FINAL BASIC ASSESSMENT REPORT INSTALLATION OF A TELECOMMUNICATION MAST AND ASSOCIATED INFRASTRUCTURE AT PYRAMID SOUTH IN GAUTENG, SOUTH AFRICA

PROPOSED INSTALLATION OF A TELECOMMUNICATION MAST AND ASSOCIATED INFRASTRUCTURE AT PYRAMID SOUTH IN GAUTENG, SOUTH AFRICA

DEFF REF: 14/12/16/3/3/1/2215

FINAL BASIC ASSESSMENT REPORT

Prepared for:

TRANSNET FREIGHT RAIL

Prepared by:

CES Centurion 70 Regency Dr Route 21 Business Park Centurion, 0178 010 045 1372 | 012 751 2160 Also in Grahamstown, Port Elizabeth, East London, Cape Town and Maputo (Mozambique)

www.cesnet.co.za

OCTOBER 2020

FINAL Basic Assessment Report

REVISIONS TRACKING TABLE

CES Report Revision and Tracking Schedule Proposed installation of a telecommunication mast at Pyramid South Document Title in Gauteng, South Africa Transnet Freight Rail Inyanda House 2 Client Name & Address 15 Girton Road Parktown Johannesburg, 2193 Document Reference DEFF Reference: 14/12/16/3/3/1/2215

Status FINAL BASIC ASSESSMENT REPORT

Issue Date October 2020

Lead Author Mr Aidan Gouws CES

Reviewer Mr Gregory Shaw CES Study Leader/ Registered Environmental Assessment Mr Gregory Shaw CES Practitioner – Approval No. of hard No. electronic Report Distribution Circulated to copies copies Transnet Freight Rail Mr Ndivhuwo Netshilaphala 1 Department of Environment, Mr Thando Booi 1 Forestry and Fisheries

Report Version Final

This document has been prepared in accordance with the scope of CES’s appointment and contains intellectual property and proprietary information that is protected by copyright in favour of CES. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of CES. This document is prepared exclusively for use by CES’s client. CES accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared. No person other than the client may copy (in whole or in part), use or [email protected] rely on the contents of this document, without the prior written www.cesnet.co.za permission of CES. The document is subject to all confidentiality, copyright, trade secrets rules and intellectual property law and practices of South Africa.

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PROJECT TEAM

CES has been appointed by Transnet Freight Rail (TFR) as independent consultants to undertake a Basic Assessment (BA) process for the proposed installation of a telecommunication mast and associated infrastructure, as required by the NEMA EIA Regulations, 2014, as amended. The BA process is largely dependent on the information and assessments provided by the independent specialists and the input received during the public participation process in order to inform the overall environmental assessment of the proposed development on both environmental and social aspects.

The process where the environmental impacts associated with a project are assessed is a collective effort from a team of appropriate and independent specialists, as well as an independent Environmental Assessment Practitioner (EAP). The EIA is required to assess the planned development from a holistic perspective, considering all aspects and characteristics within the affected natural and social environment.

The following specialist consultants have provided expert input and a detailed assessment of the project in order to assess the environmental and social impacts within the affected environment as well as the acceptability of the application.

CES team and responsibilities CES TEAM MEMBER PROJECT RESPONSIBILITIES Dr Alan Carter Environmental Assessment Practitioner Mr Gregory Shaw Project Leader, Report Reviewer Mr Aidan Gouws Project Manager, Public Participation Manager, Lead Report Writer Mr Michael Johnson Visual Impact Specialist

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EXECUTIVE SUMMARY

BACKGROUND Transnet Freight Rail (TFR) proposes to construct a telecommunication mast and associated infrastructure in an effort to improve the communication channels between train conductors along the existing railway network at Pyramid South in Pretoria, Gauteng. CES has been appointed by TFR as an independent Environmental Assessment Practitioner (EAP) to undertake a Basic Assessment (BA), including specialist Visual Impact Assessment (VIA), and apply for the necessary Environmental Authorisation (EA) for the proposed project.

LOCATION AND SITE DESCRIPTION The mast will be constructed in an area where existing freight rail-related infrastructure has been installed, namely within the fenced Central Train Control (CTC) premise. Pyramid South is located along the R101 (Lavender Road), approximately 6km north-east of Bon Accord Dam, 20km north of Pretoria CBD and 30km south of Hammanskraal, within the Tshwane Metropolitan Municipality in Gauteng Province. The project site is located on a property currently used for the train station. The proposed mast will be located on Portion 18 of Farm Doornpoort 295 JR (SGID: T0JR00000000029500018). Figure 2-1 illustrates the project location. The vegetation cover within the CTC area is limited to patchy lawn grass, interspersed between bare grounds, with a few scattered garden tree species. From the site, the adjacent property to the south appears to be mostly covered by indigenous bushveld. The land adjacent to the CTC area to the north, east and west is completely transformed by the railway lines, access roads and other associated infrastructure.

Figure 2-1: Location of the proposed site at Pyramid South near Pretoria, Gauteng.

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PROJECT DESCRIPTION The general requirement is a 35m tapered steel lattice tower with either a square or triangular base. The design is a tapered, self-supporting lattice type mast (angle iron) with a 2.5m2 Antenna load at the top of the mast, which needs to sustain wind speeds up to 160km/h. The mast shall be painted red and white, and shall have a Direct Current (DC) powered navigation light on top. The mast will occupy a footprint of 3m x 3m (9m2) and will be constructed in an area where existing freight rail infrastructure has been installed, namely within the fenced Central Train Control (CTC) station premises. The associated infrastructure to be installed will include a cable tray run, 5m in length and 457mm wide, as well as a 390mm x 240mm cable entry plate. The site layout plan is illustrated in Figure 2-3 below. No site camps will be required as the contractor will stay off site. Construction tools will be housed inside TFR property and construction material will be placed on the “Stockpiling Location” indicated on the site layout.

In terms of the Environmental Impact Assessment (EIA) regulations of 2014 (as amended), the TFR telecommunications project requires Environmental Authorisation, from the Department of Environment, Forestry and Fisheries (DEFF), for the proposed mast . The triggered activities are listed under Listing Notices 3 only (published in Government Notices No. R 985 respectively), and as such, the BA Process needs to be followed. The listed activities that have been applied for are provided in Table 4-1 below.

Table 4-1: Listed activities as described in GN R 985 (as amended) triggered by the proposed mast. Description of Activity project activity Listing Listed Activity Number that triggers listed activity The development of mast or towers of any material or type used for telecommunication broadcasting or radio transmission purposes where the mast or tower— The mast will be (a) Is to be placed on a site not previously used 35m in height, for this purpose; and thereby exceeding the 15m threshold, Listing 3 (b) Will exceed 15 metres in height 3(c) and falls within an GN R 985 c. Gauteng Endangered ecosystem v. Sites identified within threatened (Marikana ecosystems listed in terms of the National Thornveld) Environmental Management Act: Biodiversity Act (Act No. 10 of 2004);

PUBLIC PARTICIPATION PROCESS Public consultation is a legal requirement throughout the BA process. The Public Participation Process included:  Placing notice boards on site;  Identifying and registering Interested and Affected Parties (I&APs) and relevant stakeholders;  Providing notice to I&APs and stakeholders of the intent to submit an application for EA and the release of the Draft Basic Assessment Report (BAR) for public review.

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 Publishing an advertisement in a local newspaper notifying the public of the release of the Draft BAR for public review;  Keeping a register of all comments by and responses to registered I&APs and stakeholders for inclusion in the Final BAR.

IMPACT ASSESSMENT Table 12-1 provides an overall summary of the negative (cost) and positive (benefit) environmental impacts associated with the proposed telecommunications mast.

Table 12-1: Summary of impacts before and after mitigation across phases. Before Mitigation After Mitigation Theme Low Moderate High Low Moderate High Environmental -3 -3 policy Built -10 (+1) -10 (+1) environment Terrestrial -2 -8 -1 -11 environment Hydrological -1 -1 environment Socio- -2 (+1) -7 -9 (+1) economic Rehabilitation and -3 -3 maintenance Landscape -4 -3 -4 -3 and aesthetic Total -8 (+1) -32 (+1) -4 -41 (+1) -3 (+1) 0

Overall, the table above indicates that there are several potential negative impacts (environmental costs) associated with the proposed telecommunications mast. However, the significance of these can be reduced to an acceptable level by implementing appropriate mitigation measures. There are a few positive impacts (benefits) associated with the proposed telecommunications mast. These relate primarily to the improvement of the telecommunication infrastructure along the existing freight rail lines and associated efficiency and safety benefits, and the creation of temporary jobs. Based on the above analysis it can be seen that pre- mitigation, there are eight negative impacts of LOW significance, 32 of MODERATE significance and four of HIGH. After mitigation there be no negative residual impacts of HIGH, with only three visual impacts of MODERATE significance.

VISUAL IMPACT SPECIALIST OPINION Overall, the telecommunication mast and associated infrastructure will have a low to moderate impact on the visual landscape for certain visual receptors. However, this should be considered within the context of the following:  Existing industrial and electrical infrastructure, including the railway line, the Transnet Depot, overhead powerlines and telephone lines, already impose on the visual landscape for nearby visual receptors; and  Although limited, certain mitigation recommendations in this report can mitigate the impacts to some extent, it is concluded that potential losses of scenic resources are not sufficiently significant to present a fatal flaw to the proposed project.

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SITE SENSITIVITY A site sensitivity analysis has been conducted based on specialist and general site information gathered. The site was classified into areas of low, conditional sensitivity and NO-GO development. The Pyramid South project site falls within an area of low terrestrial and hydrological sensitivity, with no significant environmental sensitivities found on site. Areas of moderate terrestrial sensitivity, namely an ESA and vulnerable ecosystem, are found within 500m to the north and west of the site. A high sensitivity hydrological area (natural wetland) is found within 500m to the north-west of the site. Considering the relatively small footprint of the mast and its location within the fenced CTC area, which has already been transformed for freight rail purposes, the proposed mast will minimally impact upon sensitive terrestrial and hydrological environments.

CONCLUDING REMARKS AND RECOMMENDATIONS It is the professional opinion of CES and specialists that:  NO FATAL FLAWS are currently associated with the proposed telecommunications mast installation, as all identified impacts can be adequately mitigated to reduce the risk or significance of impacts to an acceptable level, provided mitigation measures recommended in this report are implemented and maintained throughout the life of the project.  If any changes to these layouts are made, the input of the relevant specialist must be obtained and incorporated into any changes.  The information in the report is sufficient to allow DEFF to make an informed decision.

It is the recommendation of CES that the proposed telecommunications mast should be approved provided that the proposed mitigation measures are implemented and that the Environmental Management Programme (EMPr) is implemented, maintained and adapted to incorporate relevant legislation, standard requirements and audit reporting, throughout the life of the development. The mitigation measures for all impacts identified in this report must be incorporated into the EMPr and must be used by the engineers during the detailed Planning & Design Phase, by the contractors during the Construction Phase and by TFR during the Operation Phase.

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TABLE OF CONTENTS

1 INTRODUCTION ...... 1

Background ...... 1 Purpose of this Report ...... 1 Details and Experience of the Environmental Assessment Practioner ...... 1 Nature and Structure of the Report ...... 3 Scope of Assessment and Content of the Basic Assessment Report ...... 3 2 PROJECT DESCRIPTION ...... 7

Project Location ...... 7 General Site Observations ...... 7 Technical Details...... 7 3 PROJECT NEED AND DESIRABILITY ...... 11

Development Planning ...... 11 Infrastructure development ...... 11 Environmental Rights ...... 12 Ecological Sustainability ...... 12 4 RELEVANT LEGISLATION ...... 13

Environmental Authorisation in South Africa ...... 13 Applicable Legislation ...... 14 National ...... 14 The Constitution Act, 1996 (Act No. 108 of 1996) ...... 14 National Environmental Management Act, 1998 (Act No. 107 of 1998) ...... 15 National Environment Management: Biodiversity Act, 2004 (Act No. 10 of 2004) ... 16 Telecommunications Act, 1966 (Act No. 103 of 1966) ...... 17 National Environmental Management: Waste Management Act, 2008 (Act No. 59 of 2008) 17 Occupational Health and Safety Act, 1993 (Act No. 85 of 1993) ...... 18 Aviation Act, 1962 (Act No. 74 of 1962): 13th Amendment of the Civil Aviation Regulations 1997 ...... 18 National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) .. 18 National Water Act, 1998 (Act No. 36 of 1998) ...... 19 National Road Traffic Act, 1996 (Act No. 93 of 1996) ...... 20 Other Relevant National Legislation ...... 20 Provincial ...... 20 Gauteng Conservation Plan (C-Plan v3.3) ...... 20 Gauteng Province Environmental Management Framework ...... 21

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Other ...... 21 5 DESCRIPTION OF THE AFFECTED ENVIRONMENT ...... 23

Biophysical Environment ...... 23 Climate ...... 23 Topography ...... 24 Geology ...... 24 Watercourses ...... 24 Soils ...... 28 Vegetation and Floristics ...... 28 National Vegetation Map (Mucina & Rutherford 2018) ...... 28 Critical Biodiversity Areas and broad-scale processes ...... 28 Fauna ...... 33 Amphibians ...... 33 Reptiles ...... 33 Mammals ...... 33 Avifauna ...... 33 Land Use and Cover ...... 34 Socio-Economic Profile ...... 37 Population ...... 37 Economy ...... 37 Employment, Education, Income and Poverty ...... 37 6 PUBLIC PARTICIPATION PROCESS ...... 38

Notification to Potential I&APs ...... 38 Site Notices and Posters ...... 38 I&AP and Stakeholder Notifications ...... 38 Newspaper Advertisement ...... 39 Register of Stakeholders and I&APs ...... 39 Public Review of Draft BAR ...... 40 Issues Raised by I&APs ...... 40 7 ALTERNATIVES ...... 41

Fundamental, Incremental and No-go Alternatives ...... 41 Fundamental Alternatives ...... 41 Incremental Alternatives ...... 41 No-go Alternative ...... 41 Alternatives Considered ...... 42 Location Alternatives ...... 42

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Activity Alternatives ...... 42 Technology Alternatives ...... 42 Layout Alternatives ...... 42 No-go Alternative ...... 42 Evaluation of Alternatives ...... 43 8 IMPACT ASSESSMENT METHODOLOGY ...... 46

Aims of Environmental Impact Assessment ...... 46 Impact Assessment Criteria ...... 46 Assessment of Cumulative Impacts ...... 49 Technical Scope...... 50 9 VISUAL SPECIALIST KEY FINDINGS AND IMPACTS ...... 54

10 IMPACT ASSESSMENT ...... 58

Planning and Design Phase Impacts ...... 59 Construction Phase Impacts ...... 63 Operational Phase Impacts ...... 68 Impacts Associated with the No-Go Alternative ...... 70 Cumulative impacts ...... 70 11 SENSITIVITY ANALYSIS ...... 71

12 SUMMARY OF KEY ENVIRONMENTAL FINDINGS ...... 76

13 CONCLUSIONS AND RECOMMENDATIONS ...... 77

Description of the Proposed Activity ...... 77 Assumptions, Uncertainties and Gaps ...... 77 Assumptions ...... 77 Gaps ...... 77 Consideration of alternatives ...... 78 Location Alternatives ...... 78 Activity Alternatives ...... 78 Technology Alternatives ...... 78 Layout Alternatives ...... 78 No-go Alternative ...... 78 Opinion of the EAP ...... 78 Recommendation of the EAP and Specialist ...... 79 14 APPENDICES ...... 80

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LIST OF TABLES

Table 4-1: Listed activities as described in GN R 985 (as amended) triggered by the proposed mast...... 13 Table 4.2: NEMA Environmental Management Principles ...... 15 Table 7-1: Analysis of the proposed alternatives for the TFR Telecommunication mast and associated infrastructure...... 44 Table 8-1: Ranking of Evaluation Criteria ...... 46 Table 8-2: Description of significance ratings ...... 49 Table 8-3: Technical scope of the impacts identified during all phases of the proposed mast installations...... 51 Table 9-1: Summary of visual impacts associated with the proposed telecommunications mast ...... 55 Table 10-1: Summary of impacts associated with the proposed telecommunications mast during the planning and design phase...... 59 Table 10-2: Summary of impacts associated with the proposed telecommunications mast during the construction phase...... 63 Table 10-3: Summary of impacts associated with the proposed telecommunications mast during the operational phase...... 68 Table 10-4: Summary of impacts associated with the no-go alternative to the proposed telecommunications mast...... 70 Table 11-1: Sensitive Features in the Study Area ...... 71 Table 12-1: Summary of impacts before and after mitigation across phases...... 76

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LIST OF FIGURES

Figure 2-1: Location of the proposed site at Pyramid South near Pretoria, Gauteng...... 8 Figure 2-2: Site of the proposed site within the CTC area at Pyramid South near Pretoria, Gauteng...... 9 Figure 2-3: Site layout of the proposed radio high mast at Pyramid South...... 10 Figure 5-1: Climate graph for Pretoria (Climate-Data.Org, 2019)...... 23 Figure 5-2: Elevation profile from north to south (top) and west to east (bottom) within 500m of the proposed Pyramid South mast site...... 24 Figure 5-3: Topographical map of the surrounding area at the Pyramid South site...... 25 Figure 5-4: Geological Profile of the Pyramid South site and surrounding area...... 26 Figure 5-5: Hydrological map of the area surrounding the proposed Pyramid South mast site...... 27 Figure 5-6: SOTER Soil Association map of the proposed Pyramid South site and surroundings...... 30 Figure 5-7: Mucina & Rutherford Vegetation Map of the proposed mast site at Pyramid South...... 31 Figure 5-8: Gauteng Conservation Plan map of the proposed site at Pyramid South...... 32 Figure 5-9: Important Birding Areas (IBA) and protected areas located near the proposed site at Pyramid South...... 35 Figure 5-10: Land use and cover surrounding the proposed mast site at Pyramid South .... 36 Figure 9-1: Potential visual receptors for the proposed development site at Pyramid South.54 Figure 11-1: Terrestrial Environment Site Sensitivity for the Pyramid South project site...... 73 Figure 11-2: Hydrological Environment Site Sensitivity for the Pyramid South project site. . 74 Figure 11-3: Overall Site Sensitivity for the Pyramid South project site...... 75

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ACRONYMS

AIS Alien Invasive Species BID Background Information Document BAR Basic Assessment Report CA Competent Authority CBA Critical Biodiversity Area CES Coastal and Environmental Services (Pty) Ltd. (t/a CES) DEFF Department of Environment, Forestry and Fisheries EA Environmental Authorisation EAP Environmental Assessment Practitioner ECO Environmental Control Officer EIA Environmental Impact Assessment EMPr Environmental Management Programme ESA Ecological Support Area GN Government Notice IDP Integrated Development Plan I&AP Interested and Affected Party MEC Member of the Executive Council NEMA National Environmental Management Act NEMBA National Environmental Management Biodiversity Act NFEPA National Freshwater Ecosystem Priority Area NDP National Development Plan PPP Public Participation Process SACNASP South African Council for Natural Scientific Professions SANBI South African National Biodiversity Institute SDF Spatial Development Framework SCC Species of Conservation Concern SG Surveyor General TFR Transnet Freight Rail

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1 INTRODUCTION

BACKGROUND

Transnet Freight Rail (TFR) proposes to construct a telecommunication mast and associated infrastructure in an effort to improve the communication channels between train conductors along the existing rail network at Pyramid South in Pretoria, Gauteng.

CES was appointed by TFR as an independent Environmental Assessment Practitioner (EAP) to undertake a Basic Assessment (BA), including Visual Impact Assessment (VIA), and apply for the necessary Environmental Authorisation (EA) for the proposed project.

PURPOSE OF THIS REPORT

In accordance with the National Environmental Management Act, 1998 (Act No. 107 0f 1998) (NEMA) and the NEMA EIA Regulations (2014), as amended, the issuing of an Environmental Authorisation (EA) requires the undertaking of a BA process, with associated Public Participation Process (PPP) and required specialist studies. This will enable the competent authority to decide whether to issue an EA for the proposed development, and if so, on what conditions. The EIA Regulations (2014) (as amended) allow for a BA process for activities with limited environmental impact (listed in GN R 983 and 985) and a more rigorous two-tiered approach, known as a Scoping/EIA process, for activities with potentially greater environmental impact (listed in GN R 984).

In terms of the EIA regulations of 2014 (as amended), the triggered activity for this project is listed under Listing Notice 3 only (published in Government Notices No. R 985), and as such, the BA Process will be followed, including a VIA specialist assessment.

This report documents the process and findings of the BA for the proposed telecommunication mast and associated infrastructure. This report was subject to a public comment period after which it was finalised and hereby submitted to the competent authority for review.

DETAILS AND EXPERIENCE OF THE ENVIRONMENTAL ASSESSMENT PRACTIONER

In fulfilment of the legislative requirement (see Section 4.1 below) the details of the EAP that prepared this Basic Assessment Report (BAR) as well as the expertise of the individual members of the study team are provided below.

CES was established in 1990 as a specialist environmental consulting company based in Grahamstown, with branches in East London, Cape Town, Port Elizabeth and Centurion. CES has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, and state of environment reporting (SOER), Integrated Waste Management Plans (IWMP), Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) processes. CES has been active in all of the above fields, and in so doing have made a positive contribution to towards

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environmental management and sustainable development in the Eastern Cape, South Africa and many other African countries.

Dr Alan Carter (Role: Environmental Assessments Practitioner [EAP]) Alan is the executive of the CES East London Office. He holds a PhD in Marine Biology and is a certified Public Accountant, with extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He has 25 years of experience in environmental management and has specialist skills in sanitation, coastal environments and industrial waste. Dr Carter is registered as a Professional Natural Scientist under the South African Council for Natural Scientific Professions (SACNASP). He is also registered as an EAP by the Environmental Assessment Practitioners of South Africa (EAPSA).

Mr Gregory Shaw is a Principal Environmental Consultant and the Business Development Manager at CES. Greg has 12 years’ experience in conducting environmental consultancy services in the energy, transport, maritime and agricultural sectors on behalf of South African and oversees government departments and agencies, local government authorities, private developers, international funding organisations, and non-government organisations. He has a strong track record of projects completed within budget, on time and in accordance with national and/or international environmental legislation and guidelines. Greg’s skills include ESIA, environmental survey development, management, execution and monitoring, report writing, project management and strategic planning.

Mr Aidan Gouws obtained his MSc in Environmental Science (Cum laude) from Rhodes University, having conducted research on the spatio-temporal dynamics of Acacia dealbata invasions and broader land-use and cover changes in the northern Eastern Cape, funded through a study bursary awarded by the Agricultural Research Council (ARC). Prior to this, he obtained his BSc Honours in Geographical and Environmental Sciences (Cum laude) from the University of Pretoria, studying plant ecology and EIA methodology amongst others. He is also member of the Golden Key Honours Society. Aidan joined CES in 2018 and has been involved in several projects, including Basic Assessments, Full Scoping and Environmental Impact Assessments, Environmental Audits and Resettlement Action Plan (RAP) Audit. He works from the Johannesburg office and his interests include the general Environmental Impact Assessment (EIA) process, GIS mapping, ecological studies and the Public Participation Process (PPP).

Mr Michael Johnson holds a BSc in Geoinformatics, a BSc (Hons) Cum laude in Geoinformatics and an MSc in Geoinformatics from Stellenbosch University. Michael’s Master’s thesis examined the use of Remote Sensing and computer vision technologies for the extraction of near-shore ocean wave characteristic parameters. For the duration of his Master’s, he was based at the CSIR in Stellenbosch. During this time, in addition to his Master’s studies, he conducted work in collaboration with the CSIR Coastal Systems Research Group and provided GIS and Remote Sensing tutoring and technical assistance to the junior staff and fellow students. In 2017, Michael completed the Environmental Impact Assessment short course through Rhodes University. Michael graduated from Stellenbosch University in March 2018 and has been working for CES since. Since joining CES, Michael has been involved in a number of projects where his GIS and Remote Sensing skills have

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been utilised. These include, but are not limited to, landcover mapping for the King Cetswayo District Municipality Environmental Management Framework, the use of remote sensing to map invasive alien plant species for the Buffalo City Invasive Alien Species Management Plan and multiple Visual Impact Assessments. He has also been involved in a number of EIA’s. Michael is registered with the South African Geomatics Council as a Candidate Geomatics Practitioner: GISc Professional (CGPrGISc 0299).

Full Curricula Vitae (CV) for individual members of the project team are attached as Appendix F1.

NATURE AND STRUCTURE OF THE REPORT

The structure of this report is based on Appendix 1 of GN R 982, of the EIA Regulations (2014) (as amended), which clearly specifies the required content of a Basic Assessment Report.

 Chapter 1 introduces the proposed project and describes the purpose of this report and its structure.  Chapter 2 details the project location and describes the proposed project in detail, including primary infrastructure such as the pylon types and infrastructural requirements.  Chapter 3 describes the needs and desirability of the project.  Chapter 4 describes the legislation that is applicable to the project.  Chapter 5 describes the biophysical and social environment of the proposed project site.  Chapter 6 describes the Public Participation Process (PPP) undertaken.  Chapter 7 provides a description of the alternatives to the proposed development, or components of the proposed development.  Chapter 8 covers the impact assessment methodology.  Chapter 9 provides a summary of the key findings of the specialist study for the proposed project.  Chapter 10 covers the impact assessment for the proposed project.  Chapter 11 provides a sensitivity analysis.  Chapter 12 provides a summary of the key environmental findings.  Chapter 13 provides recommendations and concludes this report.

SCOPE OF ASSESSMENT AND CONTENT OF THE BASIC ASSESSMENT REPORT

Section 3 of Appendix 1 of GN R982, as amended, specifies the content requirements for a Basic Assessment Report. The table below indicates how this document complies with these requirements.

Section 3 NEMA EIA Regulations – Appendix 1 Requirement Section in Report (a) details of- Section 1.3 (i) the EAP who prepared the report; and Appendix F1 (ii) the expertise of the EAP, including a curriculum vitae; (b) the location of the activity, including- Section 2.1

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Section 3 NEMA EIA Regulations – Appendix 1 Requirement Section in Report (i) the 21-digit Surveyor General code of each cadastral land parcel; (ii) where available, the physical address and farm name; (iii) where the required information in items (i) and (ii) is not available, the coordinates of the boundary of the property or properties; (c) a plan which locates the proposed activity or activities applied for Section 2.1 and at an appropriate scale, or, if it is- Appendix A1 (i) a linear activity, a description and coordinates of the corridor in which the proposed activity or activities is to be undertaken; or (ii) on land where the property has not been defined, the coordinates within which the activity is to be undertaken; (d) a description of the scope of the proposed activity, including- Section 4.1 and (i) all listed and specified activities triggered; (ii) a description of the activities to be undertaken, including Section 4.2 associated structures and infrastructure; (e) a description of the policy and legislative context within which Section 4.2 the development is proposed including (i) an identification of all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks, and instruments that are applicable to this activity and have been considered in the preparation of the report; and (ii) how the proposed activity complies with and responds to the legislation and policy context, plans, guidelines, tools frameworks, and instruments; (f) a motivation for the need and desirability for the proposed Chapter 3 development including the need and desirability of the activity in the context of the preferred location; (g) a motivation for the preferred site, activity and technology Chapter 7 alternative; (h) a full description of the process followed to reach the proposed preferred alternative within the site, including - (i) details of all the alternatives considered; Chapter 7 (ii) details of the PPP undertaken in terms of regulation Chapter 6 and 41 of the Regulations, including copies of the Appendix D supporting documents and inputs; (iii) a summary of the issues raised by I&APs, and an Appendix D6 indication of the manner in which the issues were incorporated, or the reasons for not including them; (iv) the environmental attributes associated with the Chapter 5 alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects; Chapter 9, Chapter (v) the impacts and risks which have informed the 10 and Appendix B identification of each alternative, including the nature, significance, consequence, extent, duration and probability of such identified impacts, including the degree to which these impacts- (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be avoided, managed or mitigated; Chapter 8

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Section 3 NEMA EIA Regulations – Appendix 1 Requirement Section in Report (vi) the methodology used in identifying and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks associated with the alternatives; Chapter 9, (vii) positive and negative impacts that the proposed Chapter 10 and activity and alternatives will have on the Appendix B environment and on the community that may be

affected focusing on the geographical, physical,

biological, social, economic, heritage and cultural aspects; Chapter 9, Chapter (viii) the possible mitigation measures that could be 10 and Appendix B applied and level of residual risk; N/A (ix) the outcome of the site selection matrix; Chapter 7 (x) if no alternatives, including alternative locations for the activity were investigated, the motivation for not considering such; and (xi) a concluding statement indicating the preferred Section 13.3 alternatives, including preferred location of the activity; (i) a full description of the process undertaken to identify, assess Chapter 8, Chapter and rank the impacts the activity will impose on the preferred 9, Chapter 10 and location through the life of the activity, including - Appendix B (i) a description of all environmental issues and risks that were identified during the EIA process; and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures; (j) an assessment of each identified potentially significant impact Chapter 9, Chapter and risk, including— 10 and Appendix B (i) cumulative impacts; (ii) the nature, significance and consequences of the impact and risk; (iii) the extent and duration of the impact and risk; (iv) the probability of the impact and risk occurring; (v) the degree to which the impact and risk can be reversed; (vi) the degree to which the impact and risk may cause irreplaceable loss of resources; and (vii) the degree to which the impact and risk can be avoided, managed or mitigated; (k) where applicable, a summary of the findings and impact Chapter 9 management measures identified in any specialist report complying with Appendix 6 to these Regulations and an indication as to how these findings and recommendations have been included in the final report; (l) an environmental impact statement which contains— Chapter 12 (i) a summary of the key findings of the EIA; Chapter 10 (ii) a map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers; and (iii) a summary of the positive and negative impacts and Chapter 12 risks of the proposed activity and identified alternatives;

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Section 3 NEMA EIA Regulations – Appendix 1 Requirement Section in Report (m) based on the assessment, and where applicable, impact Appendix E management measures from specialist reports, the recording of the proposed impact management outcomes for the development for inclusion in the EMPr; (n) any aspects which were conditional to the findings of the Chapter 13 assessment either by the EAP or specialist which are to be included as conditions of authorisation; (o) a description of any assumptions, uncertainties, and gaps in Chapter 13 knowledge which relate to the assessment and mitigation measures proposed; (p) a reasoned opinion as to whether the proposed activity should or Chapter 3 should not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation; (q) where the proposed activity does not include operational N/A aspects, the period for which the environmental authorisation is required, the date on which the activity will be concluded, and the post construction monitoring requirements finalised; (r) an undertaking under oath or affirmation by the EAP in relation Appendix F2 to— (i) the correctness of the information provided in the reports; (ii) the inclusion of comments and inputs from stakeholders and I&APs; (iii) the inclusion of inputs and recommendations from the specialist reports where relevant; and (iv) any information provided by the EAP to I&APs and any responses by the EAP to comments or inputs made by I&APs; and

(s) where applicable, details of any financial provision for the N/A rehabilitation, closure, and ongoing post decommissioning management of negative environmental impacts; (t) any specific information that may be required by the competent N/A authority; and (u) any other matters required in terms of section 24(4)(a) and (b) of N/A the Act.

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2 PROJECT DESCRIPTION

PROJECT LOCATION

Transnet Freight Rail proposes to construct a radio high site telecommunication mast and associated infrastructure at Pyramid South. The mast will be constructed in an area where existing rail-related infrastructure has been installed, namely within the fenced Central Train Control (CTC) premise. Pyramid South is located along the R101 (Lavender Road), approximately 6km north-east of Bon Accord Dam, 20km north of Pretoria CBD and 30km south of Hammanskraal, within the Tshwane Metropolitan Municipality in Gauteng Province. The project site is located on a property currently used for the train station. The proposed mast will be located on Portion 18 of Farm Doornpoort 295 JR (SGID: T0JR00000000029500018). Figure 2-1 illustrates the project location (A3 Locality map provided in Appendix A1).

GENERAL SITE OBSERVATIONS

The proposed telecommunication mast and associated infrastructure will be located within the existing, fenced CTC area at the TFR Pyramid South site in an area already used for rail- related purposes (Figure 2-2). The vegetation cover within the CTC area is limited to patchy lawn grass, interspersed between bare grounds, with a few scattered garden tree species. From the site, the adjacent property to the south appears to be mostly covered by indigenous bushveld. The land adjacent to the CTC area to the north, east and west is completely transformed by the freight railway lines, access roads and other associated infrastructure. Site photographs can be found in Appendix A2.

TECHNICAL DETAILS

The general requirement is a 35m tapered steel lattice tower with either a square or triangular base. The design is a tapered, self-supporting lattice type mast (angle iron) with a 2.5m2 Antenna load at the top of the mast, which needs to sustain wind speeds up to 160km/h. The mast shall be painted red and white, and shall have a Direct Current (DC) powered navigation light on top. The mast will occupy a footprint of 3m x 3m (9m2) and will be constructed in an area where existing freight rail infrastructure has been installed, namely within the fenced Central Train Control (CTC) station premises. The associated infrastructure to be installed will include a cable tray run, 5m in length and 457mm wide, as well as a 390mm x 240mm cable entry plate. The site layout plan is illustrated in Figure 2-3 below.

No site camps will be required as the contractor will stay off site. Construction tools will be housed inside TFR property and construction material will be placed on the “Stockpiling Location” indicated on the site layout.

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Figure 2-1: Location of the proposed site at Pyramid South near Pretoria, Gauteng.

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Figure 2-2: Site of the proposed site within the CTC area at Pyramid South near Pretoria, Gauteng.

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STOCKPILING LOCATION

Figure 2-3: Site layout of the proposed radio high mast at Pyramid South.

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3 PROJECT NEED AND DESIRABILITY

The need and desirability of the proposed mast installation were evaluated in terms of the Integrated Environmental Management Guideline on Need and Desirability (General Notice 891 of 2014, as amended). This guideline outlines the legislative, strategic and statutory considerations for identifying and describing the need and desirability of proposed developments, which trigger NEMA listed activities. The need and desirability of a proposed development is described in terms of its ecological sustainability, socio-economic justifiability and overall contribution to sustainable development. The following considerations were taken into account in determining the need and desirability of the proposed telecommunication mast.

DEVELOPMENT PLANNING

The National Development Plan (NDP) represents a new approach by Government to promote sustainable and inclusive development in South Africa. The proposed telecommunications mast will contribute at least two of the NDP’s goals, namely to strengthen and optimise freight corridors, and maintain and expand telecommunications infrastructure.

The proposed development will not contravene the conditions of the Gauteng Spatial Development Framework (SDF), Tshwane Metropolitan Spatial Framework, the City of Tshwane Integrated Development Plan (IDP) 2019/2020 or the Gauteng Environmental Management Framework (EMF) adopted by the national, provincial and metropolitan government.

INFRASTRUCTURE DEVELOPMENT

The proposed telecommunication mast and associated infrastructure is required to improve communication between Train Drivers and Train Control Officers (TCO) along the railway lines. Telecommunications infrastructure is an essential supporting utility for the freight rail industry for coordinating cargo delivery and ensuring safety along the railway lines.

The Radio Communication Network is used by TFR for train movement and authorisation. There are 9 base station radios at Pyramid South that are used by Train Controlling Officers to communicate with Train Drivers. The antennas for these base station radios are currently mounted on a 15m pole. The over population of the pole with antennas has affected the quality of communication and has caused interference, as a result, the Train Controlling Officers are having difficulty to communicate with Train Drivers, which can lead to safety incidents arising from conflicting train movement between sections.

The solution is to erect a Telecommunications Tower and relocate the antennas on the Pole to the new Tower to allow an acceptable spacing between the antennas. Erecting a tower/mast would allow acceptable vertical separation of ≥ 4  (≥ 2.64 m) between the antennas and eliminate interference. The proposed telecommunication mast and associated infrastructure is required to improve radio communication along the railway line.

The proposed mast installation project aligns with TFR Telecoms’ objectives to improve service levels and efficiencies to ensure volume growth, to ensure rail capacity retention and to meet core telecommunication specifications in support of maintenance standards.

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ENVIRONMENTAL RIGHTS

The project will not affect the rights of the local community. The applicant and EAP have ensured community engagement during the Public Participation Process to ensure that the rights of the local community will not be affected.

ECOLOGICAL SUSTAINABILITY

Biodiversity, ecological integrity and site sensitivity were all assessed. Although the site falls within a threatened ecosystem (namely the endangered Marikana Thornveld) and within relatively close proximity (approximately 300m) to sensitive areas such as Ecological Support Areas and natural wetlands, any potential impacts to the overall biodiversity and ecological integrity of these areas will be low to negligible. This is because the site falls within an already highly-transformed area, surrounded by existing rail-related infrastructure.

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4 RELEVANT LEGISLATION

ENVIRONMENTAL AUTHORISATION IN SOUTH AFRICA

The regulation and protection of the environment within South Africa, occurs mainly through the application of various items of legislation, within the regulatory framework of the Constitution, 1996 (Act No. 108 of 1996).

The primary legislation regulating Environmental Impact Assessment (EIA) within South Africa is the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA). NEMA makes provision for the Minister of Environmental Affairs to identify activities which may not commence prior to authorisation from either the Minister or the provincial Member of the Executive Council (“the MEC”). In addition to this, NEMA also provides for the formulation of regulations in respect of such authorisations.

The EIA Regulations (2014) (as amended) allow for a Basic Assessment (BA) process for activities with limited environmental impact (listed in GN R 983 & 985, 2014, as amended) and a more rigorous two tiered approach to activities with potentially greater environmental impact (listed in GN R 984, 2014, as amended). This two-tiered approach includes both a Scoping and EIA process.

In terms of the EIA regulations of 2014 (as amended), the TFR telecommunications project requires Environmental Authorisation, from the Department of Environment, Forestry and Fisheries (DEFF), for the proposed mast. The triggered activities are listed under Listing Notices 3 only (published in Government Notices No. R 985), and as such, the BA Process needs to be followed.

The listed activities that have been applied for are provided in Table 4-1 below.

Table 4-1: Listed activities as described in GN R 985 (as amended) triggered by the proposed mast. Description of Activity project activity Listing Listed Activity Number that triggers listed activity The development of mast or towers of any material or type used for telecommunication broadcasting or radio transmission purposes where the mast or tower— The mast will be (a) Is to be placed on a site not previously used 35m in height, for this purpose; and thereby exceeding the 15m threshold, Listing 3 (b) Will exceed 15 metres in height 3(c) and falls within an GN R 985 c. Gauteng Endangered ecosystem v. Sites identified within threatened (Marikana ecosystems listed in terms of the National Thornveld) Environmental Management Act: Biodiversity Act (Act No. 10 of 2004);

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The competent authority that must consider and decide on the application for authorisation in respect of the activities listed in Table 4-1 is the National Department of Environment, Forestry and Fisheries (DEFF). DEFF is the Competent Authority mandated to process and approve all environmental authorisation applications submitted by State Owned Companies (SOC). The Transnet SOC Limited, a state owned company, is the applicant for this project. DEFF is required to provide a decision regarding the proposed project based on comments from provincial Departments. This decision has been made in terms of Section 24(C) (3) of the National Environmental Management Act, 1998 (Act No 107 of 1998).

It is important to note that in addition to the requirements for an authorisation in terms of NEMA, there may be additional legislative requirements which need to be considered prior to commencing with the activity, for example:  National Heritage Resources Act, 1999 (Act No. 25 of 1999)  Aviation Act, 1962 (Act No. 74 of 1962): 13th Amendment of the Civil Aviation Regulations (1997)  NEM: Biodiversity Act, 2004 (Act No. 10 of 2004)  National Water Act, (Act No. 36 of 1998).

APPLICABLE LEGISLATION

This section describes the South African (national), provincial and municipal legislation considered during the Basic Assessment process of the proposed development.

NATIONAL

The Constitution Act, 1996 (Act No. 108 of 1996)

This is the supreme law of the land. As a result, all laws, including those pertaining to the proposed development, must conform to the Constitution. The Bill of Rights - Chapter 2 of the Constitution, includes an environmental right (Section 24) according to which, “everyone has the right – (a) To an environment that is not harmful to their health or well-being; and (b) To have the environment protected for the benefit of present and future generations, through reasonable legislative and other measures that– (i) prevent pollution and ecological degradation. (ii) promote conservation; and (iii) secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.”.

RELEVANCE TO THE PROPOSED TELECOMMUNICATIONS MAST . The developer has an obligation to ensure that the proposed activity will not result in pollution and ecological degradation. . The developer has an obligation to ensure that the proposed activity is ecologically sustainable, while demonstrating economic and social development.

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National Environmental Management Act, 1998 (Act No. 107 of 1998)

The National Environmental Management Act, 1998 (Act No.107 of 1998) (NEMA) provides for the basis for environmental governance in South Africa by establishing principles and institutions for decision-making on matters affecting the environment.

A key aspect of NEMA is that it provides a set of environmental management principles that apply throughout the Republic to the actions of all organs of state that may significantly affect the environment. Section 2 of NEMA contains principles (see Table 4-1) relevant to the proposed mast, and likely to be utilised in the process of decision making by DEFF.

Table 4.2: NEMA Environmental Management Principles Number Description of Principles Environmental management must place people and their needs at the forefront of its (2) concern, and serve their physical, psychological, developmental, cultural and social interests equitably. (3) Development must be socially, environmentally and economically sustainable. Sustainable development requires the consideration of all relevant factors including the following: i. That the disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied; (4)(a) ii. That pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied; iii. That waste is avoided, or where it cannot be altogether avoided, minimised and re- used or recycled where possible and otherwise disposed of in a responsible manner. Responsibility for the environmental health and safety consequences of a policy, (4)(e) programme, project, product, process, service or activity exists throughout its life cycle. The social, economic and environmental impacts of activities, including disadvantages (4)(i) and benefits, must be considered, assessed and evaluated, and decisions must be appropriate in the light of such consideration and assessment. The right of workers to refuse work that is harmful to human health or the environment (4)(j) and to be informed of dangers must be respected and protected. The costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental (4)(p) damage or adverse health effects must be paid for by those responsible for harming the environment. Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal shores, estuaries, wetlands, and similar systems require specific attention in management and (4)(r) planning procedures, especially where they are subject to significant human resource usage and development pressure.

As these principles are utilised as a guideline by the competent authority in ensuring the protection of the environment, the proposed development should, where possible, be in accordance with these principles. Where this is not possible, deviation from these principles would have to be very strongly motivated.

NEMA introduces the duty of care concept, which is based on the policy of strict liability. This duty of care extends to the prevention, control and rehabilitation of significant pollution and environmental degradation. It also dictates a duty of care to address emergency incidents of pollution. A failure to perform this duty of care may lead to criminal prosecution and may lead to the prosecution of managers or directors of companies for the conduct of the legal persons.

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Employees who refuse to perform environmentally hazardous work, or whistle blowers, are protected in terms of NEMA.

In addition, NEMA introduces a new framework for environmental impact assessments, the EIA Regulations (2010), which aims to avoid detrimental environmental impacts through the regulation of specific activity that cannot commence without prior environmental authorisation (discussed in Section 4.1).

RELEVANCE TO THE PROPOSED TELECOMMUNICATIONS MAST . An application for Environmental Authorisation (as triggered by the EIA Regulations 2014 (as amended) will be required. In terms of Section 28, every person who causes, has caused, or may cause significant pollution or degradation of the environment, must take reasonable measures to prevent pollution or rectify the damage caused. The undertaking of various specialist studies, in order to identify potential impacts on the environment and to recommend mitigation measures to minimise these impacts, complies with Section 28 of NEMA. The developer must apply the NEMA principles, the fair decision-making and conflict management procedures that are provided for in NEMA. The developer must apply the principles of Integrated Environmental Management and consider, investigate and assess the potential impact of existing and planned activities on the environment, socio-economic conditions and the cultural heritage. . In terms of the EIA regulations, the construction of the proposed telecommunication mast and associated infrastructure will trigger the need for a Basic Assessment process under the NEMA EIA Regulations of 2014 (as amended) in Listing Notice 3 (refer to Section 4.1 for a detailed description of the listed activity applied for).

National Environment Management: Biodiversity Act, 2004 (Act No. 10 of 2004)

The National Environment Management: Biodiversity Act, 2004 (Act No. 10 of 2004) (NEMBA) provides for the management and conservation of South Africa’s biodiversity and the protection of species and ecosystems that warrant national protection.

The objectives of NEMBA are: (a) within the framework of the National Environmental Management Act, to provide for— (i) the management and conservation of biological diversity within the Republic and of the components of such biological diversity; (ii) the use of indigenous biological resources in a sustainable manner; and (iii) the fair and equitable sharing among stakeholders of benefits arising from bioprospecting involving indigenous biological resources; (b) to give effect to‘ ratified international agreements relating to biodiversity which are binding on the Republic; (c) to provide for co-operative governance in biodiversity management and conservation; and (d) to provide for a South African National Biodiversity Institute to assist in achieving the objectives of this Act.

The Act provides for the management and conservation of South Africa’s biodiversity within the framework of the NEMBA. In terms of the Biodiversity Act, the developer has a responsibility for:

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 The conservation of endangered ecosystems and restriction of activities according to the categorisation of the area (including The Endangered and Threatened Ecosystem Regulations, Government Notice R. 1002 dated 9th December 2011).  Application of appropriate environmental management tools in order to ensure integrated environmental management of activities thereby ensuring that all developments within the area are in line with ecological sustainable development and protection of biodiversity.  Limit further loss of biodiversity and conserve endangered ecosystems.

The Act’s permit system is further regulated in the Act’s Threatened or Protected Species Regulations Government Notice R. 152 of 23 February 2007.

RELEVANCE TO THE PROPOSED TELECOMMUNICATIONS MAST . The developer must not cause a threat to any endangered ecosystems and must protect and promote biodiversity; . The developer must assess the impacts of the proposed development on endangered ecosystems; . The developer may not remove or damage any protected species without a permit; and . The developer must ensure that the site is cleared of alien vegetation using appropriate means. . Alien Invasive Species (AIS) Regulations, Government Notice R. 598 of 1st April 2014 are applicable.

Telecommunications Act, 1966 (Act No. 103 of 1966)

Transnet has authority to operate its Private Telecommunication Network (PTN) in terms of Section 41(1)(c) of the Telecommunications Act.

National Environmental Management: Waste Management Act, 2008 (Act No. 59 of 2008)

The National Environmental Management: Waste Management Act, 2008 (Act No. 59 of 2008) (NEMWMA) gives legal effect to the Government’s policies and principles relating to waste management in South Africa, as reflected in the National Waste Management Strategy (NWMS). The objects of the Act are “to protect health, well-being and the environment by providing reasonable measures for— • minimising the consumption of natural resources; • avoiding and minimising the generation of waste; • reducing, re-using, recycling and recovering waste; • treating and safely disposing of waste as a last resort; • preventing pollution and ecological degradation; • securing ecologically sustainable development while promoting justifiable economic and social development; • promoting and ensuring the effective delivery of waste services; • remediating land where contamination presents, or may present, a significant risk of harm to health or the environment; and • achieving integrated waste management reporting and planning.”

RELEVANCE TO THE PROPOSED TELECOMMUNICATIONS MAST . The developer must ensure that all activities associated with the project address waste related matters in compliance with the requirements of the Act.

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. The developer must consult with the local municipalities to ensure that waste is disposed of at a registered landfill site.

Occupational Health and Safety Act, 1993 (Act No. 85 of 1993)

The objective of this Act is to provide for the health and safety of persons at work. In addition, the Act requires that, “as far as reasonably practicable, employers must ensure that their activities do not expose non-employees to health hazards”. The importance of the Act lies in its numerous regulations, many of which will be relevant to the proposed project. These cover, among other issues, noise and lighting.

RELEVANCE TO THE PROPOSED TELECOMMUNICATIONS MAST . The developer must be mindful of the principles and broad liability and implications contained in the OHSA and mitigate any potential impacts.

Aviation Act, 1962 (Act No. 74 of 1962): 13th Amendment of the Civil Aviation Regulations 1997

Any communications structure, building or other structure, whether temporary or permanent, which has the potential to endanger aviation in navigable airspace, or has the potential to interfere with the operation of navigation or surveillance systems or Instrument Landing Systems, including meteorological systems for aeronautical purposes, is considered an OBSTACLE and shall be submitted to the Commissioner for Civil Aviation for evaluation (refer SA-CAR Part 139.01.33)

Also applicable is Part 91.01.10 of the CAR of 1997 - endangering safety:

"No person shall, through any act or omission endanger the safety of an aircraft or person therein, or cause or permit an aircraft to endanger the safety of any person or property".

RELEVANCE TO THE PROPOSED TELECOMMUNICATIONS MAST . Due to requirements of the Act to ensure the safety of aircrafts, the developer must engage directly with the Civil Aviation Authority regarding the structural details of the facility. . The developer must ensure that aviation impacts are prevented by ensuring that the mast are clearly visible to air traffic. The mast will be equipped with navigations lights. The mast will not be located in close proximity to any runways that could affect safety of planes approaching/leaving a runway.

National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004)

The National Environmental Management: Air Quality Act (No. 39 of 2004)(NEMAQA) is the principal legislation regulating air quality in South Africa. The objects of the Act are to:  Give effect to section 24(b) of the Constitution in order to enhance the quality of ambient air for the sake of securing an environment that is not harmful to the health and well-being of people, and  Protect the environment by providing reasonable measures for: o Protection and enhancement of the quality of air in the Republic. o Prevention of air pollution and ecological degradation.

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 Securing ecologically sustainable development while promoting justifiable economic and social development.

The Air Quality Act empowers the Minister to establish a national framework for achieving the objects of this Act. The said national framework will bind all organs of state. The said national framework will inter alia have to establish national standards for municipalities to monitor ambient air quality and point, non-point and mobile emissions.

RELEVANCE TO THE PROPOSED TELECOMMUNICATIONS MAST . Although no major air quality issues are expected, the developer needs to be mindful of the Act as it also relates to potential dust generation during construction, etc.

National Water Act, 1998 (Act No. 36 of 1998)

The National Water Act (NWA) provides for fundamental reform of the law relating to water resources in South Africa.

The purpose of the Act is “to ensure that the nation's water resources are protected, used, developed, conserved, managed and controlled in ways which take into account amongst other factors– (a) meeting the basic human needs of present and future generations; (b) promoting equitable access to water; (c) redressing the results of past racial and gender discrimination; (d) promoting the efficient, sustainable and beneficial use of water in the public interest; (e) facilitating social and economic development; (f) providing for growing demand for water use; (g) protecting aquatic and associated ecosystems and their biological diversity; (h) reducing and preventing pollution and degradation of water resources; (i) meeting international obligations; (j) promoting dam safety; (k) managing floods and droughts.”

Section 21 of the NWA describes activities defined as a water use under the Act. These activities may only be undertaken subject to the application for, and issue of, a Water Use License (WUL) or General Authorisation (GA). Water use activities include— (a) taking water from a water resource; (b) storing water; (c) impeding or diverting the flow of water in a watercourse; (d) engaging in a stream flow reduction activity contemplated in section 36; (e) engaging in a controlled activity identified as such in section 37(1) or declared under section 38(1); (f) discharging waste or water containing waste into a water resource through a pipe, canal, sewer, sea outfall or other conduit; (g) disposing of waste in a manner which may detrimentally impact on a water resource; (h) disposing in any manner of water which contains waste from, or which has been heated in, any industrial or power generation process; (i) altering the bed, banks, course or characteristics of a watercourse; (j) removing, discharging or disposing of water found underground if it is necessary for the efficient continuation of an activity or for the safety of people; and

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(k) using water for recreational purposes.”

RELEVANCE TO THE PROPOSED TELECOMMUNICATIONS MAST . There may be certain instances where the developer may need to obtain approval in terms of the Water Act, e.g. the site falls within 500m of a wetland, which may trigger the need for a Section 21c and 21i GA or WUL.

National Road Traffic Act, 1996 (Act No. 93 of 1996)

The National Road Traffic Act (No. 93 of 1996) (NRTA) provides for all road traffic matters and is applied uniformly throughout South Africa. The Act enforces the necessity of registering and licensing motor vehicles. It also stipulates requirements regarding fitness of drivers and vehicles as well as making provision for the transportation of dangerous goods.

RELEVANCE TO THE PROPOSED TELECOMMUNICATIONS MAST . All the requirements stipulated in the NRTA will need to be complied with during the construction and operational phases of the proposed telecommunications mast.

Other Relevant National Legislation

Other legislation that may be relevant to the proposed telecommunication mast and associated infrastructure includes:  The Environment Conservation Act, 1989 (Act No. 73 of 1989)(ECA) Noise Control Regulations, which specifically provide for regulations to be made with regard to the control of noise, vibration and shock, including prevention, acceptable levels, powers of local authorities and related matters;  Provincial Nature and Environmental Conservation Ordinance, 1974 (Act No. 19 of 1974), which lists species of special concern which require permits for removal. Schedules 1 to 4 list protected and endangered plant and animal species.  Spatial Planning and Land Use Management Act, 2013 (Act No. 16 of 2013 – came into force on 1 July 2015) (SPLUMA) aims to provide inclusive, developmental, equitable and efficient spatial planning at the different spheres of the government. This act repeals national laws on the Removal of Restrictions Act, Physical Planning Act, Less Formal Township Planning Act and Development Facilitation Act.

PROVINCIAL

Gauteng Conservation Plan (C-Plan v3.3)

The Gauteng Conservation Plan (C-Plan) is a spatial tool that forms part of a broader set of national biodiversity planning tools and initiatives that are provided for in national legislation and policy. It comprises the Biodiversity Spatial Plan Map of biodiversity priority areas, accompanied by contextual information and land use guidelines that make the most recent and best quality biodiversity information available for use in land use and development planning, environmental assessment and regulation, and natural resource management. According to GDARD’s C-Plan Technical Report (2014):

“A systematic conservation plan for the Gauteng Province was undertaken by Gauteng Nature Conservation, a division within the Gauteng Department of Agriculture and Rural Development

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(GDARD). The Gauteng Conservation Plan Version 3.3 (Gauteng C-Plan v3.3) was released in February 2012. It was built on, and replaces CPlan Version 2.1 (2007).

Gauteng C-Plan v3.3 is based on the systematic conservation planning approach described by Margules & Pressey (2000). The key characteristics of a systematic conservation plan are representation, persistence, quantitative targets, and efficiency and conflict avoidance (DEAT, 2009).

The Gauteng C-Plan v3.3 delineates on a map, commonly known as a Critical Biodiversity Areas Map, biodiversity priority areas called Critical Biodiversity Areas, Ecological Support Areas and Protected Areas. The map is designed to be used at approximately 1:50 000 scale.

The Critical Biodiversity Areas are comprised of key areas that are required to meet national biodiversity pattern and process targets. Ecological Support Areas are areas required to prevent the degradation of Critical Biodiversity Areas and Protected Areas.”

RELEVANCE TO THE PROPOSED TELECOMMUNICATIONS MAST . The proposed development must be aligned with provincial spatial planning guidelines and targets. . The developer must not cause a threat to any endangered ecosystems and must protect and promote biodiversity. . The developer must assess the impacts of the proposed development on endangered ecosystems.

Gauteng Province Environmental Management Framework

The objective of the GPEMF is to guide sustainable land use management within the Gauteng Province. The GPEMF, inter alia, serve the following purposes:  To provide a strategic and overall framework for environmental management in Gauteng;  Align sustainable development initiatives with the environmental resources, developmental pressures, as well as the growth imperatives of Gauteng;  Determine geographical areas where certain activities can be excluded from an EIA process; and  Identify appropriate, inappropriate and conditionally compatible activities in various Environmental Management Zones in a manner that promotes proactive decision- making.

RELEVANCE TO THE PROPOSED TELECOMMUNICATIONS MAST . The proposed development must be aligned with provincial spatial planning guidelines and targets.

OTHER

In addition to the above, aside from the environmental authorisation, there are other permits, contracts and licenses that will need to be obtained by the project proponent for the proposed project some of which fall outside the scope of the EIA. However, for the purposes of completeness, these include:

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 Gauteng Spatial Development Framework  Tshwane Metropolitan Spatial Framework  City of Tshwane By-Laws  City of Tshwane Integrated Development Plan 2019/2020

In addition to the above, the following spatial tools from the South African National Biodiversity Institute (SANBI) need to be taken into consideration:  The South African Vegetation Map (Mucina and Rutherford);  The Gauteng C-Plan; and  The National Freshwater Ecosystem Priority Areas (NFEPA) project.

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5 DESCRIPTION OF THE AFFECTED ENVIRONMENT

This chapter provides a description of the affected environment within the vicinity of the proposed telecommunications mast. This information is provided to assist the reader in understanding the possible effects of the project on the environment within which it is proposed to be developed. This information has been sourced from existing information available for the area as well as the specialist consultants who have undertaken studies for the proposed development. This chapter aims to provide the context within which this BA is being conducted.

BIOPHYSICAL ENVIRONMENT

CLIMATE

Pyramid South is located approximately 20km north of the Pretoria CBD. The climate in Pretoria is characteristically warm and temperate, with a predominantly summer rainfall. According to the Köppen-Geiger climate classification system, Pretoria is categorised as a Cwa zone (Climate-Data.Org, 2019), which includes humid to mild subtropical climates. The average annual temperature in Pretoria is 17.8°C, with July being the coldest month and January being the hottest month, averaging at 11°C and 22.4°C, respectively. An average of 697mm precipitation falls annually, with the least amount of rainfall experienced in June and the most in January (6mm and 128mm, respectively) (Climate-Data.Org, 2019). The climate graph below summarises the monthly average temperature and precipitation for the area (Figure 5-1).

Figure 5-1: Climate graph for Pretoria (Climate-Data.Org, 2019).

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TOPOGRAPHY

The Pyramid South site lies at an altitude of 1 195m above sea level (masl). The immediate surroundings (within the 500m buffer) are mostly flat, with slight southward sloping, ranging from 1 198-1 205masl from north to south (Figure 5-2). The broader surroundings are predominantly flat towards the north, with koppies to the south (Figure 5-3).

Figure 5-2: Elevation profile from north to south (top) and west to east (bottom) within 500m of the proposed Pyramid South mast site.

GEOLOGY

The geology of the proposed mast site is comprised of the Bierkraal Magnetite Gabbro (Figure 5-4), forming part of the Upper Zone and Rustenburg Sub-Facies of the Western Lobe of the Rustenburg Layered Suited, itself forming part of the Bushveld Complex and Transvaal Supergroup (Viring & Cowell, 1999). The Rustenburg Layered Suite consists primarily of mafic rock, with the Upper Zone containing a mixture of Gabbro, Anorthosite and Magnetite rock types, comprised of the various minerals, namely Olivine, Clinopyroxene, Plagioclase, Magnetite and Apatite (McCarthy & Rubidge, 2005). According to the South African Heritage Resources Information System (SAHRIS), the Bierkraal Magnetite Gabbro is of insignificant or zero paleontological sensitivity. Additionally, considering the very small area covered by the mast, as well as the fact that the mast will be located within the existing fenced CTC area, it is unlikely that the proposed mast will significantly impact on the underlying geology of the area.

WATERCOURSES

The project site falls within the Apies River / Pienaars River sub-management area of the Crocodile (West) and Marico Water Management Area (WMA), which includes the Apies, Pienaar, Moretele and Tlholwe Rivers and their tributaries. The Apies River is located approximately six kilometers west of the site, while the Pienaars River is located about 10km east of the site. The Bon Accord Dam is located approximately 6km south-west of the proposed mast site. The landscape is also populated with numerous scattered wetlands, including a channeled valley-bottom wetland, located approximately 320m north-west of the proposed mast site (Figure 5-5).

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Figure 5-3: Topographical map of the surrounding area at the Pyramid South site.

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Figure 5-4: Geological Profile of the Pyramid South site and surrounding area.

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Figure 5-5: Hydrological map of the area surrounding the proposed Pyramid South mast site.

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SOILS

The soil at the Pyramid South site is categorised as an “A4” type according to the Soil and Terrain (SOTER) Soil Association map (Figure 5-6), described as “Red, massive or weakly structured soils with high base status (association of well drained Lixisols, Cambisols, Luvisols)”. The following soil types are found within the broader landscape:  D1 (located approximately 700m west of the proposed site) – Black and red, strongly structured clayey soils with high base status (association of Vertisols, Phaoezems, Kastanozems and Nitisols. In addition one or more Leptosols, Calcisols and Cambisols may be present).  E1 (located approximately 2.5km north of the proposed site) – Soils with minimal development, usually shallow on hard or weathering rock, with or without intermittent diverse soils (association of Leptosols, Regosols, Calcisols and Durisols. In addition one or more of Cambisols and Luvisols may also be present).  G1 (located approximately 8.5km south of the proposed site) – Rock with limited soils (association of Leptosols, Regosols, Durisols, Calcisols and Plinthosols).

VEGETATION AND FLORISTICS

National Vegetation Map (Mucina & Rutherford 2018)

The Pyramid South Site falls within the Marikana Thornveld vegetation type, which expands from Rustenburg in the west, to Marikana and Brits in the north, to Pretoria in the east, ranging in altitude from 1050m – 1450m above mean sea level (Mucina & Rutherford, 2018). The landscape within this vegetation type is dominated by open Vachellia karroo woodland, in valleys separated by slightly undulating plains, and some lowland hills. The composition of shrubs increase where regions are more protected from fire (Mucina & Rutherford, 2018). This vegetation type is regarded as Endangered (EN), with only 1% of the 19% conservation target currently being statutorily conserved, in reserves such as the Magaliesberg Nature Area and De Onderstepoort Nature Reserve. This vegetation type has been considerably impacted, with 48% being transformed predominantly via cultivation, urban or built up areas. Nearer Pretoria, industrial development is the greatest threat of land transformation, with agriculture being the dominant threat in the more rural regions where this vegetation type occurs. Erosion potential within this vegetation type is low to moderate, with localised, high densities of invasive species, in particular along drainage lines (Mucina & Rutherford, 2018). The national vegetation map (Mucina & Rutherford 2018) for the project site is provided below in Figure 5-7.

Critical Biodiversity Areas and broad-scale processes

The Gauteng Conservation Plan (C-Plan) is based on the systematic conservation protocols based on principles developed by Margules & Pressey (2000). This plan must be treated as a living document with periodic review and updates as the knowledge of the distribution of biodiversity, the status of species, approaches for dealing with aspects such as climate change, methods of data analysis, and the nature of threats to biodiversity within a planning region are constantly changing, especially in the Gauteng province, which is developing at an extremely rapid rate. The main purposes of the C-Plan are:  To serve as the primary decision support tool for the biodiversity component of the Environmental Impact Assessment (EIA) process;

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 To inform protected area expansion and biodiversity stewardship programmes in the province;  To serve as a basis for development of Bioregional Plans in municipalities within the province.

The Gauteng C-Plan forms part of the environmental authorization process in that if the proposed project is located within a CBA, Listing Notice 3 (GN No. R. 985, as amended) activities are triggered. This requires the submission of a copy of the Basic Assessment Report to the Biodiversity Sub-Directorate.

The Gauteng C-Plan was utilised to indicate any sensitive surrounding environments and the level of protection of these. The proposed mast installation site does not fall within a CBA (Figure 5-8).

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Figure 5-6: SOTER Soil Association map of the proposed Pyramid South site and surroundings.

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Figure 5-7: Mucina & Rutherford Vegetation Map of the proposed mast site at Pyramid South.

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Figure 5-8: Gauteng Conservation Plan map of the proposed site at Pyramid South.

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FAUNA

Amphibians

Approximately 30 species of amphibian are known to occur in Gauteng (ADU, 2019), of which 28 species have a distribution which coincides with the project site (IUCN, 2019). Approximately 15 of these have been recorded within a 30km2 area (QDS 2528CA) within which the project area is located (ADU, 2019). This includes one near threatened species, namely the Giant Bull Frog, Pyxichephalus adspersus. However, it is unlikely that this species will be found on site due to the lack of suitable habitat.

Reptiles

Approximately 90 species of reptile are known to occur in Gauteng (ADU, 2019), of which 46 species have a distribution which coincides with the project site (IUCN, 2019). Approximately 15 of these have been recorded within a 30km2 area (QDS 2528CA) within which the project area is located (ADU, 2019). All of these species are of least conservational concern in terms of the IUCN Red List (ADU, 2019; IUCN, 2019).

Mammals

Approximately 160 species of mammal are known to occur in Gauteng (ADU, 2019), of which 123 species have a distribution which coincides with the project site (IUCN, 2019). Approximately 31 of these have been recorded within a 30km2 area (QDS 2528CA) within which the project area is located (ADU, 2019). This includes one endangered species (the African Wild Dog) and three near threatened species (the Rusty Pipistrelle, the Brown Hyena and the Serval). However, it is unlikely that these species will be found on site due to the lack of suitable habitat.

Avifauna

The Important Bird and Biodiversity Areas (IBA) is a conservation programme which speaks to all four focal areas including species, sites, habitat and people. The IBA Programme aims to conserve a network of sites considered to be critical for the long-term survival of bird species that are globally threatened, have a restricted range and/or are restricted in terms of specific biomes or vegetation types.

The Magaliesburg IBA The Pyramid South project site is situated approximately 8.5km north of the eastern-most reaches of the Magaliesburg IBA (Figure 5-9), which extends for approximately 120km westwards, covering an area of 363 890ha. The Magaliesburg IBA is characterised by hilly terrain and rocky ridges. The area is partially protected. Bird Life SA (2019) identified the expansion of commercial, recreational and housing developments as one of the major threats to birds in this region. According to Bird Life SA (2019), the region has the following birding characteristics:

"Cape Vulture Gyps coprotheres breeds at Nooitgedacht and at Skeerpoort, the larger of the two colonies. No breeding activity was recorded at a third colony, Roberts' Farm, in 2014.

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Many raptor species occur in the Magaliesberg IBA, including White-backed Vulture Gyps africanus and Lappet-faced Vulture Torgos tracheliotus, although most records are of individuals. Verreauxs' Eagle Aquila verreauxii breeds in the Magaliesberg, and African Grass Owl Tyto capensis and Secretarybird Sagittarius serpentarius are regularly recorded. Long-crested Eagle Lophaetus occipitalis is a more recent coloniser of the range. White-bellied Korhaan Eupodotis senegalensis is found in grassland at the top of the Magaliesberg, as well on the Witwatersberg.

One pair of Black Stork Ciconia nigra also breeds at Skeerpoort, and there is a possibility that more birds occur in the area. The densely wooded valleys along overgrown, slow-flowing streams hold Half- collared Kingfisher Alcedo semitorquata. African Finfoot Podica senegalensis is recorded regularly along rivers in the IBA, such as the Hennops and Magalies.

The surrounding woodland holds Striped Kingfisher Halcyon chelicuti, Burnt-necked Eremomela Eremomela usticollis, Barred Wren-Warbler Calamonastes fasciolatus, Marico Flycatcher Bradornis mariquensis, Crimson-breasted Shrike Laniarius atrococcineus, Scaly-feathered Finch Sporopipes squamifrons, Violet-eared Waxbill Uraeginthus granatinus, Black-faced Waxbill Estrilda erythronotos, Striped Pipit Anthus lineiventris and Short-toed Rock Thrush Monticola brevipes.

Some Afromontane affinities appear along the range and there are patches of Northern Afro-temperate forest in the kloofs, where Mountain Wagtail Motacilla clara has been recorded.

The most important trigger species in the IBA is the globally threatened Cape Vulture. The number of breeding pairs in the Skeerpoort colony seems to be stable at 200–250. Secretarybird is the other globally threatened species in the IBA. Regionally threatened species are Lanner Falcon Falco biarmicus, Half-collared Kingfisher, African Grass Owl, African Finfoot and Verreauxs' Eagle. Biome- restricted species include White-bellied Sunbird Cinnyris talatala, Kurrichane Thrush Turdus libonyanus, White-throated Robin-chat Cossypha humeralis, Kalahari Scrub Robin Erythropygia paena and Barred Wren-Warbler."

LAND USE AND COVER

The mast will be constructed in an area where existing freight rail-related infrastructure has been installed, namely within the CTC area at Pyramid South. The surrounding landscape is comprised of various land uses, ranging from mostly cultivation and urban smallholdings in the north, to bush and urban residential land use in the south, bush and urban smallholdings in the east, and a mixture of cultivation, bush and urban smallholdings in the west (Figure 5-10).

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Figure 5-9: Important Birding Areas (IBA) and protected areas located near the proposed site at Pyramid South.

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Figure 5-10: Land use and cover surrounding the proposed mast site at Pyramid South

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SOCIO-ECONOMIC PROFILE

The Pyramid South project site is located within a primarily rural area, 20km north of Pretoria CBD and more than 3km from the closest urban residential area, located to the south. The Pyramid South falls within Ward 49 of the City of Tshwane Metropolitan Municipality, a Category-A municipality. Tshwane is one of three Metropolitan Municipalities that make up the Gauteng Province.

POPULATION

The City of Tshwane Metropolitan Municipality had a total population of 2 921 488 in 2011 (Statistics South Africa, 2011). The population is roughly balanced with 50.25% of the population being female and males comprising 49.75%. Three-quarters of the population in Tshwane is black African (75.4%), followed by 20.08% being white, 2.01% coloured, 1.84% Indian or Asian and 0.67% other. The age distribution revealed that the youth make up the highest population component with the highest concentrations occurring between 20-34 years.

ECONOMY

The total gross domestic product for the City of Tshwane in 2017 was R313 billion, contributing to over a quarter (28.4%) of Gauteng’s economy and a tenth of South Africa’s economy (City of Tshwane, 2019). The project site falls within the Pyramid Freight Hub, which, along with the automotive cluster and Wonderboom Airport, forms a significant economic node in the north of the municipality (City of Tshwane, 2019). Freight transportation and farming are the primary economic activities for the area surrounding the site.

EMPLOYMENT, EDUCATION, INCOME AND POVERTY

Approximately 51% of the working age population in Tshwane are employed, 17% are unemployed, 3% are discouraged work seekers and 29% are not economically active (Statistics South Africa, 2011). A third of the population in Tshwane have had at least some primary schooling, nearly a third (29.2%) have had some secondary schooling and a fifth have completed secondary schooling, with 6.2% having received tertiary education (Statistics South Africa, 2011). The median household income in Tshwane is around R57 300 per year, but vary greatly amongst population groups (Statistics South Africa, 2011). Approximately a quarter of the population in Tshwane has been classified as living in poverty (Statistics South Africa, 2011).

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6 PUBLIC PARTICIPATION PROCESS

Public consultation is a legal requirement throughout the EIA process. Developers are required to conduct public consultation throughout the Basic Assessment process. Formal EIA documents are required to be made available for public review, which include the project brief, Draft and Final BARs, and the decision of the Competent Authority.

According to Regulation 41(2) of the NEMA EIA Regulations 2014 (as amended 2017) “The person conducting a public participation process must take into account any relevant guidelines applicable to public participation as contemplated in section 24J of the Act”. These guidelines include:  The 2012 Public Participation Guidelines (General Notice 807 of 2012), which provides information and guidance for applicants, I&APs and EAPS on the public participation requirements of the BA process; and  The Promotion of Access to Information Act (PAIA), 2000 (Act No. 2 of 2000), which allows citizens access to any information held by the State, and any information held by private bodies that is required for the exercise and protection of any rights.

NOTIFICATION TO POTENTIAL I&APS

According to Regulation 41(2) of the NEMA EIA Regulations 2014 (as amended 2017) “The person conducting a public participation process . . . must give notice to all potential interested and affected parties of an application or proposed application which is subjected to public participation by—

SITE NOTICES AND POSTERS

(a) fixing a notice board at a place conspicuous to and accessible by the public at the boundary, on the fence or along the corridor of— (i) the site where the activity to which the application or proposed application relates is or is to be undertaken; and (ii) any alternative site.

During the initial site visit, a site notice was placed at the entrance to the proposed mast site, at the junction between the main tarred road and the access road to the TFR CTC area (see Appendix D1 for proof of placement). The site notice was placed at the following coordinates: 25˚ 36.577’ S, 28˚ 12.979’ E.

I&AP AND STAKEHOLDER NOTIFICATIONS

(b) giving written notice, in any of the manners provided for in section 47 D of the Act, to— (i) the occupiers of the site and, if the proponent or applicant is not the owner or person in control of the site on which the activity is to be undertaken, and to any alternative site where the activity is to be undertaken; (ii) owners, persons in control of, and occupiers of land adjacent to the site where the activity is or is to be undertaken and to any alternative site where the activity is to be undertaken;

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(iii) the municipal councillor of the ward in which the site and alternative site is situated and any organisation of ratepayers that represent the community in the area; (iv) the municipality which has jurisdiction in the area; (v) any organ of state having jurisdiction in respect of any aspect of the activity; and (vi) any other party as required by the competent authority;

Formal inception notifications were sent out via email and postal mail on the 7th of November 2019 (all notification proofs are provided in Appendix D3). All I&APs were notified of the availability of the Draft BAR for public review by means of email and registered mail sent out on the 17th of August 2020 (all notification proofs are provided in Appendix D3).

NEWSPAPER ADVERTISEMENT

(c) placing an advertisement in— (i) one local newspaper; or (ii) any official Gazette that is published specifically for the purpose of providing public notice of applications or other submissions made in terms of these Regulations; (d) placing an advertisement in at least one provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the boundaries of the metropolitan or district municipality in which it is or will be undertaken: Provided that this paragraph need not be complied with if an advertisement has been placed in an official Gazette referred to in paragraph (c)(ii);

A newspaper advertisement was placed in the Rekord (Northern Region), in order to notify the general public of the proposed development and availability of the Draft BAR for public review. Proof of placement is provided in Appendix D5.

REGISTER OF STAKEHOLDERS AND I&APS

According to Regulation 42 of the NEMA EIA Regulations 2014 (as amended 2017) “A proponent or applicant must ensure the opening and maintenance of a register of interested and affected parties and submit such a register to the competent authority, which register must contain the names, contact details and addresses of—

(a) all persons who, as a consequence of the public participation process conducted in respect of that application, have submitted written comments or attended meetings with the proponent, applicant or EAP; (b) all persons who have requested the proponent or applicant, in writing, for their names to be placed on the register; and (c) all organs of state which have jurisdiction in respect of the activity to which the application relates.

A comprehensive I&AP register was compiled and is included in Appendix D2. This register included the following parties, among others:  Immediate neighbours, as well as landowners within a radius of 500m to the proposed development were notified;  The Department of Environment, Forestry and Fisheries (DEFF); including the following units: o Biodiversity Planning and Conservation;

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o Protected Areas Systems Management; o National Wildlife Information Management; and o Biodiversity Specialist Monitoring and Services  City of Tshwane Metropolitan Municipality, including the Municipal Ward councillor;  Eskom;  SANBI;  Gauteng Department of Agriculture and Rural Development (GDARD);  Department of Mineral Resources (DMR);  Gauteng Department of Roads and Transport;  Gauteng Provincial Heritage Resources Authority (PHRA); and  Department of Water and Sanitation (DWS).

PUBLIC REVIEW OF DRAFT BAR

The Draft BAR was subject to a 30-day public review period from 20 August 2020 to 20 September 2020. The Draft BAR was made available electronically on the CES website. Letters of notification were emailed and/or posted to the registered I&APs, notifying them of the commencement of the public review period and the availability of the Draft BAR (including the link to the CES website), as well as providing the contact details (telephone and email) of the EAP Additionally, I&APs were provided the option of receiving a hardcopy version of the executive summary of the Draft BAR via registered post, upon request, in cases where they were unable to access the electronic version. It is assumed that all I&APs could access the Draft BAR electronically as none had requested a hardcopy by the end of the public review period.

I&APs were invited to provide comment on the Draft BAR via a number of contact options, namely telephone, post, fax and/or email. The medium of correspondence is noted in the I&APs register (Appendix D2).

ISSUES RAISED BY I&APS

44 (1) The applicant must ensure that the comments of interested and affected parties are recorded in reports and plans, and that such written comments, including responses, are attached to the reports and plans that are submitted to the competent authority in terms of these regulations.

Other than the comments provided by the DEFF case officer, no other comments or issues were raised by I&APs regarding the Civil Works for the Radio High Telecommunication mast and associated infrastructure. The Issues and Response Trail (IRT) has been attached in Appendix D6.

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7 ALTERNATIVES

Alternatives should include consideration of all possible means by which the purpose and need of the proposed activity could be accomplished. In all cases, the no-go alternative must be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. The determination of whether site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment.

“Alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to— (a) The property on which or location where it is proposed to undertake the activity. (b) The type of activity to be undertaken. (c) The design or layout of the activity. (d) The technology to be used in the activity. (e) The operational aspects of the activity. (f) The option of not implementing the activity.

FUNDAMENTAL, INCREMENTAL AND NO-GO ALTERNATIVES

FUNDAMENTAL ALTERNATIVES

Fundamental alternatives are developments that are totally different from the proposed project description and usually include the following:  Alternative property or location where it is proposed to undertake the activity.  Alternative type of activity to be undertaken.  Alternative technology to be used in the activity.

INCREMENTAL ALTERNATIVES

Incremental alternatives relate to modifications or variations to the design of a project that provide different options to reduce or minimise environmental impacts. There are several incremental alternatives that can be considered with respect to the current telecommunications project, including:  Alternative design or layout of the activity.  Alternative operational aspects of the activity.

NO-GO ALTERNATIVE

It is mandatory to consider the “no-go” option in the BA process. The “no-go” alternative refers to the current status quo and the risks and impacts associated with it. Some existing activities may carry risks and may be undesirable (e.g. an existing contaminated site earmarked for a development). The no-go is the continuation of the existing land use, i.e. maintain the status quo.

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ALTERNATIVES CONSIDERED

LOCATION ALTERNATIVES

Only one location has been assessed. Alternative locations for the current project are not being considered as the proposed telecommunication mast is required at this location. Communication channels along this freight rail route requires upgrading and the installation of telecommunication mast at this site is critical to the overall feasibility of the project.

ACTIVITY ALTERNATIVES

The proposed site is currently being used by TFR as the CTC area for freight rail-related purposes. Alternative activities for the current project are not being considered as the purpose of the proposed mast is to improve the communication channels along the existing freight railways in this area.

TECHNOLOGY ALTERNATIVES

Three technology alternatives were considered for the proposed telecommunications project, namely:  Global System for Mobile communication (GSM) Technology – GSM describes second-generation (2G) digital cellular networks. This technology was deemed inappropriate for the proposed project because Pyramid South is located at a relatively remote location with limited GSM coverage.  Satellite Technology – This alternative requires the launching of a satellite into orbit. This alternative was deemed too costly and inappropriate because there is no prospect of maintenance or repair of the satellite in the event that it goes faulty.  Ultra-High Frequency (UHF) Technology (Preferred Alternative) – This technology uses radio links and is the preferred alternative because TFR is licenced to operate radio equipment on the frequency band approved by the Independent Communications Authority of South Africa (ICASA).

LAYOUT ALTERNATIVES

This relates mostly to alternative ways in which the proposed development or activity can be physically laid out on the ground to minimise or reduce environmental risks or impacts. The proposed layout in Figure 2-3 is the only layout alternative being considered.

NO-GO ALTERNATIVE

The No-Go alternative in the context of this project implies that the telecommunication mast would not be constructed and the current land use, namely the use as freight rail CTC area, would persist. If the project does not proceed the negative impacts such as risk of collisions of birds would be avoided. However, it would also mean that the project would not provide the required telecommunications upgrade for the surrounding freight railway lines, resulting in significant safety concerns.

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EVALUATION OF ALTERNATIVES

According to NEMA, the evaluation of alternatives is determined “through a detailed site selection process, which includes an identification of impacts and risks inclusive of identification of cumulative impacts and a ranking process of all the identified alternatives focusing on the geographical, physical, biological, social, economic, and cultural aspects of the environment.” This process was not applied at the outset due to the limited anticipated impact of the preferred alternative. Rather, the alternatives for the proposed development were identified in response to the need and desirability for the installation of the mast, namely to improve communication along the rail network. The proposed alternatives were evaluated based on their advantages and disadvantages, as well as their feasibility and reasonability in meeting this need. Only feasible and reasonable alternatives were further evaluated in the impact assessment. Site selection was informed by the positioning of the rail network, as well as the richness of the Ultra-High Frequency (UHF) spectrum.

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Table 7-1: Analysis of the proposed alternatives for the TFR Telecommunication mast and associated infrastructure. Reasonable Further Alternative level Alternatives Advantages Disadvantages Comment and feasible assessment Property or Preferred Site  Located in an area  Some visual intrusion. location already used by applicant (TFR) for telecommunications and/or freight rail purposes.  Located within secure, fenced CTC area.  Close proximity to key YES YES railway lines.  Close proximity to and easy accessibility from the main road.  Reduced visual intrusion due to existing surrounding railway infrastructure. Activity Preferred Activity  The proposed mast will  Visually intrusive. improve and complement the existing YES YES freight rail-related.

Technology Preferred  Relatively small footprint  Visually intrusive. The preferred option Technology – UHF and lower environmental using UHF radio high impact. mast is the most cost-  Broad transmission effective and feasible, range. least intrusive, and  Faster construction easier to maintain time. YES YES options.  Lower construction, operation and maintenance costs.  TFR is licenced to operate radio equipment on the frequency band

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Reasonable Further Alternative level Alternatives Advantages Disadvantages Comment and feasible assessment approved by the Independent Communications Authority of South Africa (ICASA). Alternative  Pyramid South is located at technology – GSM a relatively remote location NO NO with limited GSM coverage Alternative  Costly technology –  No prospect of Satellite maintenance or repair of NO NO the satellite in the event that it goes faulty Design or layout Preferred Design  Relatively small  Visually intrusive. and Layout footprint of the mast. YES YES  Structurally stable. No-go option Site alternative  The environment will  No improvement of No adverse remains in its existing remain relatively telecommunications environmental impacts condition. undisturbed. infrastructure. are foreseen for the no- YES NO  No temporary and go option. No further permanent job assessment deemed opportunities. necessary.

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8 IMPACT ASSESSMENT METHODOLOGY

AIMS OF ENVIRONMENTAL IMPACT ASSESSMENT

The aim of Basic Assessments and Environmental Impact Assessments is determine the consequences of proposed developments on the environments to better inform decision- making and the management of natural and social systems. This BA sought to assess the potential environmental impacts of the proposed installation of a telecommunications mast at Pyramid South, Gauteng.

IMPACT ASSESSMENT CRITERIA

CES has developed evaluation criteria for assessing impacts in accordance with the requirements outlined in Appendix 2 of the EIA Regulations (2014, as amended). This scale takes into consideration the following variables:  Nature: negative or positive impact on the environment.  Type: direct, indirect and/or cumulative effect of impact on the environment.  Significance: The criteria in Table 8-1 are used to determine the overall significance of an activity. The impact effect (which includes duration; extent; consequence and probability) and the reversibility/mitigation of the impact are then read off the significance matrix in order to determine the overall significance of the issue. The overall significance is either negative or positive and will be classified as low, moderate or high (Table 8-2).  Consequence: the consequence scale is used in order to objectively evaluate how severe a number of negative impacts might be on the issue under consideration, or how beneficial a number of positive impacts might be on the issue under consideration.  Extent: the spatial scale defines the physical extent of the impact.  Duration: the temporal scale defines the significance of the impact at various time scales, as an indication of the duration of the impact.  Probability: the likelihood of impacts taking place as a result of project actions arising from the various alternatives. There is no doubt that some impacts would occur (e.g. loss of vegetation), but other impacts are not as likely to occur (e.g. vehicle accident), and may or may not result from the proposed development and alternatives. Although some impacts may have a severe effect, the likelihood of them occurring may affect their overall significance.  Reversibility: The degree to which an environment can be returned to its original/partially original state.  Irreplaceable loss: The degree of loss which an impact may cause.  Mitigation potential: The degree of difficulty of reversing and/or mitigating the various impacts ranges from very difficult to easily achievable. The four categories used are listed and explained in Table 8-1 below. Both the practical feasibility of the measure, the potential cost and the potential effectiveness is taken into consideration when determining the appropriate degree of difficulty.

Table 8-1: Ranking of Evaluation Criteria Nature Positive Beneficial/positive impact. Negative Detrimental/negative impact. Type Direct Direct interaction of an activity with the environment.

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Impacts on the environment that are not a direct result of the project or Indirect activity. Cumulative Impacts which may result from a combination of impacts of this project and similar related projects. Duration Short term Less than 5 years. Medium term Between 5-20 years. Long term More than 20 years. Permanent Over 40 years or resulting in a permanent and lasting change that will always be there.

Extent Localised Impacts affect a small area of a few hectares in extent. Often only a portion of the project area. Study area The proposed site and its immediate environments. Municipal Impacts affect the municipality, or any towns within the municipality. Regional Impacts affect the wider district municipality or the Eastern Cape Province as a whole. National Impacts affect the entire country. International/Global Impacts affect other countries or have a global influence. Consequence Slight Slight impacts or benefits on the affected system(s) or party(ies). Moderate Moderate impacts or benefits on the affected system(s) or party(ies). Severe/ Severe impacts or benefits on the affected system(s) or party(ies). Beneficial Probability Definite More than 90% sure of a particular fact. Should have substantial supportive data. Probable Over 70% sure of a particular fact, or of the likelihood of that impact occurring. Possible Only over 40% sure of a particular fact, or of the likelihood of an impact occurring. Unsure Less than 40% sure of a particular fact, or of the likelihood of an impact occurring. Reversibility Reversible The activity will lead to an impact that can be reversed provided appropriate mitigation measures are implemented. Irreversible The activity will lead to an impact that is permanent regardless of the implementation of mitigation measures. Irreplaceable loss Resource will not be The resource will not be lost/destroyed provided mitigation measures are lost implemented. Resource will be The resource will be partially destroyed even though mitigation measures partly lost are implemented. Resource will be The resource will be lost despite the implementation of mitigation lost measures. Mitigation potential The impact can be easily, effectively and cost effectively Easily achievable mitigated/reversed. The impact can be effectively mitigated/reversed without much difficulty or Achievable cost. The impact could be mitigated/reversed but there will be some difficultly in Difficult ensuring effectiveness and/or implementation, and significant costs.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 47

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The impact could be mitigated/reversed but it would be very difficult to Very Difficult ensure effectiveness, technically very challenging and financially very costly.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 48

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Table 8-2: Description of significance ratings Significance Description Rating The impacts on this issue are acceptable and mitigation, whilst desirable, is not essential. The impacts on the issue by themselves LOW LOW are insufficient, even in combination with other low impacts, to NEGATIVE POSITIVE prevent the development being approved. Impacts on this particular issue will result in either positive or negative medium to short term effects on the social and/or natural environment. The impacts on this issue are important and require mitigation. The impacts on this issue are, by themselves, insufficient to prevent the implementation of the project, but could in conjunction with other MODERATE MODERATE issues with moderate impacts, prevent its implementation. Impacts NEGATIVE POSITIVE on this particular issue will usually result in either a positive or negative medium to long-term effect on the social and/or natural environment. The impacts on this issue are serious, and if not mitigated, they may prevent the implementation of the project (if it is a negative impact). HIGH HIGH Impacts on this particular issue would be considered by society as NEGATIVE POSITIVE constituting a major and usually a long-term change to the (natural and/or social) environment, and will result in severe effects or if positive, substantial beneficial effects.

ASSESSMENT OF CUMULATIVE IMPACTS

In terms of the NEMA EIA Regulations (2014), a cumulative impact is defined as: “The past, current and reasonably foreseeable future impact of an activity, considered together with the impact of activities associated with that activity that in itself may not be significant, but may become significant when added to the existing and reasonably foreseeable impacts eventuating from similar or diverse activities”.

Project induced cumulative impacts should be considered, along with direct and indirect impacts, in order to better inform the developer’s decision making and project development process. Cumulative impacts may be categorised into one or more of the following types:

 Additive: the simple sum of all the effects (e.g. the accumulation of ground water pollution from various developments over time leading to a decrease in the economic potential of the resource);  Synergistic: effects interact to produce a total effect greater than the sum of individual effects. These effects often happen as habitats or resources approach capacity (e.g. the accumulation of water, air and land degradation over time leading to a decrease in the economic potential of an area);  Time crowding: frequent, repetitive impacts on a particular resource at the same time (e.g. multiple boreholes decreasing the value of water resources);  Neutralizing: where effects may counteract each other to reduce the overall effect (e.g. infilling of a wetland for road construction, and creation of new wetlands for water treatment); and,  Space crowding: high spatial density of impacts on an ecosystem (e.g. rapid informal residential settlement).”

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 49

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Cumulative impacts are, however, difficult to accurately and confidently assess, owing to the high degree of uncertainty, as well as their often being based on assumptions. It is therefore difficult to provide as detailed an assessment of cumulative impacts as is the case for direct and indirect project induced impacts. This is usually because of the absence of specific details and information related to cumulative impacts. In these situations, the EAP will need to ensure that any assumptions made as part of the assessment are made clear. Accordingly, this includes an overview and analysis of cumulative impacts related to a variety of project actions, and does not provide a significance rating for these impacts, as was done for direct project induced impacts. The objective is to identify and focus on potentially significant cumulative impacts so these may be taken into consideration in the decision-making process. It is important to realise these constraints, and to recognise that the assessment will not, and indeed cannot, be perfect. The potential for cumulative impacts will, however, be considered, rather than omitted from the decision making-process and is therefore of value to the project and the environment.

TECHNICAL SCOPE

The technical scope (Table 8-3) maps out at a high level the categories or types of impacts that are expected under various themes for all phases of the proposed development.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 50

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Table 8-3: Technical scope of the impacts identified during all phases of the proposed mast installations. PHASE POTENTIAL POTENTIAL ASSESSMENT THEME SOURCE OF ISSUE Planning ISSUES RECEPTORS Construction Operational ACTIONS and design General BA and Environmental Legal and policy  Licensing and obtaining  DEFF X X X policy compliance Authorisations authorisation from relevant CA  Siting and placement  Terrestrial  Earthworks environment Infrastructure  Accidental leakages X X X General BA  TFR train  Maintenance conductors  Improved telecommunications  Siting and  Terrestrial placement environment Material  Runoff and  Hydrological X General BA Stockpiling sedimentation environment  Alien vegetation  Surrounding Built  Dust landowners environment  Terrestrial  Inappropriate Stormwater environment infrastructure X X X General BA management  Hydrological  Poor maintenance environment  Poor planning for storage, handling  Terrestrial and disposal of environment general and Waste hazardous waste  Hydrological X X General BA Management environment  Construction rubble  Surrounding  General refuse landowners  Hazardous wastes  Cement mixing

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 51

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PHASE POTENTIAL POTENTIAL ASSESSMENT THEME SOURCE OF ISSUE Planning ISSUES RECEPTORS Construction Operational ACTIONS and design  Construction  Hydrological activities environment Soils  Inadequate erosion X X  Terrestrial management/rehabi environment litation  Vegetation  Flora in study Terrestrial Natural vegetation disturbance / X X area General BA environment clearance Invasion / establishment of  Faunal and flora  Habitat destruction X X X alien vegetation in study area species Avifaunal injuries  Bird collisions with  Avifauna X and mortalities mast  Earthworks  Siting and placement of infrastructure Surface- and  Construction and Hydrological  Hydrological groundwater operational X General BA environment environment pollution activities  Waste management  Hazardous substances  Erosion  Planning and  Local design, construction Job creation community X X and operational  General public activities Socio-  Adequate ablution General BA economic  Staff Sanitation facilities at X  Labourers construction site  Staff Health and safety  Poor planning X X  Labourers

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 52

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PHASE POTENTIAL POTENTIAL ASSESSMENT THEME SOURCE OF ISSUE Planning ISSUES RECEPTORS Construction Operational ACTIONS and design  Construction activities  Vegetation  Surrounding clearance Air quality and dust landowners and  Earthworks community X control  Construction  Staff and activities labourers  Terrestrial  Flammable goods environment  Cooking, smoking On-site fire risk  Surrounding X X and open flame on landowners and site general public  Construction activities  Surrounding Traffic  Operation of the landowners and X X telecommunication general public mast  Heritage Heritage and  Siting and resources and paleontological placement X General BA Paleontological resources  Earthworks findings  Inadequate  Terrestrial planning and environment Rehabilitation Inadequate provisioning  Hydrological and rehabilitation and  Lack of environment X X X General BA maintenance maintenance maintenance of  Surrounding infrastructure landowners and general public  Construction  Surrounding Landscape and activities Visual landowners and X X VIA aesthetic  Mast and community infrastructure

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 53

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9 VISUAL SPECIALIST KEY FINDINGS AND IMPACTS

An appropriately qualified and experienced specialist was appointed to undertake the Visual Impact Assessment. The specialist gathered baseline information relevant to the study and assessed impacts associated with the proposed telecommunications mast. The specialist has also made recommendations to mitigate negative impacts and enhance benefits. The resulting information has been synthesised in the section below, whilst the full specialist report has been attached to the BAR in Appendix C. This section summarises the specialist Visual Impact Assessment and their opinion on the proposed mast installation.

A site visit to assess the visual character of the area and visit potentially sensitive viewpoints was undertaken on the 23rd of October 2019. The following main land use activities identified included agricultural holdings to the north and west. There are areas of natural vegetation immediately south of the proposed site. Generally, the development is sheltered to some degree by natural vegetation and the topography of the landscape. Visually sensitive receptors are locations or areas where people may have a significantly increased visual sensitivity or exposure to changes in the surrounding environment. Figure 9-1 indicates all potential visual receptors within 5km of the proposed telecommunications mast. The following visual sensitive receptors were identified:  Residents of Pyramid AH;  Residents of Stil Gelee AH;  Residents of Bon Accord AH;  Residents of Doornpoort Urban Suburb; and  Motorists using the main roads in the study area.

Figure 9-1: Potential visual receptors for the proposed development site at Pyramid South.

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Table 9-1 summarises the impacts identified by the Visual Impact Specialist.

Table 9-1: Summary of visual impacts associated with the proposed telecommunications mast

SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

CONSTRUCTION PHASE There are various activities which will take place during the  The construction contractor should clearly demarcate construction construction phase which may have impacts on sensitive visual areas so as to minimise site disturbance. receptors:  The site should be kept neat and tidy. Littering should be fined, and the SHE officer should organise rubbish clean-ups on a regular basis.  There will be a slight increase in vehicular movement of Visual impact of  Night lighting of the construction sites should be minimised within trucks delivering supplies and construction material. construction LOW- requirements of safety and efficiency in the EMPr. LOW - activity  A small area of degraded vegetation will need to be cleared  Implement mitigation measures as recommended. for the foundations.  Construction of telecommunication mast will potentially draw attention if they are exposed above the skyline.  Soil stockpiling and vegetation debris. OPERATIONAL PHASE There are a number homesteads on the Pyramid Agricultural  Other than avoiding the site completely there are no mitigation holdings to the north of the proposed site. Residents’ views and measures that will reduce the visual intrusion of the any scenic viewpoints on their properties may potentially be MODERATE - MODERATE - telecommunication mast due to its height and visibility. However, affected by the proposed development. However, this will be lighting must be designed to minimise light pollution without dependent on the site specific characteristics of each homestead. compromising safety. There are a number homesteads on the Stil Gelee Agricultural holdings to the north of the proposed site. Residents’ views and Impact of tele- any scenic viewpoints on their properties may potentially be MODERATE - MODERATE - communication affected by the proposed development. However, this will be mast on visually dependent on the site specific characteristics of each homestead. sensitive Bon Accord is an area comprising of agricultural holdings. Based on receptors the viewshed analysis, views from most of the area will not be LOW- LOW- affected by the proposed telecommunications mast. The suburb of Doornpoort is located approximately 3.9km directly south of the proposed site. The majority of the suburb is screened LOW- LOW- as a result of the topography (i.e. the hills/”koppies”) between Doornpoort and the proposed site. Motorists using the main roads, such as R101, N4 and N1, will LOW- LOW- potentially be able to see the mast from certain viewpoints.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 55

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SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

CUMULATIVE IMPACTS There are other industrial developments and electrical  There are no feasible mitigation measures to reduce the cumulative infrastructure existing within the surrounding landscape. These Visual impact of visual impact of the industrial and electrical infrastructure in the facility include existing railways lines and overhead powerlines. The MODERATE - surrounding areas. If each the mitigation measures suggested in the MODERATE - construction and cumulative visual impacts of this infrastructure will be moderate, VIAs and Environmental Management Programmes, this will serve to operation however the contribution of the proposed telecommunication reduce the cumulative impact to some extent. mast will be low. NO-GO ALTERNATIVE The No-Go alternative in the context of this project implies that  Not applicable to the no-go option. Impact of tele- the telecommunication mast would not be constructed and the communication current land use, namely the use as freight rail relay substations, NONE NONE mast on sensitive would persist. The required telecommunications upgrade will not visual receptors be provided.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 56

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Overall, the telecommunication mast and associated infrastructure will have a low to moderate impact on the visual landscape for certain visual receptors. However, this should be considered within the context of the following:

 Existing industrial and electrical infrastructure, including the railway line , the Transnet Depot, overhead powerlines and telephone lines, already impose on the visual landscape for nearby visual receptors; and  Although limited, certain mitigation recommendations in this report can mitigate the impacts to some extent.

It is concluded that potential losses of scenic resources are not sufficiently significant to present a fatal flaw to the proposed project.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 57

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10 IMPACT ASSESSMENT

The impact assessment identified and assessed impacts across three phases of development:  Planning & Design Phase  Construction Phase  Operational Phase

Using the technical scope as a guide, an impact assessment was conducted based on site visits and information provided by TFR relating to the planning, construction and operation phases, as well as the no-go alternative, for the telecommunications mast. A detailed impact assessment of all the identified impacts is provided in Appendix B. A breakdown of the assessment and mitigation measures is presented in Planning and Design Phase Impacts Table 10-1 - Impacts Associated with the No-Go Alternative Table 10-4 below.

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PLANNING AND DESIGN PHASE IMPACTS

Table 10-1: Summary of impacts associated with the proposed telecommunications mast during the planning and design phase.

SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

Environmental Policy

During the planning and design phase, failure to adhere to existing  All relevant legislation and policy must be consulted and the policies and legal obligations and obtain the necessary proponent must ensure that the project is compliant with such authorisations could lead to the project conflicting with local, legislation and policy. Legal and policy  These should include (but are not restricted to): NEMA, the Gauteng provincial and national policies, legislation, etc. This could result in HIGH - LOW - compliance lack of institutional support for the project, overall project failure C-Plan, and Local Municipal bylaws. and undue disturbance to the natural environment.  All relevant permits and authorisations including Water Use Licences, Building Plan Approvals and plant removal permits must be in place prior to commencement of construction.

Built Environment

During the planning and design phase, planning and placement of  Planning for and placement of infrastructure must be done so as to structures in sensitive areas could lead to the damage and avoid sensitive areas as far as possible. Infrastructure MODERATE - LOW - degradation of natural areas as well as to the structures themselves.

During the planning and design phase, inadequate planning for  A method statement must be developed by the project manager or stormwater during the construction and operational phases within contractor prior to construction, including considerations for the site could result in erosion and contamination of the soil and stormwater, erosion, waste and alien vegetation management, as surrounding watercourses if there is not appropriate stormwater well as site rehabilitation and maintenance considerations. This management structures in place. method statement must be approved by the appointed ECO.  This method statement should include stormwater management Stormwater considerations to control runoff prevent erosion of the site and its MODERATE - LOW - management surroundings, and mitigate the unnecessary loss of soil and sedimentation of watercourses during all phases of the project.  Regular monitoring of implementation of this method statement for the rehabilitation of disturbed areas must be conducted.  Appropriate stormwater structures, in alignment with the method statement, must be designed to minimise erosion of the surrounding environment

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 59

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SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

During the planning and design phase, failure to plan for the  A method statement must be developed by the project manager or storage, handling and disposal of general and hazardous waste contractor prior to construction, including considerations for during the construction and operation phase may lead to littering stormwater, erosion, waste and alien vegetation management, as and pollution of the surrounding environment, unsanitary well as site rehabilitation and maintenance considerations. This conditions and health risks. method statement must be approved by the appointed ECO.  This method statement should include waste management Waste considerations for handling onsite general and hazardous waste MODERATE - LOW - management during the construction and operation phases must be developed and implemented during construction.  An appropriate area must be identified where waste can be stored before disposal.  All hazardous substances such as paints, diesel and cement must be stored in a secure bunded area with an impermeable surface beneath them.

Terrestrial environment

During the planning and design phase inappropriate demarcation  A method statement must be developed by the project manager or of construction activities may result in the loss of topsoil and contractor prior to construction, including considerations for increase in soil erosion. stormwater, erosion, waste and alien vegetation management, as well as site rehabilitation and maintenance considerations. This Soils LOW - LOW - method statement must be approved by the appointed ECO.  This method statement should include erosion management considerations to mitigate the unnecessary loss of soil during all phases of the project.

During the planning and design phase the inappropriate design of  Vegetation clearance must be limited to the area within the fenced the project infrastructure and demarcation of project boundaries CTC area where applicable. Natural vegetation MODERATE - LOW - will lead to the unnecessary disturbance and/or loss of natural  Vegetation disturbance outside of the fenced CTC area should be vegetation and habitat supporting other taxonomic groups. minimized.

During the planning and design phase the failure to plan for the  A method statement must be developed by the project manager or Control of alien removal and management of alien vegetation could result in the contractor prior to construction, including considerations for MODERATE - LOW - species invasion of alien vegetation in sensitive areas during the stormwater, erosion, waste and alien vegetation management, as construction and operational phases.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 60

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SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

well as site rehabilitation and maintenance considerations. This During the planning and design phase, the failure to plan for the method statement must be approved by the appointed ECO. rehabilitation of impacted areas may lead to the establishment of  This method statement should include alien vegetation management alien vegetation. MODERATE - considerations to mitigate the establishment and spread of LOW - undesirable alien plant species during all phases of the project.  Regular monitoring and rehabilitation of disturbed areas must be conducted by the appointed ECO.

Socio-economic

During the planning and design phase, there will be some  N/A temporary job opportunities associated with planning and design Job creation of the proposed telecommunication mast. LOW + LOW +

During the planning and design phase, failure to plan for potential  A health and safety plan in terms of the Occupational Health and health and safety risks during the construction and operation Safety Act, 1993 (Act No 85 of 1993) must be drawn up by and HSE Health and safety phase may result in the harm of labourers, staff, surrounding MODERATE - officer prior to construction to ensure workers safety. LOW - landowners and the public.  Railway safety protocols need to be implemented during construction and operational phases.

During the planning and design phase, failure to plan for accidental  Emergency preparedness must be in place for both the construction fires during the construction and operation phase could result in and operational phases and before these phases commence. This On-site fire risk potential harm to the public and/or surrounding landowners and MODERATE - should form part of the method statement. LOW - their property.  TFR must plan for and put measures in place to prevent and deal with fires including the provision of firefighting equipment.

During the planning and design phase, inadequate planning for the  Consultation with the local Road Traffic Unit should be done early in transportation of mast materials and specialist construction the planning phase and if deemed necessary, road traffic permits equipment to the site could cause traffic congestion. should be obtained for transporting parts, containers, materials and construction equipment to the site.  Make provision for traffic accommodation where construction Traffic MODERATE - activities impact on existing roads. LOW -

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SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

Rehabilitation and maintenance

Inadequate During the planning and design phase, inadequate planning for  A rehabilitation plan must be developed by the project manager or contractor as part of the method statement and implemented during rehabilitation and rehabilitation and maintenance of infrastructure could lead to MODERATE - LOW - construction and operation phases. This method statement must be maintenance degradation of the study area and surrounding areas. approved by the appointed ECO.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 62

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CONSTRUCTION PHASE IMPACTS

Table 10-2: Summary of impacts associated with the proposed telecommunications mast during the construction phase.

SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

Environmental Policy  All construction related conditions in the Environmental During the construction phase, failure to adhere to existing policies Authorisation, EMPr and other permits must be adhered to. and legal obligations and obtain the necessary authorisations  Transnet must employ an independent Environmental Control Officer could lead to the project conflicting with local, provincial and (ECO) for the construction phase to ensure that construction is Legal and policy national policies, legislation, etc. This could result in lack of HIGH - implemented according to specifications in the EA and EMPr. LOW - compliance institutional support for the project, overall project failure and  Copies of all applicable licenses, permits and managements plans (EA, undue disturbance to the natural environment. EMPr, etc.) must be available on-site at all times.  Environmental Awareness Training must be included in site meetings/talks with all workers. Built Environment  Vegetation clearance must be limited to the area within the fenced During the construction phase, the disturbance/clearing of CTC area where applicable. vegetation and construction activities within or within close Infrastructure MODERATE -  Vegetation disturbance outside of the fenced CTC area should be LOW - proximity to sensitive areas may result in degradation of the minimized. surrounding environment.

 Material stockpiles must be located away from sensitive areas and Material During the construction phase, inappropriate location and MODERATE - they must be monitored for erosion and alien vegetation. LOW - stockpiling management of material stockpiles may result in erosion.  Material stockpiles locations must be approved by the ECO.  The construction site must be managed in a manner that prevents During the construction phase, failure to implement effective pollution to downstream watercourses or groundwater, due to stormwater management measures may result in increased suspended solids, silt or chemical pollutants. Stormwater surface soil erosion and contamination of stormwater and MODERATE -  Berms and swathes must be placed in areas that may be prone to LOW - management resulting surrounding watercourses. erosion.  Temporary cut-off drains and berms may be required to capture storm water and promote infiltration.  All general waste must be disposed of in bins/waste skips labelled During the construction phase, poor management of handling, “general waste”. disposal and storage of general and hazardous waste may lead to  Sufficient waste bins must be provided throughout the construction Waste the pollution of the surrounding environment. site for collecting waste. MODERATE - LOW - management  All general waste collected on site must be disposed of at a licensed general waste disposal site.  All hazardous waste generated on site must be placed in a temporary impermeable bunded containment area which must be disposed of

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SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

at a hazardous landfill site or be collected by the appropriate service provider.  Proof of receipt of hazardous waste by a licenced service provider must be maintained on the site.  Adequate sanitary facilities must be provided for construction workers and they must be properly secured to the ground.  Maintenance of the chemical toilets should be done on a regular basis to prevent any leakages.  Concrete and cement mixing must be conducted at a single location During the construction phase, the mixing of cement on site could which should be centrally located, where practical. This mixing must result in ground water contamination from compounds in the take place on an impermeable surface, and dried waste concrete and cement. In addition, a large number of cement mixing stations on MODERATE - cement must be disposed of with building rubble. LOW - site could increase the presence of impermeable areas which in  No concrete mixing must take place within 32 m of any watercourse. turn could increase rates of run-off and thereby increase the risk of localized flooding, soil erosion, silting, gully formation, etc.

Terrestrial environment  Wind screening and stormwater control must be undertaken to During construction phase, the erosion from construction prevent soil loss from the site. activities may result in the loss of soil from the development area  All erosion control mechanisms must be regularly maintained. and surrounds.  Natural vegetation must be retained where possible to avoid soil erosion. Soils MODERATE -  Construction must be phased in order to minimise the area of LOW - exposed soil at any one time.  Disturbed areas of natural vegetation must be rehabilitated immediately to prevent further soil erosion.  Fill and stabilise all erosion rills before they develop into larger gullies that advance from erosion and runoff due to construction activities  The construction footprint must be surveyed and demarcated prior During the construction phase the clearing of natural vegetation to construction commencing. outside the approved development footprint will lead to the  Vegetation clearance must be limited to the area within the fenced unnecessary loss of natural vegetation. CTC area. Natural vegetation MODERATE -  Vegetation disturbance outside of the fenced CTC area should be LOW - minimized.  Where vegetation has been cleared, site rehabilitation in terms of soil stabilisation and vegetation must be undertaken.  The contractor's staff must not harvest any natural vegetation.

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SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

 The alien vegetation management measures outlined in the method During the construction phase, the disturbance of natural statement must be implemented by the contractor during the vegetation creates open habitats that favour the establishment of construction phase to reduce the establishment and spread of undesirable alien plant species in areas that are typically very HIGH - undesirable alien plant species. LOW - difficult to eradicate and may pose a threat to neighbouring  Alien plants must be removed from the site through appropriate Establishments of ecosystems methods such as hand pulling, application of chemicals, cutting etc. alien plant species as in accordance to the NEMBA: Alien Invasive Species Regulations.  Disturbed areas will be rehabilitated/prepared to allow natural re- During the construction phase poor rehabilitation of disturbed vegetation. Restoration must be conducted as per the approved areas may lead to the permanent degradation of ecosystems as MODERATE - method statement. LOW - well as allow alien vegetation species to expand.

Hydrological environment  All hydrocarbons and chemicals must be stored on impermeable During the construction phase, various substances may result in surfaces with appropriately-sized containment bunds and grease the pollution of surface and groundwater sources. Washing down traps. Traps must be regularly cleaned. of vehicles and equipment may result in the pollution of  All chemicals of all types must be stored on impermeable surfaces in groundwater, drainage lines, wetlands, and other water bodies, secure and bunded designated storage areas. and pollution may occur from poor vehicle maintenance and  Cement must be stored on impermeable storage areas protected improper storage of hazardous materials such as fuel, etc. from the rain and mixed only in designated areas. Cement residue Surface- and must be cleaned up immediately.  Vehicle repairs, servicing, refuelling and washing must be done only groundwater MODERATE - LOW - in designated areas with impermeable surfaces with appropriately- pollution sized containment bunds and grease traps.  Where it is necessary to service, repair or refuel a vehicle or item of plant in the field drip trays must be used to catch drips, spills and leaks.  Spill kits must be available at all locations where chemicals of hydrocarbons are stored, handled or used, and spills must be cleaned up immediately in accordance with an established protocol appropriate to the material in question Socio-economic During the construction phase, there will be some temporary job  N/A Job creation opportunities associated with building of the proposed LOW + LOW + telecommunication mast.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 65

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SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

During the construction phase, failure to comply with health and  A health and safety plan in terms of the Occupational Health and safety policies and protocols may result in the harm of labourers, Safety Act, 1993 (Act No 85 of 1993) must be adhered to and enforced Health and safety staff, surrounding landowners and the public. MODERATE - by a HSE officer to ensure workers safety. LOW -  Railway safety protocols need to be implemented during construction and operational phases.

 During windy periods un-surfaced and un-vegetated areas must be During the construction phase, dust generated by construction dampened down. vehicles and construction activities could result in significant dust MODERATE -  Vegetation must be retained where possible as this will reduce dust LOW - during windy conditions. Air quality and travel. dust control  Any complaints or claims emanating from dust issues must be During the construction phase poor maintenance and servicing of attended to immediately and noted in the complaints register. construction plant and vehicles may result in an increase in vehicle MODERATE -  Vehicles and construction plant must be serviced regularly so as to LOW - emissions in the areas. reduce excessive vehicle emissions.

In order to reduce the risk of fires: During the construction phase inadequate attention to fire safety awareness and fire safety equipment could result in uncontrolled  All flammable substances must be stored in dry areas which do not fires, posing a threat to animals, vegetation and the surrounding pose an ignition risk to the said substances.  Smoking must not be permitted near flammable substances. On-site fire risk landowners. MODERATE - LOW -  All cooking must be done in demarcated areas that are safe in terms of runaway or uncontrolled fires.  No open fires must be allowed on site.  Fire extinguishers must be available onsite.

During the construction phase, there is likely to be an increase in  Activities which include the movement of construction vehicles and traffic volumes to and from the site which may result in the operation of machinery should be restricted to normal working vehicle/pedestrian collisions and degrade the existing road hours (07:00am – 17:00pm). conditions  There must be a complaints register on site for nearby residents to make complaints. These must be addressed and recorded.  Local residents should be made aware of the presence of Traffic LOW - construction vehicles by making use of high-visibility signage. LOW -  All traffic safety (flagmen) and traffic calming measures should be in place within the site and where traffic enters the main road.  It is recommended that any damage to the road as a result of construction activities and vehicles should be repaired immediately and maintained in the original or improved state prior to construction.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 66

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SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

During the construction phase, there is the possibility of impacts  Although it would seem unlikely that any significant archaeological on unidentified heritage and paleontological resources. remains will be exposed during the development, there is always a possibility that human remains and/or other archaeological remains Heritage and and historical material may be uncovered during the development. paleontological LOW - Should such material be exposed during construction, all work must LOW - resources cease in the immediate area (depending on the type of find) and it must be reported to SAHRA, so that a systematic and professional investigation can be undertaken. Sufficient time should be allowed to investigate and to remove/collect such material.

Rehabilitation and maintenance

Inadequate During the construction phase inadequate provision and  The rehabilitation plan must be implemented during and after the rehabilitation and implementation of rehabilitation measures may lead to the MODERATE - construction has been completed. LOW - maintenance degradation of the surrounding environment.

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OPERATIONAL PHASE IMPACTS

Table 10-3: Summary of impacts associated with the proposed telecommunications mast during the operational phase.

SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

Environmental Policy

During the operation phase, failure to adhere to all permits,  The proponent must ensure that operations of the telecommunication mast is compliant with the relevant legislation Legal and policy authorisations and regulations may lead to financial penalties and HIGH - and policy. LOW - compliance closure of the proposed telecommunication mast.  These should include (but are not restricted to): NEMA, EA, EMPr and any other permits/authorisations.

Built Environment

During the operation phase, the telecommunication mast will  Regular maintenance and inspections of all infrastructure and Infrastructure facilitate open communication channels between train conductors MODERATE + services must be undertaken. MODERATE + along the railway lines.

During the operation phase, failure of the stormwater system and  Stormwater management measures such as attenuation structures, channels, etc. must be properly maintained and monitored. Stormwater or lack of maintenance of the stormwater system may result in the MODERATE -  If the stormwater management measures put in place are deemed LOW - management erosion and or pollution of the surrounding environment should the stormwater be contaminated. insufficient, a qualified engineer must be approached to assist with additional storm water attenuation mechanisms and remediation.

Terrestrial environment

During the operational phase, the collisions with  None telecommunication mast may result in avifaunal injuries and Avifaunal injuries mortalities. Although there is limited data available on the number LOW - LOW - and mortalities of avifaunal collisions with telecommunications mast, it is possible that a few cases of collisions may occur should the proposed mast be installed.

During the operational phase, the inadequate monitoring of alien  The approved alien vegetation management measures must be Establishment of invasive vegetation could result in such introductions resulting in MODERATE - implemented to reduce the establishment and spread of undesirable LOW - alien plant species permanent establishment of alien species. alien plant species.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 68

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SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

 Alien plants must be removed from the site through appropriate During the operational phase, the poor rehabilitation of disturbed methods such as hand pulling, application of chemicals, cutting etc. areas may lead to the permanent establishment of alien as in accordance to the NEMBA: Alien Invasive Species Regulations. vegetation. MODERATE - LOW -

Rehabilitation and maintenance

Inadequate During the operation phase inadequate rehabilitation of disturbed  Disturbed areas will be rehabilitated/prepared to allow natural re- rehabilitation and areas and lack of maintenance of infrastructure may lead to the MODERATE - vegetation. LOW - maintenance degradation of the surrounding environment.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 69

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IMPACTS ASSOCIATED WITH THE NO-GO ALTERNATIVE

Table 10-4: Summary of impacts associated with the no-go alternative to the proposed telecommunications mast.

SIGNIFICANCE SIGNIFICANCE POTENTIAL OF IMPACT SOURCE OF ISSUE WITHOUT MITIGATION MEASURES ISSUES WITH MITIGATION MITIGATION

Built Environment

The No-Go alternative in the context of this project implies that  Proceed with the installation of the telecommunications mast. the telecommunication mast would not be constructed and the Infrastructure current land use, namely the use as freight rail relay substations, MODERATE - MODERATE + would persist. The required telecommunications upgrade will not be provided.

Socio-economic

The No-Go alternative, resulting in the required  Proceed with the installation of the telecommunications mast. Health and safety telecommunications upgrades not being installed, could indirectly MODERATE - LOW + lead to safety concerns along the freight railway lines.

CUMULATIVE IMPACTS

The main cumulative impact will be the addition of another tall visual intrusion in the area, which will be visible to the surrounding areas. There are other industrial developments and electrical infrastructure existing within the surrounding landscape. These include existing railways lines and overhead powerlines. The cumulative visual impacts of the existing infrastructure will be moderate, however the contribution of the proposed telecommunication mast will be low.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 70

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11 SENSITIVITY ANALYSIS

A site sensitivity analysis has been conducted based on specialist and general site information gathered. The site was classified into areas of low, conditional sensitivity and NO-GO development.  NO-GO includes areas where no construction should take place.  High Sensitivity areas will require considerable effort to design out, mitigate or manage negative environmental impacts. In many cases this will not be possible and in general these areas should be avoided. Only facilities that are location dependent should be permitted in these areas.  Moderate Sensitivity areas can accommodate development, but there are constraints. Mitigation and management will be required to reduce significant environmental impacts to acceptable levels, and appropriate technology and design will be required to reduce impacts and ensure sustainability.  Low Sensitivity areas can be easily developed, as there are only minor constraints, and little mitigation and management is required (aside from normal building design and construction restrictions outlined in the EMP).

Table 11-1 and Figure 11-1 - Figure 11-3 below indicate the sensitive environmental features identified by the EAP within the vicinity of the proposed development site and surrounding areas.

Table 11-1: Sensitive Features in the Study Area SENSITIVE ENVIRONMENT DESCRIPTION RISK

Built Environment  Railways VERY LOW  Roads

 Endangered Ecosystems  Critical Biodiversity Areas HIGH  Formal Protected Areas

 Vulnerable Ecosystems Terrestrial Environment  Ecological Support Areas MODERATE  Informal Protected Areas  Important Birding Areas

 Any other areas LOW

 Rivers HIGH  Natural Wetlands Hydrological Environment  Rivers (50m buffer)  Artificial Wetlands MODERATE

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SENSITIVE ENVIRONMENT DESCRIPTION RISK

 Natural Wetlands (500m buffer) LOW  Any other areas

The Pyramid South project site falls within an area of low terrestrial and hydrological sensitivity, with no significant environmental sensitivities found on site. Areas of moderate terrestrial sensitivity, namely an ESA and vulnerable ecosystem, are found within 500m to the north and west of the site. A high sensitivity hydrological area (natural wetland) is found within 500m to the north-west of the site. Considering the relatively small footprint of the mast and its location within the fenced CTC area, which has already been transformed for freight rail- related purposes, the proposed mast will minimally impact upon sensitive terrestrial and hydrological environments.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 72

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Figure 11-1: Terrestrial Environment Site Sensitivity for the Pyramid South project site.

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Figure 11-2: Hydrological Environment Site Sensitivity for the Pyramid South project site.

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Figure 11-3: Overall Site Sensitivity for the Pyramid South project site.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 75

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12 SUMMARY OF KEY ENVIRONMENTAL FINDINGS

This section provides and overview of the environmental impacts associated with the installation of the telecommunications mast at Pyramid South, Gauteng. Table 12-1 provides an overall summary of the negative (cost) and positive (benefit) environmental impacts associated with the proposed telecommunications mast. Overall, the tables above indicates that there are several potential negative impacts (environmental costs) associated with the proposed telecommunications mast. However, the significance of these can be reduced to an acceptable level by implementing appropriate mitigation measures. There are a few positive impacts (benefits) associated with the proposed telecommunications mast. These relate primarily to the improvement of the telecommunication infrastructure along the existing freight rail lines and associated efficiency and safety benefits, and the creation of temporary jobs. Based on the above analysis it can be seen that pre-mitigation, there are eight negative impacts of LOW significance, 32 of MODERATE significance and four of HIGH. After mitigation there be no negative residual impacts of HIGH, with only three visual impacts of MODERATE significance.

Table 12-1: Summary of impacts before and after mitigation across phases. Before Mitigation After Mitigation Theme Low Moderate High Low Moderate High Environmental -3 -3 policy Built -10 (+1) -10 (+1) environment Terrestrial -2 -8 -1 -11 environment Hydrological -1 -1 environment Socio- -2 (+1) -7 -9 (+1) economic Rehabilitation and -3 -3 maintenance Landscape -4 -3 -4 -3 and aesthetic Total -8 (+1) -32 (+1) -4 -41 (+1) -3 (+1) 0

Construction and operational activities will likely result in the areas of bare soil being exposed to the elements. Erosion is thus likely to occur and is further intensified by the climatic conditions (heavy winds and high rainfall). Not only will this affect the volume, and fertility of the soil but may also impact on the quality of the surface water runoff (which could affect the wetland nearby).

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 76

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13 CONCLUSIONS AND RECOMMENDATIONS

This Chapter of the FINAL BAR provides a summary of the findings of the proposed telecommunications mast and a comparative assessment of the positive and negative implications of the proposed project and identified alternatives. In addition, this Chapter provides the EAP’s opinion as to whether the activity should or should not be authorised as well as the reason(s) for the opinion.

DESCRIPTION OF THE PROPOSED ACTIVITY

Transnet Freight Rail (TFR) proposes to construct a telecommunication mast in an effort to improve the communication channels between train conductors along existing freight rails at Pyramid South in Pretoria, Gauteng.

The general requirement is a 35m tapered steel lattice tower with either a square or triangular base. The design is a tapered, self-supporting lattice type mast (angle iron) with a 2.5m2 Antenna load at the top of the mast, which needs to sustain wind speeds up to 160km/h. The mast shall be painted red and white, and shall have a Direct Current (DC) powered navigation light on top. The following details are relevant to the proposed mast.

The mast will be constructed in areas where existing freight rail-related infrastructure has been installed. In all cases this will be within secured, fenced CTC station premises. The site layout plan is illustrated in Figure 2-3.

ASSUMPTIONS, UNCERTAINTIES AND GAPS

ASSUMPTIONS

The following assumptions have been made during the BA process:  Vegetation clearance will be kept to a minimum during the construction of the mast.  Vegetation disturbance outside of the fenced CTC area will be minimized as far as possible.

GAPS

No detailed engineering input was provided in this phase of the development. It is general engineering practice that the detailed design phase of a project is only initiated once environmental authorisation for a project (based on what is submitted as preliminary design) is secured. In this regard, the BAR considered industrial norms. This has also provided the EIA process an opportunity to guide the Planning and Design proactively rather than reactively. The Environmental Management Programme (EMPr) should therefore be viewed as a dynamic evolving document that can be adapted to specific needs and design conditions.

If the project is authorised by the Department of Environment, Forestry and Fisheries (DEFF), TFR will be required to provide DEFF with final layout plans (i.e. mast placement, mast designs, etc.). These plans should be informed by the BA and any other post-authorization studies or surveys as required, e.g. geotechnical investigations, ecological walk-throughs and

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micro siting adjustments. The final layout requirement will further serve to demonstrate to DEFF how the relevant environmental standards and management specifications contained in the EMPr, as informed by the site specific environmental context and potential impacts, as well as the relevant conditions of authorisation, will be incorporated in the detailed design process.

CONSIDERATION OF ALTERNATIVES

LOCATION ALTERNATIVES

Only one location has been assessed. Alternative locations for the current project are not being considered as the proposed telecommunication mast is required at this location. Communication channels along this freight rail route requires upgrading and the installation of telecommunication mast at this site is critical to the overall feasibility of the project.

ACTIVITY ALTERNATIVES

The proposed site is currently being used by TFR as the CTC area for freight rail-related purposes. Alternative activities for the current project are not being considered as the purpose of the proposed mast is to improve the communication channels along the existing freight railways in this area.

TECHNOLOGY ALTERNATIVES

UHF technology uses radio links and is the preferred alternative because TFR is licenced to operate radio equipment on the frequency band approved by the Independent Communications Authority of South Africa (ICASA).

LAYOUT ALTERNATIVES

This relates mostly to alternative ways in which the proposed development or activity can be physically laid out on the ground to minimise or reduce environmental risks or impacts. The proposed layout in Figure 2-3 is the only layout alternative being considered.

NO-GO ALTERNATIVE

The No-Go alternative in the context of this project implies that the telecommunication mast would not be constructed and the current land use, namely the use as freight rail CTC area, would persist. If the project does not proceed the negative impacts such as risk of collisions of birds would be avoided. However, it would also mean that the project would not be provide the required telecommunications upgrade for the surrounding freight railway lines.

OPINION OF THE EAP

It is the professional opinion of CES and specialists that:  NO FATAL FLAWS are currently associated with the proposed telecommunications mast installation, as all identified impacts can be adequately mitigated to reduce the risk or significance of impacts to an acceptable level, provided mitigation measures recommended in this report are implemented and maintained throughout the life of the project.

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 If any changes to these layouts are made, the input of the relevant specialist must be obtained and incorporated into any changes.  The information in the report is sufficient to allow DEFF to make an informed decision.

RECOMMENDATION OF THE EAP AND SPECIALIST

It is the recommendation of CES that the proposed telecommunications mast should be approved provided that the proposed mitigation measures are implemented and that the EMPr is implemented, maintained and adapted to incorporate relevant legislation, standard requirements and audit reporting, throughout the life of the development. The mitigation measures for all impacts identified in the BAR must be incorporated into the EMPr and must be used by the engineers during the detailed Planning & Design Phase, by the contractors during the Construction Phase and by TFR during the Operation Phase.

The following recommendations were provided by the Visual Impact Specialist:  The construction contractor should clearly demarcate construction areas so as to minimise site disturbance.  The site should be kept neat and tidy. Littering should be fined, and the SHE officer should organise rubbish clean-ups on a regular basis.  Night lighting of the construction sites should be minimised within requirements of safety and efficiency in the EMPr.  Other than avoiding the site completely there are no mitigation measures that will reduce the visual intrusion of the telecommunication mast during the operational phase, due to its height and visibility. However, lighting must be designed to minimise light pollution without compromising safety.

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 79

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14 APPENDICES

APPENDIX A – MAPS AND PHOTOGRAPHS APPENDIX B – IMPACT TABLES APPENDIX C – SPECIALIST IMPACT ASSESSMENT APPENDIX D – PUBLIC PARTICIPATION PROCESS APPENDIX E – ENVIRONMENTAL MANAGEMENT PROGRAMME APPENDIX F – DETAILS AND EXPERIENCE OF THE EAP

CES Environmental and Social Advisory Services TFR Telecom Mast - Pyramid South, GP 80