrial CBA Activity 12 (ECBCP) The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan. a. Eastern Cape ii. Within critical biodiversity areas identified in bioregional plans. GNR. 324 Project site falls within aquatic and terrestrial CBA Activity 18 (ECBCP) and within 5km of formal protected area

The widening of a road by more than 4 metres, or the lengthening of a road by more than 1 kilometre.

a. Eastern Cape i. Outside urban areas: (ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans. (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; Listing Notice 1 of 2014 EIA Regulations, as amended, 2017 GNR. 327 The proposed site is approximately 5 hectares. The Activity 27 vegetation occurring on most of the site has been mapped The clearance of an area of 1 hectares or as Algoa Sandstone Fynbos by Mucina and Rutherford, more, but less than 20 hectares of indigenous 2012. The site falls within a terrestrial CBA as mapped by vegetation, except where such clearance of the ECBCP, 2007 and the NMB Bioregional Plan, 2014. indigenous vegetation is required for- More than 1 hectares of vegetation will be cleared. i. The undertaking of a linear activity; or

ii. Maintenance purposes undertaken in accordance with a maintenance management plan

2.2. National Environmental Management: Waste Act The following activities listed in Category A of Regulation 921 published in terms of the National Environmental Management: Waste Act (Act 59 of 2008) are likely to be triggered: (1) The storage of waste in lagoons (13) expansion of a waste management activity listed in Category A or B

A basic assessment process as set out in the EIA regulations of NEMA is required for waste management activities listed under Category A of NEMWA Regulation 921 An integrated application will be submitted to the DEDEAT for approval of the environmental authorisation and waste management license in terms of the 2014 EIA Regulations and the NEMWA Regulations

2.3. National Water Act Depending on the final design and operation of the project, several water uses, as defined in terms of Section 21 of the National Water Act, 1998 (Act No. 36 of 1998), may form part of the proposed project, these include: • Engaging in a controlled activity identified as such in section 37(1) or declared in section 36. • Section 21(f) – discharging waste or water containing waste into a water resource through a pipe, canal or other conduit. • Section 21(g) – disposing of waste in a manner which may detrimentally impact on a water resource.

The need for this application can only be determined once a detailed development plans are available. The Department of Water Affairs and Sanitation will be registered as an interested and affected party in the process. A Water Use License Application (WULA) will be lodged with the Department of Water and Sanitation and the relevant supporting documents prepared, to obtain the required license. The WULA process will run in parallel with the NEMA process.

1.1. Impact Assessment Process A Basic Assessment process is carried out to identify and assess potential impacts associated with the proposed development. Mitigation measures to reduce anticipated negative impacts and enhance anticipated positive impacts are recommended. Public participation process is carried out according to NEMA EIA Regulation 41 of GN R.326, 2017. All interested and affected parties (IAPs) are encouraged to participate. The basic assessment concludes with recommendations and conditions for environmental authorisation.

1.2. Some Identified Issues As we progress with the environmental investigations we will identify potentially beneficial and adverse impacts. All identified impacts will be subjected to an assessment to determine if they are significant and if

7 they require additional investigation. Possible mitigation measures will also be provided to reduce the identified adverse impacts and enhance identified beneficial impacts. Based on our preliminary investigations we have identified the following impacts:

• Biodiversity impacts • Groundwater impacts • Heritage impacts • Socio-economic impacts

1.3. Description of Tasks within the Basic Assessment Process  Notification of the intended application for Environmental Authorisation are sent to identified stakeholders, landowners and adjacent landowners prior to submission of the application for Environmental authorisation to the competent authority, namely the DEDEAT for this project. – We are here in the process.  Public participation starts announcing the proposed project and the registration of Interested and Affected Parties (I&APs). Newspaper advertisements and site notices are placed, and notifications are also sent to identified stakeholders – We are here in the process.  An integrated application for Environmental Authorisation and waste management license is submitted to the competent authority.

 A Basic Assessment Report is compiled that considers inputs from stakeholders, IAPs and specialists, in terms of: o potential impacts of the activity on the environment; o whether the impacts can be mitigated, and if so to what extent; and, o whether there are any other significant issues / impacts to be investigated.

 Once the Basic Assessment Report is compiled, it is then submitted for a 30-day review period to registered IAPs and stakeholders. This enables you to comment on the Basic Assessment Report and accompanying Environmental Management Programme.

 Your comments are incorporated, and the reports are then finalised.

 These final reports are submitted to the DEDEAT for consideration.

 The DEDEAT reviews the documents and decides whether the project can proceed or not.

 An Environmental Authorisation (EA) and waste management license (WML), with conditions, is issued to the applicant if the proposed development may proceed.

 A copy of the EA is made available to you to consider, along with the reasons for the decision made. If you disagree with the decision, you are provided with information on how to lodge an appeal.

2. HOW DO YOU PARTICIPATE Every proposed project and/or development has the potential to significantly affect the natural and social environments, both at, as well as, surrounding the proposed development site. While some of the impacts will have an adverse impact on the environment others will have a beneficial impact. For this reason, it is imperative that you as an Interested and/or Affected Party (I&AP) comment on the proposed development and raise issues or concerns that you feel needs to be considered during the proposed planning and implementation process.

This can be done by completing the attached registration form and submitting it to the contact details as reflected. Upon submission of the registration form to CEN IEM Unit, you will be registered as an I&AP, and be included on an I&APs database which will ensure that you receive future project information and notifications regarding reports available for public comment.

If you intend to register as an I&AP or forward comments regarding the proposed development, please submit your completed registration form to CEN IEM Unit by 15 July 2019.

CEN IEM UNIT

36 River Road, Walmer, Port Elizabeth 6070

Fax 086 504 2549 Email [email protected]

REGISTRATION / COMMENT SHEET Upgrading of Waste Water Treatment Works at Clarkson Koukamma Local Municipality Sarah Baartman District Municipality

11 June 2019 I wish to register as an Interested and / or Affected Party and request that the following issues receive attention during the assessment process Closing Date for Comments on BID: 15 July 2019

Name of Respondent: ______

Organisation / Company: ______

Address: ______

Fax Number: ______

Tel Number: ______

Email: ______Please use additional sheets as necessary Signature: ______Date: ______

Comments Received

7 [email protected]

From: Maneli Mzukisi (ELS) Sent: Wednesday, 12 June 2019 10:25 AM To: Heymann Ncumisa (ELS); Mmachaka Thandi (PLZ) Cc: [email protected]; Mpumela Ntombiyamayirha(PLZ); Ndima Manelisi (PLZ) Subject: FW: Notice - Environmental assessment: Clarkson Waste Water Treatment Works Attachments: Clarkson WWTW BID .pdf

Dear colleagues,

Herewith please find for your attention.

Regards

Mzukisi Maneli Department of Water and Sanitation Mzimvubu-Tsitsikamma Proto-CMA Water Information Management Private Bag X6041 Port Elizabeth - 6000 Tel: +27 41 501 0738 Fax2Mail: +27 86 756 1010 Cell: +27 82 881 9846 E-mail: [email protected]

From: [email protected] [mailto:[email protected]] Sent: Tuesday, June 11, 2019 11:05 AM To: 'Mike Cohen' Subject: Notice - Environmental assessment: Clarkson Waste Water Treatment Works

To: Organs of state / Interested and affected parties

Koukamma Municipality is proposing to replace the existing small-bore sewerage network and upgrade the existing waste water treatment works at Clarkson. The following is required before the project may commence: • Environmental authorisation (EA) from Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) in terms of the NEMA 2014 EIA Regulations (as amended, 2017) • Waste management license (WML) from DEDEAT in terms of Regulation 921 of the National Environmental Management: Waste Act (Act 59 of 2008) (NEMWA) • Water Use License Authorisation (WULA) from the Department of Water and Sanitation (DWS) in terms of Section 21 of the National Water Act, 1998 (Act No. 36 of 1998)

The environmental authorisation and waste management license process requires a basic assessment to be carried out.

1 A Background Information Document (BID) is attached which provides additional information on the proposed project and the basic assessment process. A public participation process will be carried out according to NEMA Regulation 41 of GN R. 326, 2017. Please register as an interested and affected party and / or submit comments on the BID by 15 July 2019.

Kind Regards

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2 [email protected]

From: Ted T. Pillay Sent: Tuesday, 11 June 2019 1:26 PM To: Theo T. Betha Cc: [email protected] Subject: FW: Notice - Environmental assessment: Clarkson Waste Water Treatment Works Attachments: Clarkson WWTW BID .pdf

Dear Theo

I support the development.

TED PILLAY MUNICIPAL MANAGER

32 GOVAN MBEKI AVENUE, PO BOX 318, PORT ELIZABETH, 6000, SOUTH AFRICA CELL : +27 83 458 9641 TEL : +27 41 508 7114 FAX : +27 41 508 7066 [email protected] | www.sarahbaartman.co.za

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From: [email protected] [mailto:[email protected]] Sent: 11 June 2019 11:05 AM To: 'Mike Cohen' Subject: Notice - Environmental assessment: Clarkson Waste Water Treatment Works

To: Organs of state / Interested and affected parties

The environmental authorisation and waste management license process requires a basic assessment to be carried out.

Kind Regards

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2 [email protected]

From: [email protected] Sent: Wednesday, 12 June 2019 11:01 AM To: 'Nokukhanya Khumalo' Cc: 'Mike Cohen ([email protected])' Subject: RE: Notice - Environmental assessment: Clarkson Waste Water Treatment Works

Thank you

Mr Makhanya has been notified.

Kind Regards

From: Nokukhanya Khumalo Sent: Wednesday, 12 June 2019 9:05 AM To: [email protected]; 'Mike Cohen' Subject: RE: Notice - Environmental assessment: Clarkson Waste Water Treatment Works

Good Morning

Thank you for informing SAHRA of this proposed development, however by law SAHRA is unable to comment on any developments located in the Eastern Cape. Therefore, all applications must be directed to the Eastern Cape Heritage Resources Authority. The contact person is Mr Sello Makhanya and his email address is [email protected]

Kind Regards, Nokukhanya Khumalo

From: [email protected] Sent: 11 June 2019 11:05 AM To: 'Mike Cohen' Subject: Notice - Environmental assessment: Clarkson Waste Water Treatment Works

To: Organs of state / Interested and affected parties

1 • Environmental authorisation (EA) from Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) in terms of the NEMA 2014 EIA Regulations (as amended, 2017) • Waste management license (WML) from DEDEAT in terms of Regulation 921 of the National Environmental Management: Waste Act (Act 59 of 2008) (NEMWA) • Water Use License Authorisation (WULA) from the Department of Water and Sanitation (DWS) in terms of Section 21 of the National Water Act, 1998 (Act No. 36 of 1998)

The environmental authorisation and waste management license process requires a basic assessment to be carried out. A Background Information Document (BID) is attached which provides additional information on the proposed project and the basic assessment process. A public participation process will be carried out according to NEMA Regulation 41 of GN R. 326, 2017. Please register as an interested and affected party and / or submit comments on the BID by 15 July 2019.

Kind Regards

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Nokukhanya Khumalo Heritage Officer: Archaeology, Palaeontology & Meteorites Unit

South African Heritage Resources Agency - A nation united through heritage -

2 [email protected]

From: Chumisa Njingana (SR) Sent: Tuesday, 09 July 2019 3:28 PM To: '[email protected]'; 'Mike Cohen' Subject: RE: Notice - Environmental assessment: Clarkson Waste Water Treatment Works Attachments: SC Application Process.pdf; Table A Statutory Control application Process.pdf; SCOMS - Encroachment for Engineering and Other Services 5 SR.PDF

Importance: High

Good day Claire

Hope all is well.

Please find the attachment for your attention, for your below enquiry.

Have a blessed day.

Kind regards Chumisa

Chumisa Njingana (SR) Statutory Control Administrator

20 Shoreward Drive, Baywest, Port Elizabeth, Eastern Cape, 6025, South Africa D: 041 398 3251 | M: [email protected] | www.sanral.co.za Fraud Hotline Number - 0800 204 558

Please consider the environment before printing.

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From: [email protected] [mailto:[email protected]] Sent: 11 June 2019 10:57 AM

1 To: 'Mike Cohen' Subject: Notice - Environmental assessment: Clarkson Waste Water Treatment Works Importance: High

To: Landowner / Surrounding Landowners

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CEN INTEGRATED ENVIRONMENTAL MANAGEMENT UNIT Environmental and Rural Development Specialist

UPGRADING OF CLARKSON SEWAGE NETWORK AND WASTE WATER TREATMENT WORKS Koukamma Local Municipality, Sarah Baartman District Municipality, Eastern Cape

Public Participation process carried out in terms the National Environmental Management Act (Act 107 of 1998) Regulation 41 of GN R.326

Attention: Marissa Bloem Date: 19 November 2019 Email: [email protected]

The comments from the Department of Water and Sanitation on the draft basic assessment report for the upgrading of Clarkson Sewage network and wastewater treatment works in Koukamma Local Municipality, Eastern Cape, dated 31 October 2019, were received via email on 15 November 2019.

The final Basic Assessment Report will be submitted to the Department of Economic Development, Environmental Affairs and Tourism for decision making regarding environmental authorisation and will be distributed to all registered interested and affected parties. Further comments on the final BAR will be requested to be submitted directly to the DEDEAT.

The response to your comments received 15 November 2019 via email is provided in the attached table.

Kind Regards

Claire De Jongh CEN IEM Unit

36 River Road, Walmer, Port Elizabeth. 6070 Phone 084 607 4743 Fax (086) 5042549 Email: [email protected] / [email protected] Table 1: Comments and Responses

Comment Response From a water resource management perspective, this Office has no Noted objection on the anticipated upgrades of the Clarkson Wastewater Treatment Works to be undertaken, provided that the following will be noted and complied with: As contemplated in the report, "the emergency ponds located nearby the This recommendation has been included in the final basic two pump stations at Clarkson are currently overflowing into the water assessment report (BAR) and construction environmental resource" a provision should be made in ensuring water resource management programme (EMP) operational EMP. contamination by the spillages emanating from the emergency ponds is  Spillages currently emanating from the emergency ponds ceased immediately and during operational phase of the works, early are to be ceased immediately warning systems are implemented to safeguard the recurrence of spillages  Emergency ponds at pump stations are to be lined with thereto; impermeable linings.  Construct an earthen berm/bund wall around the emergency ponds  Construct an earthen berm / bund wall around the pumping station to ensure that any unavoidable spills are limited to the ponds and/or pumping station areas.  Installation of controls to equally cycle both pumps, and wireless level warnings (at maximum/inlet level and overflow level) with alarm systems (e.g. via GSM uplink) to alert controllers, supervisors and/or management are recommended A baseline analysis of the final effluent at the works should be provided, This recommendation has been included in the final BAR and having ascertained that the maturation ponds will be constructed with an construction and operational EMPs. outflow channel with the aim of controlled discharge of final effluent into the  Baseline and monthly monitoring of the effluent will be environment, although not specified the type of environment (i.e. be it a required to ensure compliance to the applicable limits. water resource or irrigation of the land), this office is hereby uncertain  Irrigation with effluent may only take place if effluent is treated whether the final effluent is complaint and/or will be complying with the to the General limit values given in the Government Gazette, discharge quality standards; “Revision of General Authorisation in terms of Section 39 of the National water Act, 1998 (Act 36 of 1998)”, 6 September 2013, Table 2.1: “Wastewater limit values applicable to discharge of wastewater into a water resource”. Other alternatives of effluent disposal could be explored such as re-use in Re-use of effluent has been considered. Due to lack of electricity the form of irrigation where the land is available to minimize or control the on site, and natural gradient of the site, re-use of effluent is amount of effluent being discharged into the water resources, however, difficult without pumping. taking into account the applicable guiding principles or legislation for the activity; The following measure is included in the final bar and EMP’s:  Irrigation with effluent may only take place if effluent is treated to the General limit values given in the Government Gazette, “Revision of General Authorisation in terms of Section 39 of the National water Act, 1998 (Act 36 of 1998)”, 6 September 2013, Table 2.1: “Wastewater limit values applicable to discharge of wastewater into a water resource”.

The inlet works and outlet channel so to be constructed shall also cater for Monitoring of flow has been included in the final basic the installation of inflow and outflow measuring devices which are ascribed assessment report and operational environmental management as a requirement in daily operations of the wastewater treatment works; programme.  The installation of flow measuring devices must be done at the inlet works and outlet channel for measuring of inflow and outflow.

All mitigation measures and precaution must be undertaken to collect Measures to manage stormwater and water containing waste are stormwater runoff containing waste or wastewater emanating from the included in the BAR and EMPs. proposed upgrades as well as associated activities and/or infrastructure activities susceptible to pollute water resources and be retained for disposal; All designs shall adhere to the required wastewater facility engineering Mitigation measures are included in the final BAR and EMPs. designs as such, the anaerobic oxidation pond system should ideally be  Existing leaks and overflows need to be attended to lined with concrete slab to limit any seepages and/or percolation of immediately. groundwater resource by contaminants and the series of other ponds be lined with geosynthetic liners etc.;  An investigation of existing ponds must be done; lining of all existing ponds is required. The DWS have provided the following comment ” the anaerobic oxidation pond system should ideally be lined with concrete slab to limit any seepages and/or percolation of groundwater resource by contaminants and the series of other ponds be lined with geosynthetic liners etc”  Detailed designs of all project components must be approved prior to commencement of construction.

Ablution and/or sanitation facility for the workers/ contractors on site shall This recommendation has been included in the final BAR and be provided during construction phase to ensure the environment and health EMPs. of population is not negatively impacted, and the service schedule must be drawn and consequently adhered to; CEMP  Ablution and/or sanitation facilities must be provided for the workers/ contractors during construction phase and adequately serviced and maintained for the duration of construction.  The construction camp and necessary ablution facilities meant for construction workers must be beyond the 42m of any of the watercourses and 56m of the wetlands.

OEMP  Ensure the provision of maintenance facilities / equipment is provided including, inter alia, storage and ablutions, spare pumps (stored off-site for safety), lifting equipment (davits, block and tackle etc.), and cleaning supplies/equipment (rakes, nets, bins, brooms etc.)

Implementation of mitigation measures to safeguard dust over spraying of Mitigation measures have been included in the final BAR and the exposed soil during construction activities in order to limit possibilities of construction EMP. soil erosion that may result into overloading of sediments into water  Topsoil should be cleared in a phased manner to avoid resources; large areas of unconsolidated soils.  Topsoil and subsoil stockpiles should be covered and wetted and stabilised to prevent wind erosion and dust generation.  As necessary, dampen exposed soil areas on very windy days (>45 km/hr wind speeds) to prevent soil erosion by wind. A water cart or sufficient watering equipment should be available to wet soils during windy days if wind-blown sand and dust becomes a problem. During strong wind conditions it may be necessary to halt operations until conditions improve.  Once structures and infrastructure are in place, rehabilitate open areas with indigenous seeds and topsoil.

The water use activity to dispose of waste and water containing waste will A water use license application has been lodged. trigger Section 21 g of the National Water Act (NWA), 1998 (Act 36 of 1998). Therefore a Water Use Licence Application (WULA) must be lodged on the electronic Water Use Licence Application and Authorisation System (e- WULAAS) with the Department; On commissioning of Clarkson WWTW, the Koukamma Local Municipality This recommendation has been included in the final BAR and is mandated to undertake rigorous monthly samples of the final discharged construction EMP. effluent to the environment in order to determine if the works adheres to the  Baseline and monthly monitoring of the effluent will be discharged limits as qualified by the National Water Act (Act 36 of 1998) and required to ensure compliance to the discharge limits as its relevant regulations; qualified by the National Water Act (Act 36 of 1998) and its relevant regulations;

The Office reserves the right to amend the initial comments and add more Noted information when deemed necessary, strictly to protect water resources from contaminants. Please note that any use of water without an authorization is a contravention Noted as in accordance with Section 151 of the National Water Act, 1998 (Act 36 of 1998).

Appendix E2: Full register of Interested and Affected Parties

Full register of Interested and Affected Parties (August 2019) Name Organisation / Role City / Town Registration date Contact Details Email (available on request) Project Applicant Koukamma Municipality Technical Services Kareedouw Automatically 042 288 7227 [email protected] Simphiwe Arosi Project Management Unit: registered Manager Engineers Godwyn Smith GG&G Consulting PE Automatically +27 (0) 41 582 3835 [email protected] Engineers (Pty)Ltd registered Saadiq Agherdien GG&G Consulting PE Automatically +27 (0) 41 582 3835 [email protected] Engineers (Pty)Ltd registered Thabo Pudumo GG&G Consulting PE Automatically +27 (0) 41 582 3835 [email protected] Engineers (Pty)Ltd registered Landowners MORAVIAN CHURCH IN Landowner Cape Town Automatically 021 761 4030 [email protected] SOUTH AFRICA C03400000000065400000 registered 63 Albert Road, Farm 654 Farm 654 LANSDOWNE, Portion 0 (RE) Portion 0 (RE) CAPE TOWN Western Cape Mr. L. Mcubusi 7780 President of the church

Reverend G. Cunningham Head of Church Neighbouring landowners Farms REPUBLIEK VAN SUID- Eastern Cape Roads and PE Automatically 041 403 6043 [email protected] / AFRIKA Public Works - Marius registered [email protected] Farm 373 Keyser [email protected] Portion 0 Prov. Department of C0340000000003770000 Transport & Public Works - 0 Mzi Mafani Farm 377 Portion 0 National Department of Transport & Public Works – C0340000000007880000 Brian Stander 1 Farm 788 Portion 1 MORAVIAN CHURCH IN Landowner Cape Town Automatically 021 761 4030 [email protected] SOUTH AFRICA C03400000000065400000 registered 63 Albert Road, Farm Farm 654 LANSDOWNE, CHARLOTTENBURG Portion 0 (RE) CAPE TOWN Farm 375 Western Cape Portion 0 Mr. L. Mcubusi 7780 President of the church C0340000000006310000 0 Reverend G. Cunningham Farm 631 Head of Church Portion 0 Chumisa Njingana / SANRAL PE Automatically 20 Shoreward Drive, [email protected] / Nanna Gouws Statutory Control registered Baywest, Port SOUTH AFRICAN Administrator Elizabeth, Eastern [email protected] NATIONAL ROADS Cape, 6025, South AGENCY S O C LTD Africa 041 398 3251 [email protected] (SANRAL)

C0340000000006540000 3 Farm 654 Portion 3

C0340000000007880000 2 Farm 788 Portion 2

Comments and Response Report Final Basic Assessment Report UPGRADING OF CLARKSON SEWAGE NETWORK AND WASTE WATER TREATMENT WORKS Koukamma Local Municipality, Sarah Baartman District Municipality, Eastern Cape

8 Name Organisation / Role City / Town Registration date Contact Details Email (available on request) TSITSIKAMMA David Scheepers [email protected] DEVELOPMENT TRUST- Independent Trustee [email protected] MFENGU Makamba – chairman of C0340000000007880000 trust (0824011557) 7 Farm 788 P.R Hela Portion 7 Thobile Didiza C0340000000007880000 8 Z.J Blouw Farm 788 Portion 8 C0340000000007880001 No landowner details 5 Farm 788 Portion 15 No landowner details C0340000000008990000 0 Parks No landowner details Deliver notice – ward C0340022000000020000 councillor 0 No landowner details Deliver notice – ward C0340022000002540000 councillor 0 Cadastral Erven C0340022000000130000 Deliver notice – post box 0 – drop C0340022000000550000 0 No details Deliver notice – post box C0340022000001850000 drop 0 Stakeholders / IAPS Griffiths Morgan WESSA EC Automatically [email protected] registered Siphokazi Nonyukela Koukamma news Kareedouw 042 288 7247 [email protected] .za

Hesron Ruiters Tsitsikamma National Park (042) 281 1607 [email protected] / Thuthula Fobosi [email protected] Nonkathalo Kete Transnet EC EC Automatically [email protected] registered EC Automatically Sharlene Matthews AGRI EC registered [email protected] EC Automatically [email protected]; Mavis Stiole registered [email protected]; Zandi Siyongwana [email protected]; Thandokazi Myingwa [email protected] Eddie Leach Eskom [email protected] Heritage Representative- EC Gamtkwa KhoiSan Council (represents Chief Ronald Kobus Reichert Booysen) [email protected] ORGANS OF STATE Ward councillor Koukamma Councillor Graham LM (Ward 5) – WWTW falls Goliadh within ward 5 Clarkson [email protected] Councillor Hester Paulina Ward councillor Koukamma 0746920233 Pullen LM (Ward 6) Clarkson 0780707769 Hester.pullen@ koukamma.gov.za Koukamma LM Koukamma Automatically 042 288 7210 registered P.O. Box 011 Mr Pumelelo Maxwell Kate Mayor Koukamma LM Kareedouw 6400 [email protected] Kareedouw Automatically 042 288 0303 registered 042 288 0797 P.O. Box 011 Koukamma LM Nathan Jacob Kareedouw 6400 [email protected]

9 Name Organisation / Role City / Town Registration date Contact Details Email (available on request) Kareedouw Automatically 042 288 7203 Environmental / registered 042 288 0797 Community Officer: P.O. Box 011 [email protected] Koukamma Municipality Thozamile Sompani Kareedouw 6400 a Sarah Baartman Cacadu DM Infrastructure Sarah Automatically B Makedama Director Baartman registered 041 508 7070 [email protected] Sarah Automatically Ted Pillay Sarah Baartman DM MM Baartman registered Tel: 041 508 7115 [email protected] Sarah Baartman DM Sarah Automatically Zoleka Sumi Environmental Health Baartman registered Tel: 0415087139 [email protected] Sarah Baartman DM Sarah Automatically P.O. Box 318, Port Buyisa Botha Municipal Manager's Office Baartman registered Elizabeth, 6000 [email protected] Cadadu Development PE Automatically Chris Wilken Agency registered 0415087106 Sarah Baartman District PE Automatically Municipality – Manager: registered Kellelo Makgoka Environmental Health 041 508 7272 [email protected] Sarah Baartman DM - PE Automatically 041 508 7339 [email protected] Director: Economic registered PM Kate Development Provincial and National Departments PE Automatically 041 508 5811 registered P/Bag X5001 Green Jeff Govender DEDEAT Acres P.E., 6057 [email protected] PE Automatically P/Bag X5001 Green Andries Struwig DEDEAT registered Acres P.E., 6057 [email protected] PE Automatically 140 Govan Mbeki registered Avenue, 6th Floor Starport Building, Port Elizabeth, 6000 Private Bag X6041, Port Elizabeth, 6000 T: +27 (0) 41 501 0717 F: +27 (0) Marisa Bloem DWS 86 537 4689 [email protected] Automatically 140 Govan Mbeki registered Avenue, 6th Floor Starport Building, Port Elizabeth, 6000 Private Bag X6041, Port Elizabeth, 6000 Potrait Tshatshu DWS PE [email protected] Automatically Mzukisi Maneli Department of Water Affairs registered [email protected] Maria Galimberti / PE Automatically Nokukhanya Khumalo SAHRA registered [email protected] Eastern Cape Heritage PE Automatically Resources Authority registered (ECPHRA) 043 642 2812 Sello Mokhanya Heritage officer 043 642 2811 [email protected] Bhisho Automatically 043 605 7052 ECape DEAET Manager: registered 043 605 7300 Environmental Impact P/Bag X 0054 [email protected] Siyabonga Gqalangile Management Bhisho 5605 ov.za Thabo Nokoyo DAFF PE Automatically [email protected] registered Anneliza Collett Department of Agriculture Automatically [email protected] registered Gcinile Dumse Department of Agriculture, Sarah Automatically 043 704 6812 [email protected] Fisheries and Forestry Baartman registered (DAFF) Regional Manager: Land Use & Soil Management