Aneesah Alwie
From: Allen Lyons
Follow Up Flag: Follow up Flag Status: Flagged
Gentlemen
See e-mail below from a Strandfontein home owner. Please record Mrs Snyman's in the appropriate EIA document.
Best regards
Allen Lyons
Secretary - Strandfontein Belastingbetalersvereniging (SBV)
From: henk snyman [mailto:[email protected]] Sent: 17 September 2018 06:52 PM To: Lehan Fouche Subject: Re: Beoogde JUNO Wind Energie Fasiliteit (Windplaas) op Plaas De Boom, Noord-oos van Strandfontein
�
Please convey the following to the relevant authorities as my objection to the windfall proposal on the� farm "De Boom"
�
�1. Tourism is currently one of the biggest creators of jobs and one of the fastest growing industries in South Africa. The ratio between tourists and job� created ranges from 1:1 to 1:4. That means that for every tourist year (for example a�bed night in a hotel or B&B,� say 360 per year) one person is employed�for the full�year.
�
Therefore, developing the area as a tourist attraction, will make a much bigger contribution to the community that the proposed windfarm.
�
2. South Africa is currently attracting more overseas visitors, even to and especially to individuals that wish to experience the wilderness and the solitude of a place such as Strandfontein. The local and international
1 tourists� has no interest in looking at a windfarm especially if it is�less than 2 km from where they are on holiday.
�
Therefore, the windfarm is a guaranteed tourism killer that will not, in the long term,�contribute to the development of the area and the people in the area in any way whatsoever.
�
Summary:
�
Developing the windfarm on the area proposed is a killer for any tourism activity, the�industry that creates the most jobs specifically for the local people.
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�I am therefore as a property owner of Strandfontein� and a citizen concerned with the long-term development of� sustainable jobs in the area, completely opposed to the windfarm positioning.
�
Yours truly,
�
Margaret Snyman
From: Lehan Fouche
�
Beste SBV lede en alle ander Strandfontein eienaars
�
Die SBV het by twee geleenthede breedvoerige kommentaar op die Konsep en Finale Omvangsverslae (Scoping reports) tydens die publieke kommentaarperiode gelewer. Hierdie kommentaar is in besit �van die Departement van Omgewingsake en is in proses van oorweging. Tydens die volgende Omgewingsimpakfase (EIA) en publieke deelname proses, moet verdere skriftelike insette tesame met ander ge�ntresseerde en geaffekteerde partye (I&AP) se kommentaar, deur die Departement oorweeg word.
� 2 Aangeheg is �n SBV Vrae en antwoord dokument van 13 September wat asb u dringende aandag as Strandfontein SBV lid/eienaar nodig het.
�
Ons sal dit waardeer as u addisionele kommentaar kan lewer, of u kan ons per epos nader as bykomende inligting oor die projek benodig word.
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Baie dankie vir elkeen se betrokkenheid en kommentaarlewering by die aansoekproses.
�
Vriendelike groete. �
�
Voorsitter
Strandfontein Belastingbetalersvereniging (SBV)
�
Strandfontein ��maak dit jou trots!�
�
Posbus 222
Doringbaai
8151
�
Sel no�s: 0787430549 (Lehan- Voorsitter)
3 ����������������� 0832328731 (Kobus- Tesourier)
����������������� 0836306120 (Allen- Sekretaris)
SBV E-pos: [email protected]
�
Virus-free. www.avg.com
4 Aneesah Alwie
Subject: FW: AMDA company details Attachments: AMDA Juliett letter to SBV 18 Sept 2018.pdf
From: Piero Granelli Sent: Tuesday, 18 September 2018 12:00 PM To: Allen Lyons
Dear Mr Lyons
Thank you for your email.
Attached please find our response to your enquiries.
Regards Piero
Piero Granelli CEO AMDA Developments (Pty) Ltd
Mobile: +27 82 333 3368 Email: [email protected]
22 Dreyer Street, Claremont, Cape Town PO Box 2681, Cape Town, 8000 www.amdadevelopments.co.za
From: Allen Lyons
Dear Mr Granelli
1 The SBV is a registered I&AP for the proposed Juno project. Ten days ago we requested a copy of a report mentioned in Arcus's final scoping study. We received a letter from AMDA dated 4 September expressing regret that the company was not in a position to share the requested information with the SBV.
The fatal flaw study conducted by Savannah Environmental in September 2016 was obviously a key moment in the process that has led to this current EIA. As the community that will be most affected by the proposed Juno project, we are duty bound to familiarise ourselves with the detail of Savannah’s “Screening Reporting and Potential Fatal Flaw Identification” study.
The SBV will submit a formal request in terms of PAIA to acquire the Savannah 2016 report. To that end could you please provide me with the company name and company details to which our PAIA application must be directed? Are we dealing with AMDA Developments or AMDA Juliett?
Could you also provide the name, title and contact details of the company representative to whom the PAIA application can be addressed?
I look forward to hearing from you at your earliest convenience. Could you please acknowledge receipt of this e-mail?
Best regards
Allen Lyons
Secretary - Strandfontein Belastingbetalersvereniging (SBV)
Virus-free. www.avg.com
2
SITE SCREENING ASSESSMENT FOR THE JUNO WIND FARM WITHIN AN IDENTIFIED AREA EAST OF STRANDFONTEIN IN THE WESTERN CAPE PROVINCE
SCREENING REPORTING AND POTENTIAL FATAL FLAW IDENTIFICATION
September 2016
Prepared for: AMDA Developments c/o Jade Feinberg Development Manager [email protected] 25 Adderley Street, Cape Town, 8000
Prepared by: Savannah Environmental (Pty) Ltd
First floor, BLOCK 2, 5 Woodlands Drive Office Park Cnr Woodlands Drive & Western Service Road, Woodmead, Gauteng P.O. Box 148, Sunninghill, 2157 Telephone : +27 (0)11 656 3237 Fax: +27 (0)86 684 0547 E-mail: [email protected] www.savannahsa.com JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
TABLE OF CONTENTS PAGE
1 BACKGROUND AND OVERVIEW ...... 1
2 METHODOLOGY FOR ASSESSING THE SUITABILITY OF THE IDENTIFIED AREA FOR THE DEVELOPMENT OF A WIND FARM...... 2
2.1 APPROACH TO UNDERTAKING THE SITE SCREENING ASSESSMENT 3 2.2 METHODOLOGY 5 2.2.1 Input Data Layers...... 5
3 DESCRIPTION OF THE ENVIRONMENT ...... 9
3.1 SOCIAL ENVIRONMENT 9 3.2 BIOPHYSICAL ENVIRONMENT 10
4 OUTCOMES OF THE SITE ASSESSMENT AND ASSESSMENT OF THE IDENTIFIED PROJECT SITE ...... 13
4.1 BASE MAP OF THE STUDY AREA 13 4.2 CRITERIA BASED ASSESSMENT DATA LAYERS 13 4.2.1 Environmental Criteria ...... 13 4.2.2 Planning, Landscape and Cultural Criteria ...... 17 4.2.3 Infrastructural Criteria ...... 18 4.3. LANDSCAPE BASED ASSESSMENT 19 4.3.1.INFRASTRUCTURAL CRITERIA 19 4.3.2.LANDSCAPE CRITERIA 20
5 CONSULTATION WITH AUTHORITIES REGARDING THE DEVELOPMENT OF THE JUNO WIND FARM WITHIN A NPAES ...... 21
6 SUMMARY OF SITE SCREENING CONSIDERATIONS...... 22
7 CONCLUSIONS OF THE SITE ASSESSMENT AND RISKS TO THE DEVELOPMENT OF A WIND FARM ...... 25
APPENDICES
Appendix A: Base Map Appendix B: Ecology Screening Report Appendix C: Map Layers 1-8 Appendix D: Authority Contact Details
September 2016 i JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
SITE SCREENING ASSESSMENT FOR THE JUNO WIND FARM WITHIN AN IDENTIFIED AREA EAST OF STRANDFONTEIN IN THE WESTERN CAPE
SCREENING REPORTING AND POTENTIAL FATAL FLAW IDENTIFICATION
1 BACKGROUND AND OVERVIEW
AMDA Developments (Pty) Ltd has identified a project site with the potential for the development of a wind farm located approximately 6km east of the town of Strandfontein, approximately 10km north east of the town of Doringbaai and approximately 25km south west of the town of Vredendal in the Western Cape Province (distances are based on the approximate centre point of the project site). The project site identified for the wind farm falls under the jurisdiction of the Matzikama Local Municipality and within the greater West Coast District Municipality.
The purpose of this Site Screening Assessment is to determine fatal flaws or areas within this identified project site considered to be unsuitable for a development of this nature, as well as to exclude areas that would be negatively impacted from an environmental perspective. The Site Screening Assessment approach followed at this time therefore serves as a site risk assessment tool from an environmental acceptability perspective – that is, a process to highlight or red-flag potential issues of concern prior to initiating a full EIA process for the proposed project site.
The project site is the Remaining Extent of the Farm De Boom 273 which is approximately 4675ha in extent (refer to Appendix A for a locality map and Table 1 for a description of the project site). The suitability for the development of a wind farm within the identified project site is considered in further detail in this screening report.
Table 1: Project Site property details Farm Name De Boom Parcel Number RE/273 21 Digit SG-Code C07800000000027300000 Size (ha) 4675 District Municipality West Coast District Municipality Local Municipality Matzikama Local Municipality Ward 2
The identified project site is located between 2.5 -10km from the west coast and is approximately 14km long (measured at the longest section) and 10km wide (measured at the widest section). Accessibility to the area is via a secondary road located to the south and the west of the project site which is connected to the regional road, R346 located to the west of the project site, leading towards Vredendal.
September 2016 1 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
Three grid connection options are being considered for the development including: » Option A & B: A direct connection to the Juno Substation located 15.5km to the north east of the project site (two alternative routes are considered for this option). » Option C: A loop-in loop-out connection to the existing Aurora – Juno 400kV power line located 4km to the east of the project site. » Option D: A loop-in loop-out connection to the existing Juno – Vredendal 66kV power line located 10.5km to the north east of the project site.
The Strategic Initiative to Introduce Commercial Land Based Wind Energy Development to the Western Cape - Towards a Regional Methodology for Wind Energy Site Selection (Western Cape Provincial Government, May 2006) and the Strategic Assessment mapping for the entire Western Cape Province (finalised for DEA&DP in 2012, but not yet released) was consulted for this site assessment. To maximise the confidence of this screening assessment, ecological specialist input has also been included to inform the findings as the bulk of the site falls within a focus area classified as part of the National Protected Area Expansion Strategy (NPAES) of South Africa.
Consultation with conservation authorities also formed part of this site screening assessment in order to better establish the actual significance of a development of this nature within an area classified as part of the National Protected Area Expansion Strategy (NPAES) of South Africa. This classification relates to achieving cost-effective protected area expansion for ecological sustainability and increased resilience to climate change. As the bulk of the project site (approximately 75%) is located within a NPAES, the compatibility of the development within this area had to be further investigated. Therefore, the following conservation authorities have been contacted to determine what the significance of the development will be on the NPAES strategy:
» DEA (Biodiversity) (Department of Environmental Affairs - Biodiversity Section); » CapeNature; » SANBI (South African National Biodiversity Institute); and » DEAD&DP (Western Cape Department of Environmental Affairs and Development Planning).
2 METHODOLOGY FOR ASSESSING THE SUITABILITY OF THE IDENTIFIED AREA FOR THE DEVELOPMENT OF A WIND FARM
The proposed location of a wind energy facility is obviously constrained by the availability of an acceptable wind resource (i.e. the fuel for the plant) and the availability of suitable land. The process required to be followed in order to assess the environmental suitability of the identified project site for a wind energy facility includes the following steps – a typical funnel-down process with an increased degree of refinement of information as the project proceeds (refer to Figure 1):
September 2016 2 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
STEP 1: Strategic level: Identification of good potential wind/solar energy areas suitable for a renewable energy facility
STEP 2: Regional level: Determination of acceptable areas suitable for a renewable energy facility
STEP 3: Local level: Assessment of the suitability for a renewable energy facility within the project site and preliminary sensitivity mapping
STEP 4: Site-specific level: EIA for the identified site to determine areas of sensitivity to be avoided by development footprint or mitigated
Figure 1: The process followed for determining the suitability of a project site for the development of a wind energy facility.
The strategic level input (Step 1) and the regional level input (Step 2) has been provided by AMDA Developments (a project site has been identified), and it is assumed that the developer is able to defend the selection of the area from a wind resource and technical perspective. This Site Screening Assessment is a local level assessment (Step 3), with a site-specific assessment, or Environmental Impact Assessment (Step 4) being the subsequent and final step.
2.1 Approach to Undertaking the Site Screening Assessment
Savannah Environmental, together with Simon Todd Consulting (ecological specialist), has undertaken a Site Screening Assessment on behalf of AMDA Developments to determine those areas within the project site considered to be suitable for development as well as areas which are to be avoided by the development, and thereby assessing the suitability of the identified project site for the development of a wind energy facility. The principles as per the Western Cape Department of Environmental Affairs and Development Planning (DEA&DP) Strategic Initiative to Introduce Commercial Land Based Wind Energy Development to the Western Cape - Towards a Regional Methodology for Wind Energy Site Selection (Western Cape Provincial Government, May 2006 as well as the update (finalised in 2012, but not yet published) have been considered and the methodology partly applied, where relevant, in the evaluation of the identified project site. This methodology includes the use of appropriate ‘negative’ and ‘positive’ buffer zones, as well as the incorporation of landscape issues and planning considerations relating to landscape character, value, sensitivity and capacity.
The methodology utilised is a regional or local level planning tool to guide project development planners (and ultimately decision-makers) with regards to the appropriate
September 2016 3 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report areas for development and/or the environmental suitability of identified project site, as well as the identification of potential fatal flaws. Local level issues have been further assessed in this Site Screening Assessment through the input from the ecological specialist to assist with the decision making process, specifically regarding the identification of the potentially most suitable development areas1 within the project site as well as the areas to be avoided by the development. The appropriateness and suitability of the three grid connection options and the associated power line routes are also being considered, however not in detail.
An ecological assessment has been undertaken by Simon Todd Consulting through this process to provide a more detailed and ground-truthed assessment of the project site from an ecological perspective. The specialist study was undertaken on the basis of a literature desktop study and a site visit and is included in this assessment (refer to Appendix B).
The objectives for the assessment of the project site were therefore to:
1. Test the appropriateness of the project site identified for the establishment of a wind energy facility (ensuring that technical and environmental constraints are minimised as far as possible). 2. Define and understand any constraints within the identified project site for development. 3. Identify any fatal flaws which may hinder the development of the wind energy facility within the proposed project site. 4. Reduce or eliminate the need to assess alternative project sites within the EIA process. 5. Provide support to an application for authorisation to the Department of Environmental Affairs for the preferred project site, using the findings as a motivation for the site for which the application is made.
This report provides the outcomes of the Site Screening Assessment, the results of which indicate the environmental suitability of the identified project site for a development such as a wind energy facility. The suitability of the identified broader study area and project site (indicated on each of the maps in Appendix C) has been assessed and potential environmental constraints or benefits highlighted.
From the conclusions of this assessment, the project proponent can then make an informed decision regarding the suitability of the proposed project site, or portions thereof, from an environmental perspective for the development, and whether a project- specific Environmental Impact Assessment (EIA) is to be undertaken for the intended
1 A development area is an area of suitable size located within the broader project site which is considered to be feasible and appropriate for the development of a wind energy facility. The broader project site under investigation for the Juno Wind Farm is located on the Remaining Extent of the farm De Boom 273 and is 4675ha in extent.
September 2016 4 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report development of a wind energy facility. The EIA will examine the site-specific environmental impacts in more detail and give indications with regards to environmental sensitivities which may influence the layout and design of the facility, as well as mitigation measures for minimising negative environmental impacts associated with the development.
2.2 Methodology
The methodology followed for this Site Screening Assessment draws on the principles as outlined in the DEA&DP methodology. It is important to note that the DEA&DP regional assessment guidelines focus is on environmental and planning issues only. The consideration of technical factors such as the availability of wind resources, proximity to the electricity grid, and access requirements are also important drivers behind the selection of an area of interest, and a project site. These aspects have been considered by the project proponent as part of their feasibility study for the identified broader study area (i.e. the greater Strandfontein and Doringbaai area).
The mapping exercise followed for this site screening assessment tests the identified property/project site against the majority of the criteria as listed in the wind regional environmental assessment for the Western Cape Province, and included others which were seen as particularly important for the study area under consideration. Site selection planning for the siting of wind energy facilities, including the use of criteria and thresholds to designate areas of suitability for development, is supported by the Department of Environmental Affairs.
It must be acknowledged that the thresholds developed to address environmental concerns vary significantly between localities due to varying geographical, biophysical and cultural characteristics (including salient natural features, land uses and demography), degree of landscape modification, approaches to forward planning etc. The thresholds used within this Site Screening Assessment have largely mirrored those provided within the DEA&DP guideline. This is primarily due to the project development site under consideration being located within the Western Cape.
Specific identified sensitivities provided within the ecological screening report have also been included within the mapping layers of this report. These sensitivities are site- specific and provide a realistic and ground-truthed indication for certain features that occur within the project site.
2.2.1 Input Data Layers
The Site Screening Assessment has as its basis the following broad input components:
» Regional Methodology: based on Geographic Information System map data layers (both criteria-based and subjective).
September 2016 5 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
» Elements of a Criteria Based Assessment: including environmental, planning and infrastructure criteria. » Elements of a Landscape Based Assessment: incorporating character analysis, sensitivity, value and capacity considerations. These are less quantitative and more subjective considerations compared to the Criteria Based map layers. » Specialist input: based on existing information and includes areas of sensitivity identified in regards to the development of a wind energy facility, provided by the specialist. This was undertaken with the help of a desktop assessment and a site visit by the ecological specialist.
Data layers were sourced from readily available spatial data for both the Criteria Based Assessment and the Landscape Character Assessment, as well as specialist input. This was done in accordance with the majority of the data layers and thresholds prescribed by the DEA&DP study. As not all data layers are applicable to this particular assessment and features present within the project site, not all layers were utilised. Limitations to development prescribed by the ecological specialist have also been included for consideration. Customised maps have been prepared in order to determine the potential environmental suitability, as well as highlight any red flags, fatal flaws or risk areas for development that occur within the project site.
The input categories for the Criteria Based Method used for this Site Screening Assessment include: » Sensitive environmental criteria and protected areas that would be negatively affected by the construction and operation of a wind energy facility (e.g. national parks, formally protected areas, areas earmarked for protection as part of a National strategy (eg National Protected Areas Expansion Strategy focus areas), Critical Biodiversity Areas (CBAs), nature reserves, rivers, wetlands, Important Bird Areas etc.). » Ecological aspects that would be negatively affected by the development of a wind energy facility as a result of specific ecological features or functions that take place within the project site. » Coastal planning considerations are taken into account as the location of the project site is situated on the West Coast and in close proximity to the coastline and the consideration of scenic routes of tourism importance which are present within the surrounding areas. Major scenic routes will be visually exposed to the presence and operation of a wind energy facility. » Airports and security sites located within the surrounding areas of the project site. » Vertical and disturbed landscape corridors (major transmission lines, railway lines, etc.) which have been previously disturbed, and are considered as areas where the development of a wind energy facility would be preferred.
The input category for the Landscape Based Method used for this site screening assessment include:
September 2016 6 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
» Land capability of the area in terms of other land uses, specifically agricultural potential (i.e. crop production).
In order to compile a map indicating areas suitable for the development of a wind energy facility, environmental sensitivities identified within the project site have been combined within an overall sensitivity map (refer to Layer 7 included within Appendix C). It should, however, be noted that the sensitivities identified stem mainly from environmental issues or risks identified and not planning considerations. From the overall sensitivity map a Potential Risks Map (Layer 8) was compiled which indicates primary risk areas that should be considered as features in the landscape or areas which present a risk to the development of a wind energy facility or the grid connection lines from an environmental perspective.
Data sources are outlined in Table 2. This was done in accordance with the majority of the data layers utilised in the Western Cape Provincial Government document: Strategic Initiative to Introduce Commercial Land Based Wind Energy Development to the Western Cape, as well as data received from the ecological specialist.
Table 2: Data utilised in the GIS mapping assessment Name Note Source Buffer Environmental considerations Layer 1: Protected and Sensitive areas Protected areas (Formal Statutory (Provincial and SANBI Statutory (1km negative and Informal) national) buffer) Private Private/NHS (500m Natural Heritage Sites negative buffer) Wetlands/water bodies Dams, pans, lakes, Surveyor general 500m (negative buffer) estuaries (all water bodies) Rivers Perennial and non- DWS Perennial (2km negative perennial buffer) Non-perennial (500m negative buffer) National Protected Areas NPAES boundaries (2010) SANBI No buffer Expansion Strategy – data currently available Important Bird Areas BirdLife No Buffer Critical Biodiversity Areas SANBI No Buffer Threatened eco-systems Vegmap 2006 SANBI No buffer (Vulnerable ecosystem) Layer 2: Ecological Aspects Sensitive ecological areas Areas classified as low to Ecological Screening No Buffer very high ecological Report sensitivity Planning Considerations Layer 3: Coastal Considerations and Scenic drives Coastline buffer EGIS South Africa 2km and 4km buffers are included (both negative) Roads Major roads (national, Surveyor General Major road (1km arterial, main) and official negative buffer) tourist routes (incl. Scenic/tourist road (1km
September 2016 7 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
secondary and other negative buffer) access roads) Layer 4: Airports and Security Sites Local airports Surveyor General Local (2km) CAA SAAF Layer 5: Vertical and Disturbed Landscapes Transmission and Major Eskom Tx (5km positive buffer) Distribution Power lines Dx (2km positive buffer) Railway lines Surveyor General 2km positive buffer Layer 6: Land Capability of Soils Land capability Land capability provides ARC No Buffer a broad description of the potential for crop production Layer 7: Overall Sensitivity Map Areas of sensitivity to be Illustration of all the Specialist input and Ecological sensitivities avoided by the wind sensitivities within the DEA&DP data layers identified including the energy facility. study area very high ecological feature of the non- perennial Sandlaagte River valley and the medium ecological intact vegetation.
NPAES, CBAs and Important Bird Areas (IBA) Layer 8: Potential Risks Map Areas or features within Illustration of the areas Specialist input and No-go areas (very high and surrounding the or features to be avoided DEA&DP data layers ecological sensitivity) project site which are or taken into include the non-perennial considered to be a risk to consideration which may Sandlaagte River valley the development of the pose a risk to the located in the southern Juno Wind Farm. development portion of the project site and the hill feature located outside of the project site to the west.
Other risks include the NPAES located within the site, a formal protected area located to the north east and an IBA located to the north west.
There is also a potential of land use conflict in terms of cultivated areas surrounding the project site in terms of grid connection.
September 2016 8 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
A base map (i.e. Layer 0) has also been compiled which has been used to illustrate the locality of the project site as well as the foundation upon which all other mapping was undertaken (refer to Appendix A).
The data included within layers 1, 3, 4, 5 and 6 are primarily based on a desk top level where the data is existing and current but has not been ground-truthed as such. Layer 2 is based on data compiled by the ecology specialist through the undertaking of a site visit to illustrate on a more accurate level the ecological sensitivity of the site. The ground-truthed data from the ecology specialist in combination with the existing desk top data utilised was considered in order to compile an overall sensitivity map (Layer 7).
The input components resulted in the identification of certain risk features or areas which are considered to be a risk for the development of the Juno Wind Farm. These risk features or areas have been included in a potential risks map (Layer 8) which illustrates environmental aspects to be considered for the development. Some of these features or areas are considered to be highly sensitive and should be avoided by the development.
Section 4 details the various map layers as applied to the project site. The suitability of the identified project site and the grid connection options has been identified and mapped in terms of specific criteria (derived from the DEA&DP study and the ecological screening report) and the potential environmental constraints or benefits present.
3 DESCRIPTION OF THE ENVIRONMENT
The project site considered for the development of the Juno Wind Farm is approximately 4675ha in extent and is characterised as a flat to slightly undulating coastal plain. The project site lies 2km east of the town of Strandfontein, and has an elevation which ranges between 75 – 170m above sea level.
3.1 Social Environment
The project site is located within an agricultural region that is predominately rural in nature, with livestock farming (sheep and cattle) and crop farming (wheat, grain, oats, grapes, tomatoes, sweet potatoes, potatoes and figs) as the primary land uses in the immediate local area.
The Cape West Coast Route is a secondary scenic road located west of the project site. This is an important route in terms of tourism activities within the broader West Coast area. The broader area includes the towns of Vredendal, Lambert’s Bay, Doringbaai and Strandfontein which are supported by tourist activity and holiday homes. There are, however, no major tourism facilities located within the broader area.
September 2016 9 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
Vredendal is situated in the Green Fringe of the Olifants River valley which borders on the southern tip of Namaqualand, the northern part of the Boland and forms part of the West Coast. Vredendal with its developed infrastructure is the commercial and agricultural hub of Matzikama Local Municipality.
3.2 Biophysical Environment
3.2.1 Vegetation and Ecosystems
According to the 2009 update of the national vegetation map (Mucina & Rutherford 2006), there are only two vegetation types within the study area, Namaqualand Strandveld which dominated the majority of the site and some Namaqualand Sand Fynbos in the south east corner of the project site.
Namaqualand Strandveld » This vegetation occurs in the Northern and Western Cape Provinces from the southern Richtersveld as far south as Donkins Bay. It consists of flat to undulating coastal peneplain. The vegetation consists of a low species richness shrubland dominated by a plethora or erect and creeping succulent shrubs as well as woody shrubs and in wet years annuals are also abundant. It is associated with deep red or yellowish-red Aeolian dunes and deep sand overlying marine sediments and granite gneisses. The area is a combination of Ah, Ae, Af, Ai and Ag land types. Mucina and Rutherford list eight endemic species for this vegetation type. About 10% of this vegetation type has been lost mainly to coastal mining for heavy metals and it is not currently listed. » Typical and dominant species observed at the site include Zygophyllum morgsana, Othonna cylindrica, O.coronopifolia, Didelta carnosa, Euphorbia burmanii, E.caput- medusae, Tetragonia fruticosa, Justicia cuneata, Lycium cinereum, Salvia africana- lutea, S.lanceolata, Tylecodon wallichii, T.paniculatus, Stoeberia utilis, Lebeckia sericea, Ruschia floribunda, Vanzijlia annulata, Chrysanthemoides incana, Manulea cinerea, Manochlamys albicans, Kedrostis psammophila, Cissampelos capensis, Conicosia elongata, Helichrysum tricostatum, H.hebelepis, Eriocephalus racemosa, Asparagus capensis, Nenax arenicola, Pteronia onobromoides, P.divaricata, Gnidia clavata, and Hermannia scordifolia. Scattered larger woody shrubs are a feature in some areas, and include Rhus glauca, Gymnosporia buxifolia, Diospyros austroafricana, and Euclea racemosa. Grasses may be prominent after rains, mainly Stipagrostis zeyheri, Ehrhrarta calycina, and E.ramosa. Geophytes include Lachenalia unifolia, Oxalis flava, Trachyandra divaricata, Albuca maxima, Trachyandra falcata, and Boophone haemanthoides.
Namaqualand Sand Fynbos » This vegetation is similar to but considered to be a more depauperate form of Leipoldtville Sand Fynbos, lacking most of the special species of the latter. It typically occurs on acid to neutral sands, often on windblown dunes and on the dune
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slacks. It is distributed in the Northern and Western Cape from the vicinity of the study area to Hondeklipbaai in the north, along the coastal plain. It occurs on Aeolian deep, loose, red sands overlying marine or other sediments. Land types are mainly Ah, Hb. And Ai. It is usually a low to medium shrubland, often dominated by restios, with Proteaceae often present, usually in low numbers. Bulbs and annuals may be common, with succulents common only on dune slacks. It is not a fire driven system and often forms mosaics with various Strandveld types, and boundaries can be very diffuse. » Dominant and typical species include Willdenowia incurvata, Thamnochortus bachmanii, Calopsis viminea, Ehrharta villosa, Stipagrostis zeyheri, Wahlenbergia asparagoides, Ruschia extensa, R.caroli, R.subpaniculata, Salvia lanceolata, Rhus dissecta, Anthospermum spathulatum, Nenax arenicola, Metalasia adunca, Macrostylis decipiens, Leucadendron brunioides, Justicia cuneata, Diospyros austro- africana, Wiborgia obcordata, Leucospermum rodolentum, Elytropappus rhinocerotis, Gymnosporia buxifolia, Stoebe nervigera, Trichogyne repens, Othonna coronopifolia, Chrysanthemoides incana, and Clutia daphnoides. There are relatively few species of conservation concern associated with this vegetation unit. In the project site, it occupies only the south eastern part of the project site, but at a broad level cannot be considered less sensitive than the areas of Namaqualand Strandveld.
Although the south eastern portion of the project site is classified as Leipoldtville Sand Fynbos, which is listed as Vulnerable, this listing is based on the 2006 version of the Vegmap and in more recent updates the project site has been mapped as Namaqualand Strandveld which is not listed. As the updated data is not readily available and final at this point this report assumes that the Vulnerable Leipoldtville Sand Fynbos is still relevant to the project site. Only when an updated version of the Threatened Ecosystems is formally released (2016/2017) can the presence of the Leipoldtville Sand Fynbos within the project site be considered as a vegetation type which is not listed.
3.2.2 Critical Biodiversity Areas (CBAs) and the National Protected Areas Expansion Strategy Focus Areas (NPAES)
The CBAs located in the surrounding areas of the project site are designed to maintain the connectivity of the landscape, both in the north-south direction as well as between the coastal strip and inland. The site is largely located outside of the CBAs and only the eastern tip of the site lies within a CBA.
The NPAES has been implemented in order to achieve cost-effective protected area expansion for ecological sustainability and increased resilience to climate change. The majority of the project site (75%) does fall within an NPAES Focus Area (National Protected Areas Expansion Strategy Focus Areas) which is a potential concern regarding the development potential of the site as DEA in particular are not in favour of development within NPAES Focus Areas. The NPAES v1 (2010) focus areas are in the process of being replaced by the significantly revised version incorporated into the
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NPAES 2016 and as such the Focus Areas within the vicinity of the project site are likely to change which will have implications for the development potential of the site.
3.2.3 Listed Plant Species
The abundance of listed plant species in the broader area is very high and as many as 33 species of very high conservation concern and 25 species of moderate conservation concern are known from the area. Several of these can be confirmed to be present at the project site including Muraltia obovata (VU), Boophone disticha (declining) and Lampranthus amoenus (EN). It is likely that additional listed species are present at the project site and impact on such species is considered to be a significant potential impact associated with the development. In order to limit the impact on such species as well as the total loss of habitat, it would be recommended that as much of the development footprint is restricted to previously transformed areas as possible.
3.2.4 Faunal Communities
Mammals The project site lies within the distribution range of approximately 48 terrestrial mammals. Common species observed in the area include Steenbok Raphicerus campestris, Common Duiker Sulvicapra grimmia, Rock Hyrax Procavia capensis, Yellow Mongoose Cynictis penicillata, Cape Gray Mongoose Galerella pulverulenta, Striped Polecat Ictonyx striatus, Bat-eared Fox Otocyon megalotis, Cape Gerbil Tatera afra, Striped Mouse Rhabdomys pumilio, Karoo Bush Rat Otomys unisulcatus, Porcupine Hystrix africaeaustralis, Cape Molerat Georychus capensis, Cape Dune Mole-rat Bathyergus suillus, and Cape Hare Lepus capensis. Listed species known from the area include the White-tailed Mouse Mystromys albicaudatus (EN), the Honey Badger Mellivora capensis (VU), and Van Zyls’ Golden Mole Cryptochloris zyli (CR).
Van Zyls’ Golden Mole Cryptochloris zyli, which is known from a handful of specimens collected at Compagniesdrift, which is located 40km south of the site. Although little is known about the van Zyl’s Golden Mole it is possible that it occurs within the Juno Wind Farm project site, however this is not likely as the occurrence of the species appears to be largely associated with loose sands that are not common within the site. Therefore, this species is not considered likely to be present and an impact on this species is considered unlikely.
Reptiles The project site lies in or near the distribution range of at least 42 reptile species. Based on distribution maps and habitat requirements, the composition of the reptile fauna is likely to comprise 2 tortoises, 15 snakes, 17 lizards and skinks, 7 geckos and 1 chameleon. The vast majority of the project site consists of sandy substrates and the reptile community within the study site is likely to reflect this habitat. There are however some rocky outcrops within the site that would be locally important reptile
September 2016 12 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report habitats which should be avoided. Common species within the site includes species such as the Spotted Sand Lizard Pedioplanis lineoocellata, Knox's Desert Lizard Meroles knoxii, Variegated Skink Mabuya variegate and the Angulate Tortoise Chersina angulata.
Listed species known from the wider area includes the Large-scaled Girdled Lizard Cordylus macropholis, Gronovi's Dwarf Burrowing Skink Scelotes gronovii, Kasner's Dwarf Burrowing Skink Scelotes kasneri, Cape Sand Snake Psammophis leightoni, Black Spitting Cobra Naja nigricollis woodi and Speckled Padloper Homopus signatus. Some, such as the burrowing skinks, are associated with loose sands, while others such as Speckled Padloper are associated with rocky outcrops and are highly likely to occur at the site.
Amphibians Although 14 amphibian species are known from the area, there are few areas of high significance for amphibians within the project site, with no listed species known from the area. The vicinity of the non-perennial Sandlaagte River would be the most important area for frogs. In general, the abundance of frogs at the project site would be low as there are no freshwater features at the site.
4 OUTCOMES OF THE SITE ASSESSMENT AND ASSESSMENT OF THE IDENTIFIED PROJECT SITE
The Site Screening Assessment has been undertaken on the identified project site (i.e. the Remaining Extent of the farm De Boom 273) covering an area of approximately 4675ha in extent on the West Coast in the Western Cape Province. All mapping has been included in Appendix A (base map) and Appendix C (layers).
4.1 Base Map of the study area
A base map (Layer 0) has been compiled showing the location of the project site in relation to the surrounding towns and other spatial characteristics. The details of the farm portion associated with the assessment have been included in Table 1.
4.2 Criteria Based Assessment Data Layers
4.2.1 Environmental Criteria
Protected and Sensitive Areas (Layer 1) The information contained in Layer 1 is focused on Environmental Criteria that would potentially be negatively affected by the development of a wind energy facility (i.e. negative constraints to wind energy development). These include formally protected areas, formal conservation initiatives and strategy areas, and environmentally sensitive features and areas within the broader study area and the project site.
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All these categories are mapped as negative criteria for the development of a wind energy facility and have separate buffer zones (as indicated on the Layer 1 map). The buffers are used to define exclusionary zones around these protected and sensitive areas. The protected and environmentally sensitive areas within the project site and within the broader study area (in some cases) include the following:
Negative Criteria » Formal protected areas and associated buffer (1km buffer) » Informal protected areas and associated buffer (500m buffer) » Waterbodies (500m buffer) » Perennial rivers (2km buffer) » Non-perennial rivers (500m buffer) » National Protected Areas Expansion Strategy Focus Areas (no buffer) » Important Bird Areas (no buffer) » Vulnerable ecosystems (vegetation) » Critical Biodiversity Areas (CBA Terrestrial)
The following constraints were identified to be associated and located within the identified project site:
» A non-perennial river, known as Sandlaagte, and its associated 500m negative buffer traverses the southern portion of the project site, in close proximity to the southern boundary of the site. » A small section of a terrestrial CBA is located within the most eastern corner of the project site. With such a minor overlap, the development would not be likely to significantly impact on CBAs and this is not considered a significant concern for the development as a result. The surrounding areas to the north, east and west of the project site also contain CBAs, but are located far enough (between 2 – 5km) not to be impacted on. No buffer has been recommended for CBAs. » The vegetation type (i.e. Leipoldtville Sand Fynbos2) located within the eastern part of the project site and to the west and south of the project site boundaries is considered as a vulnerable ecosystem which would require conservation (based on currently available data). The extent of the vegetation located within the project site is approximately 1558ha. No buffer has been recommended for the protection/avoidance of this vegetation type. » A NPAES (National Protected Areas Expansion Strategy) Focus Area (known as the Knersvlakte Hantam Focus Area) overlaps with the majority of the project site, including an area approximately 3476ha in extent (75% of the entire project site).
2 According to the Vegmap of 2006 the listed Vulnerable Leipoldtville Sand Fynbos is located within the eastern part of the project site. However, current updates to the data has indicated that the site is located within the Namaqualand Strandveld, which is not a listed vegetation type. Although the updates have been considered and applied by the ecologist, the data is not published as yet. Therefore, the existing data of 2006 is considered to be relevant until the updated Vegmap is formally released and published.
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No buffer is required for this focus area. The Focus Area extends to the north of the project site. The mapped NPAES area is based on data released by the Department of Environmental Affairs (DEA) in 2010. The extent of the NPAES potentially lost to the wind farm development is not considered extensive in terms of the larger mapped NPAES Focus Area (2010 data). In addition, the area of the project site located within the NPAES Focus Area does not occupy the same habitats as the rest of the Knersvlakte Hantam NPAES Focus Area located to the north of the project site, suggesting that development within this part of the Focus Area (i.e. the project site) is not likely to significantly impact future conservation options, and could be used as a motivation for infringement in this earmarked focus area. This opinion is further supported by current/on-going work by DEA, CapeNature, SANBI and others to refine the positions, boundaries and priority areas of the NPAES. Although redefined areas are not yet released, it is understood that some movement of the Focus Area is relevant to this area3.
The following constraints were identified to be associated with the grid connection options (power line routes):
» All four power line routes (Options A-D) will infringe on the NPAES located in the project site, the vulnerable ecosystem (Leipoldtville Sand Fynbos) and sections of the terrestrial CBA, as per the current mapped data. » Option A and B will be required to traverse the Olifants River to connect to the Juno Substation which may pose some limitation in terms of the route. » Option A and B will be located approximately 2km east of a formal protected area known as the Lutzville Conservation Area which is classified as a local nature reserve.
Ecological Sensitivities (Layer 2) Layer 2 illustrates the ecological sensitivities which occurs within the project site and vary from a medium-low to very high (no-go) sensitivity. Selected ecological aspects were considered to determine what the ecological sensitivities are within the project development site. The following aspects were considered:
» Vegetation and ecosystem status » Critical Biodiversity Areas (CBA) » National Protected Areas Expansion Strategy (NPAES) » Listed plant species » Faunal communities » Unique ecological features » Previous disturbance and transformation
3 According to the NPAES of 2010 approximately 75% of the project site is earmarked as Knersvlakte Hantam NPAES Focus Area. However, current updates to the NPAES data has indicated that the project site is no longer located within a NPAES Focus Area. Although the updates are under final consideration, the data is not published as yet, and is still in a draft phase which is subject to change. Therefore, the existing data of 2010 must be considered to be relevant until the updated NPAES Focus Areas data is formally released and published (assumed to be end 2016/early 2017).
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The following constraints were identified to be associated and located within the identified project site:
» The most conspicuous feature of the site is the non-perennial Sandlaagte River, which is a palaeochannel of a larger river possibly of what is now the Olifants River that used to flow through this area. This non-perennial river traverses the southern portion of the project site. In the most part, it does not have an active channel that flows, but is a sand-filled valley with occasional rocky outcrops. It is considered highly sensitive on account of the presence of numerous listed plant species as well as the rocky outcrops which are important faunal habitat in the context of the surrounding sand-dominated landscape. The non-perennial river and its vicinity are not considered suitable for development and should be avoided as much as possible. An ecological sensitivity rating of very high has been applied to this feature and an area 432.77ha is extent is considered as a no-go area in terms of the development. This area is restricted to the southern-most boundary of the site, and as such can be readily avoided. » To the south of the non-perennial Sandlaagte River valley, there are deeper sands with low dunes present that also represent a habitat that is not widespread in the area and is considered sensitive, and also potentially home to listed fauna species such as the Van Zyls’ Golden Mole Cryptochloris zyli. An ecological sensitivity rating of high has been applied to this section within the project site and an area 62ha in extent is considered as an area unsuited for the development of the wind farm. This area is restricted to the southern-most boundary of the site, and as such can be readily avoided. » The intact vegetation is largely in a moderate to good condition and the site is generally free of alien species, except for one area where scattered Acacia cyclops (Rooikrans) trees were present. The intact vegetation across most of the project site is considered to be of a medium ecological sensitivity. » The majority of the project site (located primarily to the north of the Sandlaagte River) includes areas which have historically been ploughed and used for cultivation. As these agricultural activities have not taken place over an extended period of time most of the affected areas have recovered sufficient vegetation which resulted in difficulty in distinguishing them from the undisturbed areas within the project site. The good recovery of these areas and the strip-agriculture used originally, which retains intact strips of vegetation between the ploughed areas, has resulted in these areas being classified as medium-low ecological sensitivity and not low sensitivity as might otherwise be the case. These medium-low ecological sensitive areas are considered as the optimal areas, from an ecological perspective, for the placement of turbines due to the historical disturbance. » The presence of the Knersvlakte Hantam NPAES Focus Area was also considered from an ecological perspective as majority (~75%) of the project site falls within a NPAES Focus Area (National Protected Areas Expansion Strategy Focus Areas, 2010) which is a potential concern regarding the development potential of the site, as DEA
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(National Department of Environmental Affairs) in particular are not in favour of development within NPAES Focus Areas. A revised NPAES (2016) is currently being developed and the Focus Areas within the vicinity of the study site are likely to change which will have implications for the development potential of the site. As per the draft version of the revised NPAES data (2016) the site is no longer located within a NPAES Focus Area, however this is subject to change and can only be verified once the final data has been published and released.
The grid connection options (Options A-D) were not considered by the ecologist during the site visit. However, two areas of concern located to the west of the project site were identified in terms of the proposed power line routes, which include dunes that are rated as a very high-high ecological sensitivity and a hill feature rated as a very high ecological sensitivity. The dunes in particular are traversed by Options A, B and D.
4.2.2 Planning, Landscape and Cultural Criteria
Coastal planning and scenic drives (Layer 3) Layer 3 deals with planning criteria specifically aimed at managing and protecting the South African coastline as an important landscape feature. The Regional Methodology guideline acknowledges that coastlines are typically areas of high wind resource, but also usually of high environmental and aesthetic value. This guideline document states that “in order not to arbitrarily exclude the entire coastline by means of a somewhat crude exclusionary buffer, it is proposed in the final recommended regional method that areas may be excluded from the coastal buffer due to lower scenic value”. A 2km and a 4km coastal buffer from the coastline is reflected within the layer. The 2km buffer is a not- negotiable buffer. The 4km buffer zone (as indicated in the DEA&DP guideline document) is the preferred distance that DEA&DP would consider an appropriate off-set distance from the coastline for a development of this nature. Infringement on this 4km buffer zone has been previously tolerated, and as such is considered to be negotiable. The buffer areas indicated demarcate ‘negative’ areas, and it is acknowledged that the intention of DEA&DP is to limit large scale development in close proximity to the coastline in order to minimise the potential for compromising the future potential for the coast. Some discussion would be required regarding the extent of this zone and its potential for impact for this development.
Layer 3 also refers to the delineation of scenic drives as negative criteria. This layer includes potential scenic (tourist) roads and all major (national, arterial and main) roads within the broader study area. The Cape West Coast tourism route is a secondary scenic route which is located to the south, west and north of the project site. This route is considered sensitive in terms of tourism activities within the broader study. There are, however, no major tourist attractions located in the project site or the broader study area, with only a few guesthouses located along the coast and the Olifants River. A negative buffer of 1km has been applied to both the Cape West Coast tourism route and
September 2016 17 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report to the regional roads, R362 and R363, located within the areas surrounding the project site.
The following constraints were identified to be associated with the project site and the broader study area:
» The study area is located on the west coast of the Western Cape, therefore the possibility exists that any development within this area may have an impact on the coastline. » A 2km negative buffer zone has been applied to the coastline. This buffer zone does not infringe on the project site. However when a 4km negative buffer is applied to the coastline the boundary of the project development site is infringed on. The area affected by the buffer zone is the most western portion of the project site and is located closest to the coastline. » There are scenic drive / tourist route constraints associated with the broader study area surrounding the project site (1km buffer for scenic and tourism routes are applicable). » The Cape West Coast Route is a secondary scenic road located to the south, west and north of the project site. » The R362 is a regional route located to the west of the project site and in close proximity to the coastline. Another regional route, R363, is located to the north and north east of the project site which leads to the town of Vredendal. A 1km buffer is applicable for regional routes. » The broader study area is supported by tourist activity and holiday homes. There are, however, no major tourism facilities located within the project site.
The following were identified to be associated with the grid connection options (power line routes):
» All four power line routes are proposed to be located east of the project site and will therefore not infringe on the coastline or the associated 2km and 4km negative buffers. » Options A and B will traverse the regional road (scenic route), R363, located to the north east of the project site. Option D will infringe on the 1km negative buffer of the R363.
4.2.3 Infrastructural Criteria
Airports and Security Sites (Layer 4) Layer 4 refers to infrastructure criteria that would negatively affect the placement of a wind energy facility such as navigation beacons, local airfields and major airports, aerodromes and national key points (e.g. military bases). Buffers implemented are as prescribed by the relevant Government Departments and the appropriate legislation (e.g. the South African Civil Aviation Authority (SACAA)). It should be noted that this is
September 2016 18 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report a technical criteria and development within these buffer areas may be negotiable depending on the exact site and wind energy facility layout under consideration.
Within this layer the effects of major and local airports have been considered. A 2km buffer around local airfields has been applied as no major airports are located within the broader study area. The Vredendal airport (or airstrip) is in close proximity to the town of Vredendal and therefore in the study area. An airstrip is also located within close proximity to the town of Doringbaai located to the south west of the project site, as well as north west of the project site which is located to the north of the Olifants River and close to the town of Lutzville. Due consideration must be given to SACAA’s guidance on safeguarding smaller airstrips from wind developments. At this time, it is understood that the SACAA consider shorter airstrips or airfields as Code 2 Instrument Non-Precision Approach runways. This effectively means that some form of physical safeguarding applies, and can be up to a 4.7km radius centred on the airstrip. This must be confirmed with the SACAA once turbine positions are better understood. Line of sight issues must also be considered once turbine positions are better understood.
The following were identified to be associated with the broader study area and the identified project site:
» No local landing strips are present within the project site of the wind energy facility. » A few local landing strips are located outside of the study area and in close proximity to the towns of Vredendal, Doringbaai and Lutzville.
The following were identified to be associated with the grid connection options (power line routes):
» All four power line routes are located well away from the landing strips of Vredendal, Doringbaai and Lutzville and would most likely not have any impact on the facilities.
4.3. Landscape Based Assessment
4.3.1. Infrastructural Criteria
Vertical and Disturbed Landscapes (Layer 5) Layer 5 includes positive criteria for the development of a wind energy facility were identified in the form of vertically disturbed landscape corridors within the broader study area and the project site. This is a positive (inclusionary) map layer that recognises ‘vertical and disturbed’ landscapes as a primary-level criterion for the location of wind energy developments from a landscape perspective. The intent of inclusionary buffers is the location of wind energy developments as close as possible to landscapes that are already compromised, disturbed and transformed by vertical structures such as power lines and railway lines. A 5km positive buffer for transmission power lines and a 2km positive buffer for distribution power lines (>132kV) were applied. Situating the
September 2016 19 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report development near power lines is also regarded as being positive from a technical perspective as it allows for integration into the electricity grid as well as shortening the length of the grid connection required for the evacuation of electricity. The proximity to Juno Substation, the exiting Aurora – Juno 400kV power line and the Juno – Vredendal 66kV power line is also positive and allows for appropriate grid connection. However, the grid connection is required to be analysed further by the project proponent during the project feasibility phase and in discussion with Eskom. Situating the development within 2km of landscapes disturbed by railway lines is also considered to be positive due to the disturbed nature of the landscape in these areas.
The following were identified to be associated with the broader study area and the identified project site:
» The existing Aurora – Juno 400kV power line is located to the east of the project site. The project site is located within the 5km positive buffer of the power line. This aspect presents positive criteria and favourable conditions in terms of logistical connectivity. » A railway line is located to the west of the western boundary of the project site. The site is located within the 2km positive buffer of the railway line.
The following were identified to be associated with the grid connection options (power line routes):
» All four power line routes traverse the buffers associated with vertical disturbed areas associated with the existing power line infrastructure, and includes the Aurora – Juno 400kV power line located to the west and the Juno – Vredendal 66kV power line.
4.3.2. Landscape Criteria
Land capability of soils (Layer 6) Layer 6 refers to the land capability of the broader study area and the project site in terms of soils and agricultural potential which include the classification of soils in terms of the limitations or capability of the soils for the use crop production.
The following were identified to be associated with the broader study area and the identified project site:
» The entire extent of the project site is classified as having very severe limitations in terms of the potential for crop production, and is not considered as a practical land use. » The broader area surrounding the project site is also classified as land with very severe limitations in terms of crop production. Only those areas which have direct access to water resources are actively used for meaningful agricultural practises. The greater Vredendal area is not suitable for crop production, other than those
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areas close to the Olifant River valley, and as such the development of the wind energy facility will not have an impact on the agricultural activities within the area.
The following were identified to be associated with the grid connection options (power line routes):
» All four power line routes are located in land classified as having very severe limitations in terms of crop production, which indicates that the construction of these routes to connect the wind farm to the proposed grid connection options will not have an impact on the agricultural activities and quality within the broader area surrounding the site. » A potential land use conflict may occur with the development of Options A and B where the power line routes will have to traverse cultivated areas surrounding the Olifants River and the Juno Substation.
5 CONSULTATION WITH AUTHORITIES REGARDING THE DEVELOPMENT OF THE JUNO WIND FARM WITHIN A NPAES
This screening study included a process of consultation with authorities regarding the development of the wind farm within a National Protected Areas Expansion Strategy Focus Area. The relevant conservation authorities include the following:
» DEA (Biodiversity) (Department of Environmental Affairs - Biodiversity Section); » CapeNature (as the conservation body for the Western Cape); » SANBI (South African National Biodiversity Institute); and » DEAD&DP (Western Cape Department of Environmental Affairs and Development Planning).
Appendix D includes the contact details (database) of the relevant parties within the abovementioned authorities who have been consulted to date.
The consultation has included the following:
1. Telephonic discussions were undertaken with the identified authorities to compile a database of the relevant authorities who should be consulted regarding the matter. The representatives of the identified associated authorities were contacted via telephone to provide them with a brief description of the screening process and request for more information in terms of the development within the NPAES. 2. A KMZ file of the project site was sent to the relevant representatives to provide a better understanding of the location of the site. 3. A request for input from the relevant authorities was sent via email in order to obtain a better understanding of the consequences and impacts in terms of the development of a wind energy facility within a NPAES Focus Area.
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To date, one formal (written) response has been received from SANBI. The representative of SANBI (Mr. Jeffery Manuel) confirmed that the NPAES v1 (2010) focus areas are in the process of being replaced by the significantly revised version incorporated into the NPAES 2016. However, it is not possible to provide a confirmed publishing and release date for the data. Mr. Manuel also confirmed that the proposed project site is not included within the 2016 draft NPAES priorities focus areas (which is currently not available in the public domain). The draft output has been made available for review by government agencies.
It was also pointed out that if a full EIA was conducted before the release of the updated data, the EIA would need to evaluate the project against the current 2010 NPAES Focus Areas data and it would be required to justify why the site was not sensitive, and would not be considered as an area to be classified as protected, as a counterpoint to its current status as a focus area.
6 SUMMARY OF SITE SCREENING CONSIDERATIONS
A summary of the broad-level evaluation and input from an ecological specialist screening study of the project site is provided below and illustrated within Layer 7 (overall sensitivity) of Appendix C. Through the site screening assessment specific sites/areas within the project site have been identified as risk areas which should be avoided and duly considered as a risk to the development potential of a wind energy facility. The identified risk areas are discussed below and illustrated within Layer 8 of Appendix C.
Overall Sensitivity of the broader study area and the project site (Layer 7) Areas considered as sensitive for the development of a wind energy facility are illustrated in Layer 7. This layer is a combined map illustrating the ecological sensitivities, which have been ground-truthed within the project site, formal sensitivities that were identified on a desk top level (including CBAs and the NPAES) that occur within the broader study area and the site, as well as the important bird area (IBA), known as the Olifants River Estuary, located within the surrounding areas of the site. This layer indicates the main sensitivities present on site and within the surrounding area that should be taken into consideration for the development of the Juno Wind Farm.
The following were identified to be associated with the broader study area and the identified project site:
» There are two areas located within the southern portion of the project site that are considered to be unsuitable for the development of a wind farm. These areas cover an area of approximately 496ha in extent, and include:
September 2016 22 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
∗ the non-perennial Sandlaagte River valley, which is considered to be a palaeochannel and is rated as a very high ecological sensitive area. ∗ The section just south of the non-perennial river which represents a habitat (deeper sands and low dunes) that is not considered to be widespread is considered sensitive and is rated as a high ecological sensitive area. This area could also potentially be home to some listed fauna species such as the Van Zyls’ Golden Mole Cryptochloris zyli. » Intact vegetation occurs within the project site which is in a moderate to good condition. The areas where intact vegetation is present are considered to be of a medium ecological sensitivity. These areas are located north of the non-perennial Sandlaagte River. » Historical cultivation and agricultural activities (strip cultivation) have taken place within the project site, however these areas have recovered sufficiently and these areas are considered to be of a medium-low ecological sensitivity. » The eastern point of the project site infringes on a small portion of a terrestrial CBA. However, this is not considered to be a significant impact due to the small extent of the CBA that would be affected. » A large important bird area (IBA) is located north west of the project site, straddling the Olifants River valley and estuary. This area is recognised for its high diversity of species and large number of birds. The proximity of this area to the project site needs to be considered due to the nature of the proposed development (i.e. wind farm). » A NPAES (National Protected Areas Expansion Strategy, 2010) Focus Area (known as the Knersvlakte Hantam Focus Area) is located within the majority of the project site, including an area approximately 3476ha in extent (75% of the entire project site), no buffer has been recommended. The Focus Area extends to the north. However, the extent of the NPAES potentially lost to the wind farm development is not considered extensive in terms of the larger mapped NPAES Focus Area (2010 data). The area of the project site located within the NPAES Focus Area does not occupy the same habitats as the rest of the Knersvlakte Hantam NPAES Focus Area located to the north of the project site, suggesting that development within this part of the Focus Area (i.e. the project site) is not likely to significantly impact future conservation options. This opinion is further supported by current/on-going work by SANBI and others to refine the positions, boundaries and priority areas of the NPAES. Although redefined areas are not yet available, it is understood that some movement of the Focus Area is relevant to this area, which may potentially result in the exclusion of the project site from the NPEAS Focus Areas.
Potential Risk Areas for a wind energy facility (Layer 8) Layer 8 illustrates the potential risk areas and risk features within the project site and the surrounding areas for the development of the Juno Wind Farm. This Layer identifies primary risks which are to be considered for the development of the wind farm, and also provide an indication of the possible limitations to the development from an environmental perspective.
September 2016 23 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
The following were identified to be associated with the broader study area and the identified project site:
» Within the project site two areas have been identified as unsuitable for the development of a wind energy facility. These areas include a palaeochannel valley (very high ecological sensitivity) and low dunes (high ecological sensitivity) located within and along the most southern boundary of the project site. These areas are considered to be no-go areas and infringement of the development within these areas must be avoided. » The NPEAS (Knersvlakte Hantam) Focus Areas occupies ~75% of the project site. This is considered as a potential risk to the development due to the development of a wind farm not being considered as a compatible land use or development within such an area. However, this finding is based on current data (2010) and does not consider the revised NPAES (2016) data which illustrates that the project site is no longer located within a NPAES Focus Area. The revised data is still under consideration and comment by the relevant government authorities and may be subject to change. » A coastline buffer of 4km (negative buffer) infringes on the western portion of the project site, however this buffer is considered to be negotiable in terms of development and would not pose a risk to the development of the wind farm. It is the 2km coastline buffer (negative buffer) considered as a limitation to the development of the wind farm, however this buffer does not infringe on the project site and is located away from the project site boundary. » An important bird area (IBA), known as the Olifants River Estuary, is located north of the project site, outside of the project boundaries. This IBA is considered as a sensitive habitat for avifauna species which could possible result in an impact on the avifauna resources within the area.
The following were identified to be associated with the grid connection options (power line routes):
» Two areas of concern have been identified as sensitive areas located to the east of the project site. These areas include dunes and a hill feature which are considered to be sensitive in terms of the development of the power line routes. Options A, B and D infringe on the dunes. » In terms of the development of Options A, B and D there is a potential for land use conflict, specifically located in close proximity to the Juno Substation. This potential land use conflict relates to cultivated areas which the power line routes would traverse in order to complete the grid connection. As these cultivated areas are considered unique in terms of the surrounding areas a conflict of land use may arise. » Options A and B would be required to traverse the Olifants River in order to complete the connection to the Juno Substation. This may pose a risk in terms of impacts on the riparian area and avifauna, as well as technical limitations.
September 2016 24 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
7 CONCLUSIONS OF THE SITE ASSESSMENT AND RISKS TO THE DEVELOPMENT OF A WIND FARM
From the results of the desk-top mapping assessment and specialist input (refer to Layer 8 included in Appendix C) it is evident that, based on physical features in the landscape, there are areas within the identified project site considered suitable for the development of the of the wind farm. The majority of the risks to the development are linked to areas viewed to hold conservation importance, and are based largely on areas or buffers demarcated at a desk-top level. These areas of risk include:
1. Non-perennial Saandlaagte River and associated Palaeochannel valley and dune area Risk to development: These areas area considered to be sensitive from an ecological perspective due to their ecological contributions and functioning. Therefore, these areas are not considered as suitable or appropriate for development which would infringe on the habitats and create detrimental impacts.
2. National Protected Areas Expansion Strategy Focus Area (known as the Knersvlakte Hantam Focus Area) Risk to development: Approximately 75% of the project site is located within the Knersvlakte Hantam Focus Area. This identification is based on the NPAES Focus Areas data of 2010 and could potentially pose a risk to the development in terms of the compatibility of the wind energy facility within the project site. Should a full EIA be conducted for the facility prior to the release of any updated NPAES data, the EIA would need to evaluate the project against the current 2010 NPAES Focus Areas data and it would be required to justify why the site was not sensitive, and would not be considered as an area to be classified as protected, as a counterpoint to its current status as a focus area. This risk is viewed as high, considering the low-tolerance position which National DEA’s Biodiversity section takes regarding infringement on these areas.
3. The Olifants River Estuary important bird area (IBA) located north of the site, straddling the Olifants River valley and estuary Risk to development: The presence of the Olifants River Estuary IBA poses a possible risk to the development of the wind farm as a result of the sensitive avifaunal habitat represented by the IBA and therefore the risk of high species richness and abundance for avifaunal species. Due to its proximity, the movement patterns of avifauna, together with the type of species moving through the area must be fully understood in order to be able to draw a reasonable conclusion regarding the potential risk for collisions at the facility. The risk is higher for those sites where high priority species or collision-prone species are common.
4. Coastal exclusion zone Risk to development: The risk of the coastal zone to the development of the wind farm is considered to be minor due to the fact that the project site’s western
September 2016 25 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report
boundary infringes on the 4km negative buffer, which is considered to be negotiable, and is excluded for the 2km negative buffer.
The following section provides a description of what can be expected in terms of development within the project site.
» No development within no-go areas may be undertaken. These are critical areas for biodiversity maintenance and functioning and should be avoided. » The development footprint in areas with a medium ecological sensitivity should be kept to a minimum. These are intact areas of biodiversity value and specific mitigation and avoidance would need to be implemented in these areas to maintain a low ecological impact. These areas are vulnerable to cumulative impacts and several phases of wind energy development affecting these areas may trigger the provincial authorities to look at the implementation of offsets to counter development in these areas. These areas would be best suited to low impact components of the facility, such as turbines and access roads only. No substation, laydown areas or other areas of large-scale impact should be considered for these areas. » The areas identified as having good development potential (medium-low ecological sensitivity) should be considered as the primary target areas for the development footprint. These are historically degraded or transformed areas where ecological impacts can be more easily maintained at a low level. There are a few limitations on the extent to develop on these areas and the potential for cumulative impacts is low.
It is considered that with appropriate risk management and strict implementation of mitigation measures the abovementioned risks can be managed in a manner that will be environmentally appropriate and suitable without detrimental impacts on the environment and sensitive areas and features. At this point it should be considered that the current NPEAS data set is not in favour of the development in terms of the compatibility of the development within the project site. However, with the release and finalisation of the revised NPAES data (2016) the status of the project site in terms of a focus area might change which is currently excluded, as per the draft data set. It is recommended and would be preferred to initiate the EIA process of the Juno Wind Farm after the release and finalisation of the updated NPAES data in order to avoid potential conflict in within the process and with the relevant authorities.
Consultation with the relevant authorises in terms of the NPAES Focus Areas has been undertaken during this screening exercise in order to obtain input and a better understanding of the development within the Knersvlakte Hantam Focus Areas. To date, feedback has been received from SANBI (Mr. Jeffrey Manuel) who has confirmed that the project site is no longer considered as part of the NPAES according to the revised 2016 draft data. On-going and further consultation with the associated authorises will be beneficial to the development of the Juno Wind Farm as the developer would be able to demonstrate attempts to undertake an informed approach in terms of the development within the NPAES. The need to have formal sit down meetings with the conservation
September 2016 26 JUNO WIND FARM NEAR STRANDFONTEIN, WESTERN CAPE PROVINCE Environmental Site Screening Report authorities would also arise should additional clarity be required when making a decision on whether to proceed with the EIA process and the timing of this. Considering the need for a one year pre-construction monitoring programme for both birds and bats, the commencement of the EIA would be following Month 6 of the monitoring programme. Considering this delay in the commencement of the EIA, the revised NPAES data may well be available at that time and present a reduced risk to the EIA. However, the developer must still make a call at this time regarding initiating the bird and bat monitoring programmes and the timing of these.
The preferred development area identified for the development of the wind farm within the project site should ideally be located within the areas classified as being target areas for the development (i.e. good development potential). In order to limit the impact on species as well as the total loss of habitat, it would be recommended that as much of the development is restricted to previously transformed areas as possible. Areas classified as having largely intact vegetation will also be suitable for the development, but will have constraining factors within the areas that will most likely require more and intense mitigation measures. Through the implementation of suitable mitigation measures the sites will be developable without affecting the environment in a detrimental manner.
September 2016 27 Appendix A: Base Map !
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Juno Wind Farm - Base Map_22.07.16 !O ! !
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! ! Appendix B: Ecology Screening Report PROPOSED JUNO WIND FARM:
FAUNA & FLORA ECOLOGICAL SCREENING STUDY
PRODUCED FOR SAVANNAH ENVIRONMENTAL
August 2016 1. INTRODUCTION
Savannah Environmental has appointed Simon Todd Consulting to conduct an ecological screening study of the proposed Juno Wind Farm on a site (i.e. the Remaining Extent of the Farm De Boom 273) located east of Strandfontein on the West Coast of the Western Cape Province. The study area is approximately 4670ha in extent. The project will also include a grid connection to either, the existing Eskom Juno substation located approximately 16km north east of the site; a connection to the Aurora – Juno 400kV existing power line located 4km to the east of the site; or a connection to the existing Juno – Vredendal 66kV power line located 10.5km to the north east of the site.
The primary purpose of the ecological screening study is to contribute to the overall environmental screening study for the site and identify the main constraints and opportunities for development at the site, and assess whether or not there are any potential fatal flaws evident to the development of a wind farm. The goal of the study would be to allow the developer to gauge the risks and opportunities presented by the site as well as minimise the ecological impacts and risks should it proceed to the EIA stage.
1.1 TERMS OF REFERENCE
The terms of reference for the botanical and faunal ecology screening study includes a description and characterisation of the following:
Vegetation: o The main vegetation types, extent and interaction with neighbouring types, soils or topography; o Threatened or vulnerable ecosystems (cf. National List of Threatened Ecosystems, SA vegetation map/National Spatial Biodiversity Assessment, fine- scale systematic conservation plans, etc.). Including NPAES Focus areas, which have implications for development potential as these areas have been identified as being of importance for future conservation area expansion and hence development in these areas is not recommended. o The likelihood of Red Data Book species, or species of conservation concern, occurring in the vicinity of the site (include degree of confidence). o Identify and describe the conservation value and conservation planning frameworks relevant to this site (Regional Planning) for represented vegetation units. o Consider the NPAES Focus Areas (National Protected Areas Expansion Strategy Focus Areas) located within the project site and the relevance thereof in terms of the nature of the vegetation and habitats present. o Describe the areas where indigenous vegetation has been transformed. o Provide a detailed vegetation sensitivity map (e.g. CBA) of the site, including coarse-scale mapping of disturbance and transformation on site.
2 Juno Wind Farm – Ecological Screening Study Fauna: o Describe and assesses the terrestrial fauna present in the area that will be affected by the proposed development. o Clarify species of special concern (SSC) and that are known to be: . endemic to the region; . that are considered to be of conservational concern; . that are in commercial trade (CITES listed species); or . are of cultural significance. o A faunal sensitivity analysis which describes any risks posed by the project; and outlines possible avoidance and mitigation measures.
1.2 ASSUMPTIONS &LIMITATIONS
Various assumptions about the development were made for the purposes of the screening study. No potential layout of the facility was available for the study as the developer is still investigating the development potential of the entire site. As such, no assumptions are made regarding which areas would be targeted for development.
Conditions at the time of the site visit were very good and ecological patterns at the site are therefore well characterised. Therefore, there is little uncertainty associated with the study in terms of the data collected on-site. The main determinant of sensitivity at the site is the presence of previously transformed areas which represent the best opportunity for development at the site and these have been accurately mapped based on satellite imagery of the site.
2. METHODOLOGY
2.1 INFORMATION SOURCES
Data sources from the literature consulted and used where necessary in the study includes the following:
Vegetation: • Vegetation types and their conservation status were extracted from the South African National Vegetation Map (Mucina and Rutherford 2006) as well as the National List of Threatened Ecosystems (2011), where relevant. • Information on plant and animal species recorded for the Quarter Degree Square (QDS) 3118CB, 3118CD and 3218AB was extracted from the SABIF/SIBIS database hosted by SANBI. • Freshwater and wetland information was extracted from the National Freshwater Ecosystem Priority Areas assessment, NFEPA (Nel et al. 2011). • Important catchments and protected areas expansion focus areas were extracted from the National Protected Areas Expansion Strategy 2008 (NPAES).
3 Juno Wind Farm – Ecological Screening Study • Listed Ecosystems were extracted from the National List of Threatened Ecosystems (2011) coverage. • Critical Biodiversity Areas were obtained from the SANBI BGIS database for the study area.
Fauna • Lists of mammals, reptiles and amphibians which are likely to occur at the site were derived based on distribution records from the literature and various spatial databases including SANBI’s SIBIS and BGIS databases as well as the ADU Virtual Museum which includes the Frog Atlas of Southern Africa as well as the South African Reptile Conservation Assessment (SARCA) database (http://vmus.adu.org.za). • Literature consulted includes Branch (1988) and Alexander and Marais (2007) for reptiles, Du Preez and Carruthers (2009) for amphibians, Friedmann and Daly (2004) and Skinner and Chimimba (2005) for mammals.
2.2 SITE VISIT
The site visit was undertaken for the current assessment on the 8th of August 2016. During the site visit, areas of specific concern that were identified from satellite imagery before the site visit were visited and sampled in the field. At various areas within the site where potentially sensitive features were present, vegetation surveys and investigations were conducted and full plant species lists for the area were compiled and photographs were taken where relevant. Sensitive features observed in the field were mapped and recorded with a GPS and all fauna observed at the site were noted. The conditions at the time of the site visit were optimal for the vegetation sampling and the majority of species present were in flower and could be identified.
2.3 SENSITIVITY MAPPING
An ecological sensitivity map of the site was produced by integrating the information collected on-site with the available ecological and biodiversity information available in the literature and various spatial databases. This includes delineating the different habitat units identified in the field and assigning sensitivity values to the units based on their ecological properties, conservation value and the potential presence of species of conservation concern. The sensitivity is based on ground-truthed information and does not take account of conservation planning status such as CBA or NPAES status. The ecological sensitivity of the different units identified in the mapping procedure was rated according to the following scale:
• Low – Areas of natural or transformed habitat with a low sensitivity where there is likely to be a negligible impact on ecological processes and terrestrial biodiversity. Most types of development can proceed within these areas with little ecological impact.
4 Juno Wind Farm – Ecological Screening Study • Medium- Areas of natural or previously transformed land where the impacts are likely to be largely local and the risk of secondary impact such as erosion low. These areas usually comprise the bulk of habitats within an area. Development within these areas can proceed with relatively little ecological impact provided that appropriate mitigation measures are taken. • High – Areas of natural or transformed land where a high impact is anticipated due to the high biodiversity value, sensitivity or important ecological role of the area. These areas may contain or be important habitat for faunal species or provide important ecological services such as water flow regulation or forage provision. Development within these areas is undesirable and should only proceed with caution as it may not be possible to mitigate all impacts appropriately. • Very High – Critical and unique habitats that serve as habitat for rare/endangered species or perform critical ecological roles. These areas are essentially no-go areas from a developmental perspective and should be avoided as much as possible.
In some situations, areas were also classified between the above categories, such as Medium-High, where it was deemed that an area did not fit well into a certain category but rather fell most appropriately between two sensitivity categories.
3. DESCRIPTION OF THE AFFECTED ENVIRONMENT
3.1 VEGETATION &ECOSYSTEM STATUS
According to the 2009 update of the national vegetation map (Mucina & Rutherford 2006), there are only two vegetation types within the study area, Namaqualand Strandveld which dominated the majority of the site and some Namaqualand Sand Fynbos in the southeast corner of the site (Figure 1). Although there are a number of other vegetation types in the broader area, some of which would be affected by the power line, the main impact and focus would be on the Namaqualand Strandveld vegetation type.
Namaqualand Strandveld occurs in the Northern and Western Cape Provinces from the southern Richtersveld as far south as Donkins Bay. Especially in the north of this unit it penetrates up to 40km inland and approaches the coast only near the river mouths of the Buffels, Swartlintjies, Spoeg, Bitter and Groen Rivers. In the south of the unit it is variably narrow and approaches the coast more closely. It consists of flat to undulating coastal peneplain. The vegetation consists of a low species richness shrubland dominated by a plethora or erect and creeping succulent shrubs as well as woody shrubs and in wet years annuals are also abundant. It is associated with deep red or yellowish- red Aeolian dunes and deep sand overlying marine sediments and granite gneisses. The area is a combination of Ah, Ae, Af, Ai and Ag land types. Mucina and Rutherford list eight endemic species for this vegetation type. About 10% of this vegetation type has been lost mainly to coastal mining for heavy metals and it is not currently listed.
5 Juno Wind Farm – Ecological Screening Study Typical and dominant species observed at the site include Zygophyllum morgsana, Othonna cylindrica, O.coronopifolia, Didelta carnosa, Euphorbia burmanii, E.caput- medusae, Tetragonia fruticosa, Justicia cuneata, Lycium cinereum, Salvia africana-lutea, S.lanceolata, Tylecodon wallichii, T.paniculatus, Stoeberia utilis, Lebeckia sericea, Ruschia floribunda, Vanzijlia annulata, Chrysanthemoides incana, Manulea cinerea, Manochlamys albicans, Kedrostis psammophila, Cissampelos capensis, Conicosia elongata, Helichrysum tricostatum, H.hebelepis, Eriocephalus racemosa, Asparagus capensis, Nenax arenicola, Pteronia onobromoides, P.divaricata, Gnidia clavata, and Hermannia scordifolia. Scattered larger woody shrubs are a feature in some areas, and include Rhus glauca, Gymnosporia buxifolia, Diospyros austroafricana, and Euclea racemosa. Grasses may be prominent after rains, mainly Stipagrostis zeyheri, Ehrhrarta calycina, and E.ramosa. Geophytes include Lachenalia unifolia, Oxalis flava, Trachyandra divaricata, Albuca maxima, Trachyandra falcata, and Boophone haemanthoides.
Namaqualand Sand Fynbos is similar to but considered to be a more depauperate form of Leipoldtville Sand Fynbos, lacking most of the special species of the latter. It typically occurs on acid to neutral sands, often on windblown dunes and on the dune slacks. It is distributed in the Northern and Western Cape from the vicinity of the study area to Hondeklipbaai in the north, along the coastal plain. It occurs on Aeolian deep, loose, red sands overlying marine or other sediments. Land types are mainly Ah, Hb. And Ai. It is usually a low to medium shrubland, often dominated by restios, with Proteaceae often present, usually in low numbers. Bulbs and annuals may be common, with succulents common only on dune slacks. It is not a fire driven system and often forms mosaics with various Strandveld types, and boundaries can be very diffuse.
Dominant and typical species include Willdenowia incurvata, Thamnochortus bachmanii, Calopsis viminea, Ehrharta villosa, Stipagrostis zeyheri, Wahlenbergia asparagoides, Ruschia extensa, R.caroli, R.subpaniculata, Salvia lanceolata, Rhus dissecta, Anthospermum spathulatum, Nenax arenicola, Metalasia adunca, Macrostylis decipiens, Leucadendron brunioides, Justicia cuneata, Diospyros austro-africana, Wiborgia obcordata, Leucospermum rodolentum, Elytropappus rhinocerotis, Gymnosporia buxifolia, Stoebe nervigera, Trichogyne repens, Othonna coronopifolia, Chrysanthemoides incana, and Clutia daphnoides. There are relatively few species of conservation concern associated with this vegetation unit. In the study site, it occupies only the south eastern part of the site, but at a broad level cannot be considered less sensitive than the areas of Namaqualand Strandveld.
6 Juno Wind Farm – Ecological Screening Study Figure 1. Vegetation map of the study area according to the 2009 update of the Mucina & Rutherford (2006) vegetation map, based on the work of Helme (2007) in the area.
The Ecosystem Status of the vegetation types of the area is illustrated below in Figure 2. Although the south eastern portion of the site is classified as Leipoldtville Sand Fynbos, which is listed as Vulnerable, this listing is based on the 2006 version of the Vegmap and in more recent updates the site has been mapped as Namaqualand Strandveld which is not listed. Thus when an updated version of the Threatened Ecosystems layer is released in 2016/2017, the site will not be within a listed vegetation type. Figure 2 also illustrates the previously transformed areas within the area mapped as Leipoldtville Sand Fynbos, but there are additional transformed areas as illustrated in Section 4.
7 Juno Wind Farm – Ecological Screening Study Figure 2. The National List of Threatened Ecosystems, remaining extent overlayed on the 2006 version of the Vegmap. The National List of Threatened Ecosystems will be updated to reflect changes to the Vegmap in 2016/17 when the next NBA is released.
3.2 CRITICAL BIODIVERSITY AREAS
The Critical Biodiversity Areas (CBA) map of the study area is illustrated below in Figure 3 (Pence 2008). Most of the CBAs in the study area are designed to maintain the connectivity of the landscape, both in the north-south direction as well as between the coastal strip and inland. The site is largely outside of the CBAs and only the eastern tip of the site lies within a CBA. As such, the development would not be likely to significantly impact on CBAs and this is not considered a significant concern for the development as a result.
The majority of the site does however fall within a NPAES Focus Area (National Protected Areas Expansion Strategy Focus Areas) which is a potential concern regarding the development potential of the site, as DEA in particular are not in favour of development
8 Juno Wind Farm – Ecological Screening Study within NPAES Focus Areas. A revised NPAES is currently being developed and the Focus Areas within the vicinity of the study site are likely to change which will have implications for the development potential of the site.
Figure 3. Critical Biodiversity Areas map for the study area, showing that the site would not significantly impact on any CBAs, but that the majority of the site is however within an NPAES Focus Area.
3.3 LISTED PLANT SPECIES
The abundance of listed plant species in the area is very high and as many as 33 species of very high conservation concern and 25 species of moderate conservation concern are known from the area. Several of these can be confirmed to be present at the site including Muraltia obovata (VU), Boophone disticha (declining) and Lampranthus amoenus (EN). It is likely that additional listed species are present at the site and impact on such species is considered to be a significant potential impact associated with
9 Juno Wind Farm – Ecological Screening Study the development. In order to limit the impact on such species as well as the total loss of habitat, it would be recommended that as much of the development footprint is restricted to previously transformed areas as possible.
3.4 FAUNAL COMMUNITIES
Mammals
The site lies within the distribution range of approximately 48 terrestrial mammals. Common species observed in the area include Steenbok Raphicerus campestris, Common Duiker Sulvicapra grimmia, Rock Hyrax Procavia capensis, Yellow Mongoose Cynictis penicillata, Cape Gray Mongoose Galerella pulverulenta, Striped Polecat Ictonyx striatus, Bat-eared Fox Otocyon megalotis, Cape Gerbil Tatera afra, Striped Mouse Rhabdomys pumilio, Karoo Bush Rat Otomys unisulcatus, Porcupine Hystrix africaeaustralis, Cape Molerat Georychus capensis, Cape Dune Mole-rat Bathyergus suillus, and Cape Hare Lepus capensis. Listed species known from the area include the White-tailed Mouse Mystromys albicaudatus (EN), the Honey Badger Mellivora capensis (VU), and Van Zyls’ Golden Mole Cryptochloris zyli (CR).
Van Zyls’ Golden Mole Cryptochloris zyli, which is known from a handful of specimens collected at Compagniesdrift, which is located 40km south of the site. Although little is known about this species and it is possible that it occurs at the Juno Wind Farm site, this is not considered to be likely as the occurrence of the species appears to be largely associated with loose sands that are not common within the Juno site. Therefore, this species is not considered likely to be present and an impact on this species is not considered likely and does not impact the sensitivity of the site.
In general, impacts on mammals are likely to result from habitat loss and disturbance within the intact parts of the site. Development on previously disturbed or transformed areas is not likely to generate significant impacts on fauna. Particular areas of concern would be the high-lying ground along the southern margin of the site and the palaeochannel of the Sandlaagte non-perennial river. Development impact to these areas should be minimised in order to maintain low faunal impacts at the site.
Reptiles
The site lies in or near the distribution range of at least 42 reptile species. Based on distribution maps and habitat requirements, the composition of the reptile fauna is likely to comprise 2 tortoises, 15 snakes, 17 lizards and skinks, 7 geckos and 1 chameleon. The vast majority of the site consists of sandy substrates and the reptile community within the study site is likely to reflect this habitat. There are however some rocky outcrops within the site that would be locally important reptile habitats which should be avoided. Common species within the site includes species such as the Spotted Sand Lizard Pedioplanis lineoocellata, Knox's Desert Lizard Meroles knoxii, Variegated Skink Mabuya variegate and the Angulate Tortoise Chersina angulata.
10 Juno Wind Farm – Ecological Screening Study Listed species known from the wider area includes the Large-scaled Girdled Lizard Cordylus macropholis, Gronovi's Dwarf Burrowing Skink Scelotes gronovii, Kasner's Dwarf Burrowing Skink Scelotes kasneri, Cape Sand Snake Psammophis leightoni, Black Spitting Cobra Naja nigricollis woodi and Speckled Padloper Homopus signatus. Some, such as the burrowing skinks, are associated with loose sands, while others such as Speckled Padloper are associated with rocky outcrops and are highly likely to occur at the site.
The development would result in the loss of habitat for resident reptiles as well as disrupt the connectivity of the landscape to some extent. As with mammals, the southern boundary of the site with rocky outcrops associated with the non-perennial Sandlaagte River are the most important areas for reptiles at the site.
Amphibians
Although 14 amphibian species are known from the area, there are few areas of high significance for amphibians within the study site, with no listed species known from the area. The vicinity of the Sandlaagte River would be the most important area for frogs. In general, the abundance of frogs at the site would be low as there are no freshwater features at the site. There does not appear to be any potential impacts on frogs within the site which would be of high significance after standard mitigation practice has been implemented.
4. SITE SENSITIVITY ASSESSMENT
The sensitivity map for the site is illustrated below in Figure 4. The most conspicuous feature of the site is the Sandlaagte River, which is a palaeochannel of a larger river, possibly of what is now the Olifants River, that used to flow through this area. In the most part, it does not have an active channel that flows, but is a sand-filled valley with occasional rocky outcrops. It is considered highly sensitive on account of the presence of numerous listed plant species as well as the rocky outcrops which are important faunal habitat in the context of the surrounding sand-dominated landscape. The non- perennial river and its vicinity are not considered suitable for development and should be avoided as much as possible. To the south of the river, there are deeper sands with low dunes present that also represent a habitat that is not widespread in the area and is considered sensitive and also potentially home to some listed fauna species such as the little known Van Zyls’ Golden Mole Cryptochloris zyli.
To the north of the Sandlaagte River, the site consists of flat to gently undulating sandy plains dominated by low shrubs. Some areas have historically been ploughed and used for cultivation, but this activity has not happened for some time and most areas have recovered sufficient vegetation to make them difficult to discern from undisturbed areas in the field. The good recovery of these areas and the strip-agriculture practises used, which retains intact strips of vegetation between the ploughed areas, has resulted in these areas being classified as Medium-Low sensitivity and not Low sensitivity as might
11 Juno Wind Farm – Ecological Screening Study otherwise be the case. These areas are clearly the best opportunity for development at the site and are considered to represent a low development risk, even where these areas are within the NPAES Focus Area.
The intact vegetation is largely in a moderate to good condition and the site is generally free of alien species, except for one area where there were some scattered Acacia cyclops (Rooikrans) trees. The intact vegetation across most of the site is considered medium sensitivity. The development potential of these areas is less clear on account of the NPAES status of most of the site. The affected NPAES Focus Area is however not very large and does not occupy the same habitats as the rest of the Knersvlakte Hantam Focus Area, suggesting that development within this part of the Focus Area is not likely to significantly impact future conservation options, especially given the relatively low footprint of the wind farm development.
Figure 4. Ecological sensitivity map of the site, showing the Sandlaagte River valley in the south and the intact and previously disturbed plains which occupy the northern extent of the site.
12 Juno Wind Farm – Ecological Screening Study Figure 5. The Sandlaagte River valley is a sensitive area within the site that contains numerous rocky outcrops and features that are not found elsewhere within the site. This is considered a sensitive area that is not suitable for development (No-Go area).
Figure 6. Looking across the Sandlaagte non-perennial River valley, showing the broad valley bottom and slopes with exposed rock and dorbank layers.
13 Juno Wind Farm – Ecological Screening Study Figure 6. Examples of vegetation that has historically been disturbed for cultivation but has subsequently recovered a large proportion of the vegetation cover. These areas are however still discernible due to their lower diversity and presence of disturbance indicators such as Galenia africana. These are not considered biodiversity priority areas and are the most suitable areas for development at the site.
14 Juno Wind Farm – Ecological Screening Study Figure 7. Examples of typical Namaqualand Strandveld in the study site, dominated by species such as Didelta, Zygophyllum, Eriocephalus and Othonna. These areas are considered moderately sensitive and limited impact to these areas would be likely considered acceptable.
15 Juno Wind Farm – Ecological Screening Study 5. CONCLUSION AND RECOMMENDATIONS
Apart from the Sandlaagte River valley which is considered unsuitable for development, the Juno Wind Farm site is considered potentially suitable for well-planned development. There are relatively large tracts of previously disturbed land present that are not likely to represent significant risk for development. These areas have been disturbed in the past and are not biodiversity priority areas and the impact of development in these areas would be considered relatively low. However, in order to accommodate an economically viable wind energy facility, some impact to the intact Namaqua Strandveld vegetation is likely to be required. The overall risk associated with the development, in terms of receiving authorisation from DEA, is likely to hinge largely on the extent of impact to the undisturbed areas.
The main concern for development is the NPAES status of the majority of the site. DEA is generally not in favour of development within these focus areas. From an ecological specialist point of view, this area is however not considered to be of the same significance as for the affected Knersvlakte Hantam Focus area, and it is considered highly unlikely that development of the site for a wind farm would impact on future conservation options in the area. Namaqualand Strandveld has not been significantly impacted by development and there are still extensive intact tracts of this vegetation type remaining, particularly towards the north and into Namaqualand. Therefore, development of the site would not be considered to pose a significant risk to the NPAES Focus Area and development of the site could be well motivated. Furthermore, a new NPAES map is due for release in late- 2016 and the status of the site within this new map would need to be verified as this would potentially have significant implications for the development potential of the site.
The following recommendations are made with regards to the development of a wind farm at the site:
• The Sandlaagte River valley should be avoided as much as possible. This is in any case largely a low-lying part of the site and is likely to have poor wind resources. Impact to this area would generate high assessed impacts and would potentially constitute a fatal flaw for the development if considered. Due to the location of this feature within the site, the area can be readily avoided. • The previously transformed parts of the site should be targeted for development and as much of the development footprint as possible should be located within these areas. Development in these areas would result in lower impacts on biodiversity and is not likely to be opposed by provincial or national authorities, even where these fall within NPAES Focus Areas (as development in these areas can be justified). • Outside of the Sandlaagte River valley, the intact Namaqua Strandveld vegetation of the site is considered typical of the area and there are no specific features of significance that should prevent development of the site.
16 Juno Wind Farm – Ecological Screening Study • The site is however within the Knersvlakte Hantam Focus Area and this represents potentially the biggest uncertainty and obstacle to development of the site. However, the site is not considered significant in context of the Knersvlakte Hantam Focus Area and development of the site would not be considered to compromise future conservation options in the area. • Development within the intact Namaqua Strandveld vegetation would generate moderate impacts and it is recommended that the footprint within the intact areas be restricted to approximately 30% of the total wind farm footprint if possible, with the remaining footprint within the previously transformed areas.
17 Juno Wind Farm – Ecological Screening Study REFERENCES
Alexander, G. & Marais, J. 2007. A Guide to the Reptiles of Southern Africa. Struik Nature, Cape Town.
Bates, M.F., Branch, W.R., Bauer, A.M., Burger, M., Marais, J., Alexander, G.J. & de Villiers, M. S. 2014. Atlas and Red List of the Reptiles of South Africa, Lesotho and Swaziland. Strelitzia 32. SANBI, Pretoria.
Branch W.R. 1998. Field guide to snakes and other reptiles of southern Africa. Struik, Cape Town.
Du Preez, L. & Carruthers, V. 2009. A Complete Guide to the Frogs of Southern Africa. Struik Nature., Cape Town.
Friedmann, Y. & Daly, B. 2004. Red data book of the mammals of South Africa, a conservation assessment. Johannesburg, Endangered Wildlife Trust.
Helme, N. A. 2007. Botanical report: Fine scale vegetation mapping in the Sandveld. Report for CapeNature, as part of the C.A.P.E. programme.
IUCN 2014. IUCN Red List of Threatened Species. Version 2014..
Marais, J. 2004. Complete Guide to the Snakes of Southern Africa. Struik Nature, Cape Town.
Minter LR, Burger M, Harrison JA, Braack HH, Bishop PJ & Kloepfer D (eds). 2004. Atlas and Red Data book of the frogs of South Africa, Lesotho and Swaziland. SI/MAB Series no. 9. Smithsonian Institution, Washington, D.C.
Nel, J.L., Murray, K.M., Maherry, A.M., Petersen, C.P., Roux, D.J., Driver, A., Hill, L., Van Deventer, H., Funke, N., Swartz, E.R., Smith-Adao, L.B., Mbona, N., Downsborough, L. and Nienaber, S. (2011). Technical Report for the National Freshwater Ecosystem Priority Areas project. WRC Report No. K5/1801.
Mucina L. & Rutherford M.C. (eds) 2006. The Vegetation of South Africa, Lesotho and Swaziland. Strelitzia 19. South African National Biodiversity Institute, Pretoria.
Pence, G. Q.K. 2008. C.A.P.E. Fine-Scale Systematic Conservation Planning Assessment: Technical Report. Produced for CapeNature as part of the GEF-funded C.A.P.E. Fine- Scale Biodiversity Planning Project. Cape Town, South Africa.
Skinner, J.D. & Chimimba, C.T. 2005. The mammals of the Southern African Subregion. Cambridge University Press, Cambridge.
Threatened Ecosystems in South Africa: Descriptions and Maps (available on BGIS website: http://bgis.sanbi.org.
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Olifants ! Juno Wind Farm, Western Cape ! !
R362 ! ! !
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! R27
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!
! Power Line Route Alternatives: !
!
! !
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!
Option B - Juno MTS !
!
Option C - Juno Aurora - 400 kV !
! !
Option D - Juno Vredendal1 - 66 kV ! !
!
Ecological Sensitivities: !
! DE BOOM 273 Palaeochannel Valley (Very High Ecology Sensitivity) !
RE/273 ! ! Hill (Very High Ecological Sensitivity) !
Strandfontein ! !O ! Dunes (Very High-High Ecological Sensitivity) !
!
SANDLAAGTE SWITCHING STATION / VREDENDAL 1 66kV OHL ! Sandlaagte Aurora/Juno 1 400kV
Low Dunes (High Ecological Sensitivity) ! !
!
Intact Vegetation (Medium Ecological Sensitivity) !
! !
Historically Cultivated Areas (Medium-Low Ecological Sensitivity) ! !
Scale: 1:117 000 !
Projection: LO19 WGS 1984 !
Juno wind Farm - Layer 2 (Ecological Sensitivities)_25.08.16 ! !
! !
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!
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! !
!
!
! ! !
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! !
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! ! !
! ! ±
! ! !
! !
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!
! ! ! ! ! ! ! ! !
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! !
! Railway Line !
! Vredendal !
! !O
Olifants Regional road ! !
!
! Secondary road !
!
!
! ! R363 Perennial rivers !
! !
!
Non-perennial rivers !
! !
!
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!
R362 !
!
Project Site !
!
DE BOOM 273 !
Power Line Route Alternatives: RE/273 ! ! Option A - Juno MTS ! Strandfontein !
!O ! !
Option B - Juno MTS !
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!
Option C - Juno Aurora - 400 kV !
! !
Option D - Juno Vredendal1 - 66 kV ! !
Aurora/Juno 1 400kV
Planning Criteria: ! !
!
Regional road buffer (1km neg. buffer) !
! !
Scenic and Tourism routes buffer (1km neg. buffer) ! !
!
! !
Coastline buffer (2km neg. buffer) ! !
!
!
Coastline buffer (4km neg. buffer) !
!
! ! ! Coastline Doringbaai ! !O ! !
! ! !
!
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!
! ! Northern Cape ! ! !
!
! !
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!
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! !
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Juno wind Farm - Layer 4 (Airports & security sites)_22.07.15 GIS User Community Km !
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! !
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!
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Juno wind Farm - Layer 5 (Vertical & disturbed landscapes)_22.07.15 GIS User Community Km !
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R362 !
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Layer 6: Land Capability of Soils and Cultivation ! ! !
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! ! ! ! Town ! !O ! ! ! Olifants
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)" ! ! !
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! JUNO / VREDENDAL 1 66kV OHL !
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Power Line Route Alternatives: !
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Option A - Juno MTS !
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Option B - Juno MTS ! !
Option C - Juno Aurora - 400 kV ! ! Option D - Juno Vredendal1 - 66 kV DE BOOM 273 !
RE/273 !
! ! Environmental Sensitivities: !
Strandfontein !
Important Bird Area !O ! ! Critical Biodiversity Area (Terrestrial) !
Sandlaagte !
NPAES Focus Areas !
SANDLAAGTE SWITCHING STATION / VREDENDAL 1 66kV OHL 1 66kV VREDENDAL / STATION SWITCHING SANDLAAGTE !
!
Palaeochannel Valley (Very High Ecology Sensitivity) Aurora/Juno 1 400kV !
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Dunes (Very High-High Ecological Sensitivity) !
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Projection: LO19 WGS 1984 0Source: Esri, DigitalGlobe, GeoEye,5 i-cubed, Earthstar Geographics, CNES/Airbus10 DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo,20 and the !
Juno Wind Farm - Layer 7 (Overall Sensitivity)_25.08.16 GIS User Community ! Km !
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Layer 8: Potential Risks " !
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! )" ! ! ! ! ! ! !!! Existing power line !
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Railway Line ! ! JUNO / VREDENDAL 1 66kV OHL
! !
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Olifants !O Perennial rivers ! !
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R363 !
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Project Site !
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Power Line Route Alternatives: !
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Option A - Juno MTS ! !
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Option B - Juno MTS R362 !
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Option C - Juno Aurora - 400 kV !
! DE BOOM 273 Option D - Juno Vredendal1 - 66 kV !
RE/273 ! ! Potential Environmental Risks in terms of Development: !
Strandfontein !
!
Important Bird Area !O !
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Formal Protected Areas ! !
Palaeochannel Valley (Very High Ecology Sensitivity) ! !
Aurora/Juno 1 400kV
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Scale: 1:117 000 ! Projection: LO19 WGS 1984 0Source: Esri, DigitalGlobe, GeoEye,4.75 i-cubed, Earthstar Geographics,9.5 CNES/Airbus DS, USDA, USGS, AEX,! Getmapping, Aerogrid,19 IGN, IGP, swisstopo, and the Juno Wind Farm - Layer 8 (Potential Risks)_30.08.16 GIS User Community !
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! ! Appendix D: Authority Contact Details Authority Contact Person Designation Email Address Telephone number Cellphone number DEA (Biodiversity) (Department of Environmental Affairs - Biodiversity [email protected] Section) Willeen Olivier ov.za 012-399-9581 [email protected] CapeNature Leandi Wessels Conservation Services Officer .za 072-592-3517 Director: Biodiversity SANBI Jeffrey Manuel Information and Planning [email protected] 021-799-8858 084-722-5922 DEAD&DP (Western Cape Department of Environmental Affairs Director: Biodiversity and marlene.laros@westernc and Development Planning). Marlene Laros Coastal Management ape.gov.za 021-483-5126 Aneesah Alwie
From: Juno Sent: Tuesday, October 9, 2018 10:07 AM To: 'Allen Lyons'; Juno Cc: Ashlin Bodasing; [email protected]; 'Kobus Rossouw' Subject: RE: AMDA weather mast
Dear Allen
The coordinates for the De Boom Met Mast are -31°43’50.2” 18° 18’ 47.6”.
Thanks
From: Allen Lyons [mailto:[email protected]] Sent: Tuesday, October 9, 2018 9:09 To: Juno
Dear Ryan
Could you please send me the co-ordinates of the weather mast AMDA erected on De Boom?
Best regards
Allen Lyons
Secretary - Strandfontein Belastingbetalersvereniging (SBV)
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1 Aneesah Alwie
From: Juno Sent: Monday, October 15, 2018 4:20 PM To: 'Richard Owies' Subject: RE: Enquiry about project
Thanks Richard.
There will be approximately 200 jobs created during the construction phase of the proposed Juno WEF. Approximately 55% (136) of the employment opportunities will be available to low skilled workers (construction labourers, security staff etc.), 30% (76) to semi-skilled workers (drivers, equipment operators etc.) and 15% (38) for skilled personnel (engineers, land surveyors, project managers etc.).
Thank you
-----Original Message----- From: Richard Owies [mailto:[email protected]] Sent: Friday, October 12, 2018 11:14 To: Juno
Good day
Thanks for your quick response - very much appreciated. I am actually interested in vacancies that will arise from this project.
Thanks and regards
Richard Owies
On 10/12/18, Juno
1 > Good day Sir/Madam > > Herewith my enquiry regarding a proposed project by you in the > Strandfontein region in the West Coast - Western Cape. > > I would appreciate if you could forward me with some more information > regarding this project. I am residing in this area therefore my interest. > > Should you need additional information from me, feel free to enquire > , as I will be much obliged to do so. > > Thanking you in anticipation. > > Regards > > Richard Owies (+27 66 189 1404) >
2 Draft Environmental Impact Assessment Report Correspondence
Aneesah Alwie
From: Juno Sent: Wednesday, October 31, 2018 3:09 PM To: Allen Lyons; Juno Cc: Lehan Fouche; Kobus Rossouw; Ashlin Bodasing Subject: RE: Consultants contact details
Follow Up Flag: Follow up Flag Status: Flagged
Dear Allen
Please see below contact details for specialists as requested: Visual - Zone Land Solutions - Johan Claassen [email protected] 083 299 6650 Noise - Arcus - Michael Reid [email protected] (+44) 7878530174 Bats - BioInsight - Craig Campbell [email protected] 082 353 6515
Thanks
From: Allen Lyons [mailto:[email protected]] Sent: Wednesday, October 31, 2018 8:28 To: Juno
Dear Ryan
Could you please send me the name and contact details of the person/s responsible for the:
Visual impact assessment Noise impact assessment Bat impact assessment
Best regards
Allen Lyons
Secretary - Strandfontein Belastingbetalersvereniging (SBV)
1 Aneesah Alwie
From: Juno Sent: Tuesday, November 20, 2018 3:08 PM To: 'Lizelle Stroh' Subject: RE: Notification of Availability of Draft EIA and BA Reports for the Proposed Juno WEF and Grid Connection
Dear Lizelle
Thank you for the SACAA requirements.
These have been forwarded to the developer to allow them to confirm that they have all up to date and applicable SACAA requirements.
Thank you
From: Lizelle Stroh [mailto:[email protected]] Sent: Wednesday, October 31, 2018 10:28 To: Juno
Good day Juno, please find info on the SACAA procedure to comply to the Said regulations and requirements to follow.
Kind regards
Lizell Stroh Obstacle Inspector PANS-OPS Section Air Navigation Services Department Tel: 011 545 1232 | 083 461 6660 / Email: [email protected] | www.caa.co.za
Follow us on
From: Juno [mailto:[email protected]] Sent: 29 October 2018 09:43 PM Subject: Notification of Availability of Draft EIA and BA Reports for the Proposed Juno WEF and Grid Connection 1
Dear Interested and Affected Party
The Draft EIA Report for the Proposed 140 MW Juno Wind Energy Facility (WEF) and the Draft BA Report for the Associated Grid Connection is available for you to view.
Please find attached a letter with further information on the availability of the Juno WEF EIA and Grid Connection BA Reports.
Thank you
Arcus Consultancy Services South Africa
Tel: +27 (0) 21 412 1529 Mobile: +27 (0) 72 678 1523 Email: [email protected]
Arcus Office 220 Cube Workspace Cnr Long Street and Hans Strijdom Road Cape Town 8001 www.arcusconsulting.co.uk
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2
The S. A. Civil Aviation Authority has taken note of your intention to develop a wind farm and requires the following information in order to assess the possible impact on aviation.
An formal application via Form CA139‐26 – Wind Farm application, available electronically from the SACAA website(www.caa.co.za), follow link “Information for the industry” – drop down list – Obstacles‐ Forms. Completion of the attached Excel spreadsheet – Property boundaries co –ordinates. Completion of the attached Pylon geographic co‐ordinates. Should these co‐ordinates not be available at this stage, an indication of the planned route of the power evacuation lines to the point of connection with the national grid. A live .kmz file(Google Earth or similar) indicating proposed planned turbine layout.
Kindly provide a .kml (Google Earth) file reflecting the footprint of the proposed development site including the proposed overhead electric power line route that will evacuate the generated power to the national grid.
Also indicate the highest structure of the project & the Overhead electric power transmission line. In order to assist with the DEA process, the SACAA will, subject to the proposed wind farm not presenting a hazard, issue a “in principle” conditional approval on the receipt of the planned turbine layout which will be subjected to an in depth assessment accordance with the Civil Aviation Technical Standards. Should the turbine layout change from that which has been provided initially, a new assessment would be required to be conducted. Kindly note, that the conditional approval will be valid for a period of 5 years from date of issue. On completion of the project and receipt of “as built” detail and a statement of compliance to specified conditions, the SACAA will provide a final approval.
As the proposed site may be adjacent to areas of military interest, the SAAF will be included in the request for review, once the proposed site and wind farm information is made available for assessment. The SACAA refrains from commenting on a proposal, but will either conditionally support or disapprove the project; from an aviation perspective should the project create a hazard or obstacle to aviation in the area of the project.
Following the receipt of the information, an invoice to cover the assessment will be generated and becomes payable before the assessment results will be released.
Information Document
Wind Farms and Obstacle Assessments
1. Introduction
1.1 The effective use of an aerodrome may be considerably affected by natural features and by manmade constructions both inside and outside the boundaries of the aerodrome. 1.2 This may result in restrictions to the optimal use of the aerodrome 1.3 It is therefore necessary to consider the local airspace as an integral part of the aerodrome environment 1.4 The control of obstacles, and here I include the prevention or removal of obstacles, is clearly related to the safe and efficient use of the aerodrome. 1.5 What is an Obstacle?
International Civil Aviation Organization (ICAO) Annex 14 definition:-
All fixed or mobile objects or parts thereof, whether temporary or permanent, that:
a) are located on an area intended for the surface movement of aircraft; or b) Extend above a defined surface intended to protect aircraft in flight; or c) Stand outside those defined surfaces and that have been assessed as being a hazard to air navigation.
1.6 It is a legal requirement to obtain prior approval for an obstacle in terms of the Aviation Act with parts 139.01.30, the dominant regulation. The standards for Markings of obstacles can be found in the technical standards to this regulation and is essentially that of annex 14 and some differences in character exist to accommodate local practices and conditions.
1.6 Part 171 and its associated CATS-ESO technical standards are also applicable in as far the protection of Communication; Navigation and Surveillance systems are concerned.
1.7 Part 91.01.10 also has reference.
Note:- The above reference refers to the regulations the new Civil Aviation Act (Act 13 of 2009) as promulgated
2. Discussion
2.1 The significance of any proposed or existing obstacle on or in the vicinity of an aerodrome is accessed by two separate sets of criteria defining airspace. 2.2 The first and the one that will be concentrated on, is the obstacle limitation surfaces as defined in Annex 14 chapter 4, the second being the PANS- OPS surfaces defined in Doc8168 Vol II (Construction of Visual and Instrument Flight Procedures)
2.3 Annex 14 define surfaces such as the strip width of the runway, approach and departure surfaces, transition surfaces, the inner horizontal , the conical and the outer horizontal surfaces. The dimensions of these surfaces vary with runway classification and the dimensions of the runway. Runway classification ranges from code 1 to code 4 and a numerical sub classification (A to G) and the runways could be non instrument, instrument non-precision and precision.
2.4 Obstacle assessments inside the boundaries of the aerodrome are not discussed in this document due to the amount of variables and complexity thereof.
Obstacle assessments outside the aerodrome would look at obstacles differently depending on utilization of the aerodrome and considers runways to be used for both departure and approach purposes:-
a) Small aerodromes utilized by small slow flying aircraft and featuring short runways would be evaluated against the criteria for code 2 instrument non precision approach surfaces with a slope of 3.3 % and a diversion of 15%. The inner horizontal would be regarded as a simple horizontal disk and diameter of 3500m above the published reference point of the aerodrome.
b) Large aerodromes utilized by large(r) and fast aircraft and featuring longer runways are evaluated against the criteria applicable for precision approaches with an ideal slope of 1.6% but to a slope of not exceeding 2% as may be dictated by existing structures or terrain. The inner horizontal now becomes a composite shape with circular arcs centered on the runway thresholds, and 45m above the runway threshold, and joined tangentially by straight lines. The same principle would apply to aerodromes featuring multiple runways. In practice this means that an obstacle is evaluated against the threshold elevation of the closest threshold.
This two tier approach to obstacle assessment is aimed at offering aerodromes more protection to facilitate future expansion
2.5 In some cases obstacles in the vicinity of aerodromes are subject to more stringent requirements dictated by possible interference to Radar and/or ILS systems as is the case at ORTIA where Radar absorbing cladding may be required on structures exceeding 1730m AMSL – a figure 6m below the inner horizontal surface.
2.6 All obstacles exceeding 45m AGL are marked by default in South Africa in terms of and to the standards of Part 139 while, structures exceeding 30mAGL and also 150m above aerodrome elevation is regarded as significant within 15 Km from the aerodrome and is also marked. The latter which relates to Doc 9137 Vol 6 is however adapted and applies to any structure exceeding 150m above the mean ground level.
2.7 Wind turbine generators or collectively called Wind farms, are obstacles with unique properties as not only are they of variable geometry; they also have the ability to interfere on avionic systems.
a) Most notable interference is false targets produced on PRIMARY RADAR when in line of sight but could also interfere when in close proximity of secondary radar. It is generally accepted that it would not interfere on SECONDARY RADAR beyond 15 Km in distance.
b) Wind turbines also cause disturbance in the air that shows up on meteorological radar systems as storm cells. This disturbance also holds a potential danger to small aircraft if allowed in close proximity of small aerodromes or areas of recreational flying.
2.8 By Part 139, no wind farm SHOULD be built within 35 km from an aerodrome. This 35 km is not a forbidden zone but rather a caution zone where extended investigation will be done if required and will involve all role players. This 35 km zone is bases on the Annex 10 protection criteria for ILS plus a buffer zone.
a) If an investigation indicates a possibility of interference, mitigation measures will be investigated and may involve repositioning or relocation of turbines. Options such as fill in radar may be considered if required or an application may be rejected outright if an acceptable level of mitigation cannot be reached.
b) Wind farms are subjected to unique marking methods differentiating it from any other obstacle. Any telecommunications structure or other structure within a wind farm will be regarded as part of the wind farm and will be marked accordingly.
c) Night markings of wind farms consist of dual flashing red lights of 2000 candela intensity. Not all turbines are marked but rather aimed at defining the outline of a wind farm and the most significant points. The flashing lights are synchronized.
2.9 It should be noted that the Northern Cape Province has proven to be a popular location for wind farms. While this location may have limited impact on aviation, the high intensity night markings of wind farms may bring it in conflict with the AGA Act, which saw the light as an effort to protect the Northern Cape for purposes of astronomy. This may lead to a re-consideration of marking methods.
3. Conclusion
3.1 While South Africa has got legislation in place to protect aviation from obstacles, including wind farms in Part 139.01.30 and also protection of Communication, Navigation and Surveillance systems including aeronautical meteorological systems in Part 171, this is a slow and cost intensive process.
Number Lat_DELat_MIN Lat_SEC Long_Long_MIN Long_SEC Height_m 1 2 3 4 5 6 7 8 9 10
Property boundarie co‐ordinates Number Lat_DEG Lat_MIN Lat_SEC Long_DEG Long_MIN Long_SEC Height_m 1 2 3 4 5 6 7 8 9 10 Aneesah Alwie
From: Juno Sent: Tuesday, November 6, 2018 12:52 PM To: 'Allen Lyons' Subject: RE: Map of target areas Attachments: Preliminary Site Constraints.jpg
Dear Allen
Please find attached the Preliminary Site Constraints map.
Thanks
From: Allen Lyons [mailto:[email protected]] Sent: Monday, November 5, 2018 9:38 To: Juno
Dear Ryan
The map on page 83 of appendix C6 is to small for me to read the legend. Could you please send me a larger version of this map?
Best regards
Allen Lyons
Secretary - Strandfontein Belastingbetalersvereniging (SBV)
1
Aneesah Alwie
From: Juno Sent: Tuesday, November 6, 2018 1:10 PM To: 'Allen Lyons'; [email protected] Cc: Lehan Fouche Subject: RE: Photos from Visual Impact assessment Attachments: Figure 16 - Sere WEF from R362.jpg; Figure 17 - Visual impact of Juno WEF from Coastal Cliffs.jpg; Photograph 2 - KOP6 visual impact of Juno WEF.jpg; Photograph 5 - KOP13 Entrance to Strandfontein visual impact of Juno WEF.jpg; Photograph 9 - KOP17 Viswater MTB Route visual impact of Juno WEF.jpg
Dear Allen
The visual specialist for the proposed Juno WEF and Grid Connection will not be attending the Public Meeting. This meeting is held specifically for Interested and Affected Parties of the proposed development.
Any queries for specialists may be directed via the EAP (Arcus). All comments or queries will be responded to.
Please find attached all photographs from the Visual Impact Assessment of the proposed Juno WEF that show turbines superimposed.
Thank you
From: Allen Lyons [mailto:[email protected]] Sent: Monday, November 5, 2018 11:48 To: [email protected] Cc: Lehan Fouche
Dear Mr Claasen
There is a Juno WF public meeting tomorrow in Strandfontein. Are you perhaps attending this meeting?
I would like to project some of the photos from your report at that meeting. Could you please send me the originals of the photos shown in figures 16 and 17? Am I correct in thinking that there are only 3 turbines shown in figure 17?
Pages 53 to 55 there are three other photos labeled "Expected visual impact". Could you please also send me the originals of these 3 images?
Best regards
Allen Lyons
Secretary - Strandfontein Belastingbetalersvereniging (SBV)
1
Aneesah Alwie
From: Allen Lyons
Dear Mr Granelli
I apologise for my oversight. Thanks for the info.
Best regards
Allen Lyons Secretary - Strandfontein Belastingbetalersvereniging (SBV)
On Monday, 5 November 2018, 08:53:44 GMT+2, Piero Granelli
Dear My Lyons
Thanks for your email and we look forward to meeting you tomorrow evening.
We believe it best to keep all the information and responses aligned with the application process, and are pleased to note that information you request (and more) has been provided in the “Comments and Responses” section of the Application, which starts from page 74. (Note that the answers to your technical queries about the mast are contained mainly in answers #47 and #48 on page 97 and following.)
Kind regards
Piero
Piero Granelli
CEO
AMDA Developments (Pty) Ltd
Mobile: +27 82 333 3368
Email: [email protected]
1
22 Dreyer Street, Claremont, Cape Town
PO Box 2681, Cape Town, 8000
From: Allen Lyons
Dear Mr Granelli
In preparation for Tuesday’s public meeting could you please provide the SBV with some background information on the following?
1. What month was De Boom chosen as the preferred site for AMDA’s development?
2. What month was the meteorological mast erected on De Boom?
3. What make and model anemometer was installed on the meteorological mast?
4. Besides an anemomenter, what other sensors were installed on the meteorological mast?
5. What are the technical specifications of the other sensors installed on the mast?
6. Wind density figures quoted in the scoping report is data collected by Government meteorological stations. Any specific reason why AMDA’s in house data is not being quoted by the independent consultants?
Best regards
Allen Lyons
Secretary - Strandfontein Belastingbetalersvereniging (SBV)
2 Aneesah Alwie
From: Juno Sent: Tuesday, November 6, 2018 12:44 PM To: Allen Lyons; Juno Cc: Lehan Fouche; Kobus Rossouw; Ashlin Bodasing Subject: RE: Tuesday's meeting - DEA representation
Dear Allen
No DEA representative will be attending the Public Meeting.
The Public Meeting is being held for the Interested and Affected Parties of the proposed Juno WEF and Grid Connection.
The DEA and Mr Booi will be provided with minutes of the Public Meeting in the Final EIA Report.
Thank you
From: Allen Lyons [mailto:[email protected]] Sent: Saturday, November 3, 2018 7:36 To: Juno
Dear Ryan
Will the DEA be represented at Tuesday afternoons meeting in Strandfontein.
We feel that it is important that Mr Booi attend that public meeting.
Best regards
Allen Lyons
Secretary - Strandfontein Belastingbetalersvereniging (SBV)
1 Aneesah Alwie
From: Louisa Truter
Follow Up Flag: Follow up Flag Status: Flagged
Many thanks.
On Fri, 16 Nov 2018, 11:57 Juno Dear Interested and Affected Parties Thank you for attending the Juno WEF and Associated Grid Connection Public Meeting on 06th November 2018 at the Strandfontein Municipal Hall. Please find attached the minutes of this meeting as well as the presentation projected at the meeting. Thank you Arcus Consultancy Services South Africa Tel: +27 (0) 21 412 1529 Mobile: +27 (0) 72 678 1523 Email: [email protected] 1 Arcus Office 220 Cube Workspace Cnr Long Street and Hans Strijdom Road Cape Town 8001 www.arcusconsulting.co.uk The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location. 2 Aneesah Alwie From: Juno Sent: Thursday, November 22, 2018 11:08 AM To: 'Lehan Fouche'; Ashlin Bodasing; Juno; [email protected] Cc: Allen Lyons; 'Kobus Rossouw' Subject: RE: Juno Wind Energy Facility Public meeting of 6 November 2018: Strandfontein Dear Lehan We hereby confirm that the minutes and presentation from the Public Meeting held on the 06th November 2018 in Strandfontein was distributed on the agreed date of 16th November 2018 and received by the SBV and other meeting attendees. Thank you From: Lehan Fouche [mailto:[email protected]] Sent: Thursday, November 15, 2018 7:35 To: Ashlin Bodasing Arcus Consulting Attention: Ashlin Bodasing As requested at and after the Public Meeting of 6 November 2018 in the Strandfontein Community Hall, the SBV would now like to receive the Consultant’s Presentation, full Minutes of the proceedings and comments raised, as well as the Attendance Register completed. Could we please obtain the required documents by latest end of business tomorrow. Thank you and regards. Lehan Fouche Voorsitter Strandfontein Belastingbetalersvereniging (SBV) 1 Strandfontein “maak dit jou trots!” Posbus 222 Doringbaai 8151 Sel no’s: 0787430549 (Lehan- Voorsitter) 0832328731 (Kobus- Tesourier) 0836306120 (Allen- Sekretaris) SBV E-pos: [email protected] 2 Aneesah Alwie From: Ryan David-Andersen Sent: Wednesday, November 28, 2018 3:13 PM To: 'Lehan Fouche'; Juno Cc: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; nellienagel7 @gmail.com; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; 'Allen Lyons' Subject: RE: Juno WEF and Associated Grid Connection - Public Meeting Minutes and Presentation Dear Lehan Thank you for the feedback. You are most welcome for the minutes. Thanks again for attending the Public Meeting and for the SBV’s active participation in the PPP. All comments received will be addressed in the Final EIA Report. Thank you From: Lehan Fouche [mailto:[email protected]] Sent: Monday, November 19, 2018 9:47 To: Juno Arcus Consulting Good morning. The Strandfontein Rate Payers Association acknowledge receipt of the Public Meeting Minutes and Presentation and will follow up on specific matters raised at the meeting of 6 November 2018. It will also be distributed to our SBV membership base for their information, attention and further input. Much appreciated and kind regards. Voorsitter 1 Strandfontein Belastingbetalersvereniging (SBV) Strandfontein “maak dit jou trots!” Posbus 222 Doringbaai 8151 Sel no’s: 0787430549 (Lehan- Voorsitter) 0832328731 (Kobus- Tesourier) 0836306120 (Allen- Sekretaris) SBV E-pos: [email protected] From: Juno [mailto:[email protected]] Sent: 16 November 2018 11:58 AM To: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; 'Allen Lyons'; Lehan Fouche Subject: Juno WEF and Associated Grid Connection - Public Meeting Minutes and Presentation Dear Interested and Affected Parties Thank you for attending the Juno WEF and Associated Grid Connection Public Meeting on 06th November 2018 at the Strandfontein Municipal Hall. Please find attached the minutes of this meeting as well as the presentation projected at the meeting. Thank you Arcus Consultancy Services South Africa Tel: +27 (0) 21 412 1529 Mobile: +27 (0) 72 678 1523 Email: [email protected] Arcus Office 220 Cube Workspace Cnr Long Street and Hans Strijdom Road Cape Town 2 8001 www.arcusconsulting.co.uk 3 Aneesah Alwie From: Juno Sent: Thursday, November 22, 2018 11:15 AM To: Allen Lyons; Juno; Ashlin Bodasing Cc: Lehan Fouche; Kobus Rossouw; Suzannè du Plessis; Thando Booi Subject: RE: Notification of Availability of Draft EIA and BA Reports for the Proposed Juno WEF and Grid Connection Dear Allen This comment was addressed in the minutes of the Public Meeting held in Strandfontein on the 06th November 2018. A relevant extract from the meeting minutes is provided below: ‘Notification Site Posters requesting registration for Interested and Affected Parties (I&APs) were strategically placed around the proposed Juno WEF site and at nearby public gathering points. The Site Posters combined with Initial Notification adverts in English and Afrikaans that were published in Ons Kontrei and The Daily Sun are expected to suffice as calls for registration as an I&AP. Registered I&APs receive all public correspondence relating to the proposed development including invitations to attend the Public Meetings.’ Thank you From: Allen Lyons [mailto:[email protected]] Sent: Thursday, November 1, 2018 8:20 To: Juno Dear Ms Bodasing The previous public meeting in Strandfontein was poorly attended. Will Arcus be advertising Tuesdays meeting in the local newspaper? Best regards Allen Lyons Secretary - Strandfontein Belastingbetalersvereniging (SBV) On Wednesday, 31 October 2018, 13:54:18 GMT+2, Juno Dear Allen Notification of the combined Public Participation Process (PPP) for the Proposed Juno WEF EIA and the Proposed Juno Grid Connection Basic Assessment (BA) was provided in the Initial Interested and Affected Party (I&AP) Notification Letter, at the first Public Meeting held in Strandfontein and in the Scoping Report. 1 The Draft Basic Assessment Report (BAR) for the Proposed Juno Grid Connection has been provided for a 30 Day Public Comment period of 30th October 2018 to 28th November 2018. This comment period allows I&APs to comment on the Draft BA Report in compliance with requirements of the EIA Regulations 2014 as amended - in particular Regulation 19 of GNR 326. The comments received during this 30 day period will be incorporated into a Final BAR that will be submitted to the DEA for decision-making. The interrelation of the two projects - the Juno WEF and the Juno Grid Connection - and of the separate Environmental Authorisation (EA) application processes is the reason for combining the two PPPs. One project cannot proceed without the other. Arcus will present the findings of the Draft BAR for the Juno Grid Connection and facilitate questions and answers relating to the Grid Connection at the Public Meeting in Strandfontein on Tuesday 06th November 2018. As mentioned this will not be the only platform for I&APs to comment on the Draft BAR - any comments may be submitted to Arcus in writing by the 28th November 2018. The purpose of including the Draft BAR in the Public Meeting presentation is for information and clarity. Arcus is of the opinion that the venue chosen (Strandfontein Municipal Hall) is suitable for a presentation on the proposed Grid Connection. Vredendal is approximately 50 km and Lutzville 30 km from the chosen venue by road. We will thus be presenting the findings of the Draft EIA Report for the Proposed Juno WEF as well as the Draft BA Report for the Proposed Juno Grid Connection at the Public Meeting in Strandfontein on the 06th November 2018. Regards, Ashlin From: Allen Lyons [mailto:[email protected]] Sent: Wednesday, October 31, 2018 6:20 To: Juno 2