DRAFT

ECOLOGICAL IMPACT ASSESSMENT REPORT

KEI MOUTH ECO ESTATE, KEI MOUTH, EASTERN CAPE PROVINCE

DEDEAT REF:

DRAFT ECOLOGICAL IMPACT ASSESSMENT REPORT

Prepared for:

Mr Rob Wood Lutuli Ranches CC

Prepared by:

CES EAST LONDON 25 Tecoma Street Berea, East London, 5214 043 726 7809 Also in Grahamstown, Port Elizabeth, Cape Town, Johannesburg and Maputo (Mozambique)

www.cesnet.co.za

MAY 2019

DRAFT Ecological Report

REVISIONS TRACKING TABLE

CES Report Revision and Tracking Schedule Document Title: Draft Ecological Impact Assessment for the Kei Mouth Eco Estate

Client Name & Lutuli Ranches CC Address: Robin Wood

Farm 73, 76, 79, Kei Mouth, Eastern Cape.

Status: Draft Ecological Impact Assessment

Issue Date: May 2019

Lead Author: Caryn Clarke

Reviewer: Alan Carter

Study Leader/ Registered Environmental Assessment Practitioner – Approval: No. of hard No. electronic Report Distribution Circulated to copies copies

Report Version 1

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 [email protected] part) use or rely on the contents of this document, without the prior www.cesnet.co.za written permission of CES. The document is subject to all confidentiality, copyright and trade secrets rules, intellectual property law and practices of South Africa.

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TABLE OF CONTENTS

1 INTRODUCTION ...... 1

1.1 PROJECT LOCATION ...... 1 1.2 PROJECT DESCRIPTION ...... 1 1.3 INFRASTRUCTURE: ...... 2 1.3.1 Bulk water supply ...... 3 1.3.2 Bulk sewage: ...... 5 1.3.3 Solid Waste...... 6 1.3.4 Road access ...... 6 1.3.5 Electrical ...... 8 1.3.6 Telecommunication ...... 9 1.3.7 Stormwater ...... 9 1.3.8 Land-use zoning ...... 9 1.4 ALTERNATIVES ...... 10 1.5 TERMS OF REFERENCE ...... 5 1.6 APPROACH ...... 5 1.7 ASSUMPTIONS AND LIMITATIONS ...... 6 1.8 PUBLIC CONSULTATION ...... 6 2 PROJECT TEAM ...... 7

2.1 DETAILS OF THE SPECIALIST ...... 7 2.1.1 Ms Caryn Clarke (Cand. Nat. Sci - Report Writer) ...... 7 2.1.2 Dr Greer Hawley (Pri. Nat. Sci. – Ecologist and Report Reviewer) ...... 7 2.1.3 Dr Alan Carter (Pri. Nat. Sci. – Review and Quality Control) ...... 8 2.2 DECLARATIONS ...... 8 3 ASSESSMENT METHODOLOGY ...... 10

3.1 SPECIES OF CONSERVATION CONCERN ...... 10 3.1.1 Definitions: ...... 11 3.2 VEGETATION MAPPING ...... 15 3.3 RIVER AND WETLAND ASSESSMENT ...... 15 3.4 BIODIVERSITY AND CONSERVATION PLANNING INITIATIVES ...... 17 3.5 SENSITIVITY ASSESSMENT...... 18 3.6 IMPACT RATING METHODOLOGY ...... 21

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4 RELEVANT LEGISLATION ...... 24

4.1 OTHER RELEVANT POLICY AND PLANS ...... 29 5 DESCRIPTION OF THE BIOPHYSICAL ENVIRONMENT ...... 30

5.1 BACKGROUND AND LITERATURE REVIEW ...... 30 5.2 CLIMATE ...... 30 5.3 TOPOGRAPHY, GEOLOGY AND SOILS ...... 31 5.4 VEGETATION ...... 33 5.4.1 SANBI Classification (Mucin and Rutherford, 2018)...... 33 5.4.2 Forest Classification ...... 34 5.5 FAUNA ...... 35 5.5.1 Birds ...... 35 5.5.2 Amphibians and Reptiles ...... 35 5.5.3 Mammals ...... 36 5.6 SURFACE WATER ...... 36 5.6.1 National Freshwater Ecosystem Priority Areas (NFEPA), 2011-2014 ...... 36 5.6.2 National Biodiversity Assessment (2018) ...... 37 5.7 GROUNDWATER ...... 38 5.8 LAND USE ...... 38 5.9 BIODIVERSITY PLANNING AND CONSERVATION ...... 39 5.9.1 Subtropical Thicket Ecosystem Programme (STEP) ...... 39 5.9.2 Eastern Cape Biodiversity Conservation Plan (ECBCP) ...... 42 5.9.3 NEMBA Threatened Ecosystems ...... 44 5.9.1 Protected Areas and Expansion Areas ...... 45 5.9.2 Plant Species of Conservation Concern ...... 46 5.9.3 Alien Invasive Vegetation ...... 47 5.9.4 Great Kei Municipality Strategic Environmental Assessment (SEA) ...... 48 5.9.5 Great Kei Local Municipality Spatial Development Framework (SDF) ...... 49 6 SITE INVESTIGATION ...... 52

6.1 OBSERVATIONS ...... 52 7 SENSITIVITY ASSESSMENT ...... 66

7.1 SENSITIVITY ALLOCATION ...... 66 8 IMPACT ASSESSMENT ...... 73

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8.1 IMPACT IDENTIFICATION ...... 73 8.2 IMPACT ASSESSMENT ...... 75 9 IMPACT STATEMENT ...... 82

9.1 PROJECT SUMMARY ...... 82 9.2 IMPACT STATEMENT ...... 82 9.2.1 Summary of impacts ...... 82 9.2.2 Cumulative impacts ...... 84 9.2.3 No-Go alternative ...... 84 9.2.4 Compatibility with Biodiversity Planning Initiatives ...... 85 9.2.5 Sensitivity assessment ...... 86 9.3 RECOMMENDATIONS ...... 87 9.3.1 Planning and design phase ...... 87 9.3.2 Construction Phase...... 88 9.3.3 Operational phase ...... 89 9.4 CONCLUSION...... 89 10 REFERENCES ...... 90

APPENDIX 1: SPECIES LIST’S ...... 91

APPENDIX 2: C.V.’S ...... 97

LIST OF TABLES

Table 1-1: Potential Desktop Rainwater Harvesting ...... 3 Table 1-2: Comparison of alternatives...... 2 Table 3-1: Guidelines for the management of the various categories ...... 12 Table 3-2: The biological indicators of extinction risk as contained in each of the five SANBI criteria 14 Table 3-3: Criteria used for the analysis of the sensitivity of the area...... 18 Table 3-4: Ranking of Evaluation Criteria ...... 21 Table 3-5: Description of significance ratings ...... 23 Table 4-1: Environmental legislation relevant to the proposed development...... 24 Table 5-2: Potential protected tree species found within the study area ...... 46 Table 5-3: Potential alien invasive found within the study area ...... 47 Table 5-4: GKLM SEA Management Guidelines ...... 48 Table 5-5: Summary of GKLM Environmental Guidelines for spatial planning ...... 50 Table 7-1: Criteria used for the analysis of the sensitivity of the proposed development ...... 66 Table 7-2: List of criteria contributing to the sensitivity map ...... 68 Table 8-1: Impact identification ...... 74 Table 8-2: Planning and Design Phase Impact Assessment ...... 75

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Table 8-3: Construction Phase Impact Assessment ...... 78 Table 8-4: Operational Phase Impact Assessment...... 79 Table 8-5: No-Go Alternative Impact Assessment ...... 80 Table 8-6: Cumulative Impact Assessment ...... 81 Table 9-1: Summary of ecological impacts ...... 82 Table 9-2: Summary of the ecological impact assessment significance, pre- and post-mitigation ...... 84 Table 9-3: Summary of the cumulative impact assessment ...... 84 Table 9-4: Summary of the No-Go alternative assessment ...... 85

LIST OF FIGURES

Figure 1-1: Locality map and site plan ...... 2 Figure 1-2: Proposed service infrastructure ...... 3 Figure 1-3: Proposed underground water reticulation network (yellow lines) ...... 5 Figure 1-4: Proposed underground sewage reticulation network (purple lines) ...... 6 Figure 1-5: Proposed access road from the R349 (yellow line)...... 7 Figure 1-6: Proposed internal road structure ...... 8 Figure 1-7: Proposed internal electrical reticulation (underground cabling: white lines) ...... 9 Figure 3-1: The SA Red List system categorizes species according to their risk of extinction (Source: SA Red Data Guidelines)...... 12 Figure 3-2: The HGM types for South African Inland wetlands (SANBI, 2009)...... 17 Figure 5-1: Average rainfall and temperatures for the study area over a 12-month period...... 31 Figure 5-2: Elevation of the study area shown in a north to south direction ...... 31 Figure 5-3: Elevation of the study area shown in an east to west direction ...... 31 Figure 5-4: Geology of the study area ...... 32 Figure 5-5: Vegetation of the study area...... 34 Figure 5-6: NFEPA Rivers and wetlands associated within the study area...... 37 Figure 5-8: Land use map of the study area ...... 39 Figure 5-8: STEP Map (study area circled in red) ...... 40 Figure 5-9: Critical Biodiversity Area assessment of the study area, as per the ECBCP (2007)...... 44 Figure 5-10: NEMBA Threatened Ecosystems ...... 45 Figure 5-11: Protected Areas and Expansion Areas within and in close proximity to the study area .. 46 Figure 6-1: Focus areas during the site investigation ...... 52 Figure 7-1: Sensitivity map of the study area ...... 71

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1 INTRODUCTION

Appendix 6: Specialist Reports

1. (1) A specialist report prepared in terms of these Regulations must contain—

(c) an indication of the scope of, and the purpose for which, the report was prepared;

(cA) an indication of the quality and age of base data used for the specialist report;

(d) the duration, date and season of the site investigation and the relevance of the season to the outcome of the assessment;

(i) a description of any assumptions made and any uncertainties or gaps in knowledge;

(o) a description of any consultation process that was undertaken during the course of preparing the specialist report;

(p) a summary and copies of any comments received during any consultation process and where applicable all responses thereto; and

(q) any other information requested by the competent authority.

1.1 PROJECT LOCATION

The proposed development is located 7km from the coastal village of Kei Mouth in the Eastern Cape Province. The proposed development falls under the overall jurisdiction of the Amathole District Municipality and the Great Kei Local Municipality (refer to Figure 1-1 below).

1.2 PROJECT DESCRIPTION

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

The proposed development will have the following activities:

• The consolidation, subdivision and rezoning of the 3 farms totalling about 599.2 Ha; • The subdivision of portions of the consolidated area into approximately 68 erven (based on 1 unit per 10 Ha as recommended by the Great Kei Spatial Development Framework) and the rezoning of the 68 erven to Resort and Special Zone: Rural Residential; • Holiday housing (development footprint of 4.6 Ha);

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• Lodge and chalets (development footprint of 0.52 Ha); • Service area (development footprint of 0.1 Ha); and • Remaining area (approximately 577.1 Ha) to remain as agriculture but managed as a game farm.

The associated proposed activities include:

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

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

Figure 1-1: Locality map and site plan

1.3 INFRASTRUCTURE:

Figure 1-2 below provides an overview of the proposed service infrastructure required for the development.

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Figure 1-2: Proposed service infrastructure

1.3.1 Bulk water supply

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

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

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

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

Table 1-1: Potential Desktop Rainwater Harvesting Unit No Assumed Rainfall (m) Efficiency Potential Roof Area Harvest (m²) (kl/annum)

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Dwelling 50 15,000 0,412 95% 5870

Lodges 2 3000 0.412 95% 1175

Recreational Facility 1 1500 0.412 95% 585

• Earth Dams: Two potential dam sites have been identified. The combined potential yield of these dams will be 55000 kl taking into account losses due to evaporation. Water from the dams will be pumped to the reservoir for storage and treatment. • Reservoirs: Two separate reservoirs are proposed to be used for 1) potable water abstracted from the dams, and for 2) fire-fighting and irrigation to be supplied by the dams. The potable water reservoir will have a 2-day volume of 160 kl with a design flow of 0.93 l/s based on the Guidelines for Human Settlement Planning and Design. The fire fighting and irrigation reservoir will have a 2-hour volume of 110 kl with a design flow of 15 l/s. • Water treatment: Water abstracted from the dams will need to be treated prior to domestic use.

The primary source of water supply for the development will be abstraction from the proposed dams and rainwater harvesting (as per Figure 1-3 below). Should boreholes be required for the development, the applicable site investigations and water use licensing applications will be required to be submitted the relevant authority.

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Figure 1-3: Proposed underground water reticulation network (yellow lines)

1.3.2 Bulk sewage:

The effluent generated by the proposed site is estimated at 2.74 l/s, or 82 kl/day (30 000 kl/annum). There is currently no nearby wastewater treatment works in the area. The preferred option is to treat the effluent generated by the development via a package plant. A possible alternative to this would be to provide conservancy tanks.

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

Refer to Figure 1-4 below for the proposed sewer reticulation layout (purple lines).

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Package plant

Figure 1-4: Proposed underground sewage reticulation network (purple lines)

1.3.3 Solid Waste

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

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

The internal collection service, including the nature of the service and its frequency, could be customised in accordance with the home owner’s association requirements. The frequency of the service should be at least once a week. However, the local transfer station must have sufficient capacity to temporarily store waste for a maximum period of 14 days (2 weeks) to allow for possible disruptions in the regular service. The development will be expected to comply with the requirement of the ADM and the GKLM.

1.3.4 Road access

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

The access road from the R349 to the boundary of the development will need upgrading (refer to the yellow line in Figure 1-5 below). Application to the Provincial Road authority will need to be made and the roadway will be designed and constructed to the applicable road standard for the class of access road required.

Internal roadways within the development will be reinforced concrete strip roads (Figure 1-6). The roads will generally follow the existing ground contours and will therefore offer a minimal footprint as no major road earthwork operations are envisaged.

Figure 1-5: Proposed access road from the R349 (yellow line).

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Figure 1-6: Proposed internal road structure

1.3.5 Electrical

The village of Kei Mouth is supplied by an existing 22kVa Eskom power line. The route of this power line follows the MR00697 access road to Kei Mouth. Eskom have provided a connection together with a transformer from this power line to farm 77 of the Farm Rocky Ridge. All internal reticulation will be via underground cabling. Refer to Figure 1-7 for the proposed layout of the internal electrical reticulation (white lines).

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

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Figure 1-7: Proposed internal electrical reticulation (underground cabling: white lines)

1.3.6 Telecommunication

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

1.3.7 Stormwater

Stormwater runoff will be overland and conveyed by a system of natural tributaries all discharging into the Great Kei River.

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

Any streams that need to be crossed will be done using precast concrete culverts designed to accommodate the 1 in 50-year flood event.

1.3.8 Land-use zoning

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The study area is currently managed as a private game and nature reserve and has not been developed. It is currently zoned as Agriculture. The zoning of the study area will largely remain as Agriculture (managed as a game farm), with the addition of Resort Zone 2 (Holiday housing and Resort Hotel/Lodge) and Special Zone (roadways and service infrastructure), as detailed below:

1.4 ALTERNATIVES

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Table 1-2 below provides a summary of the alternatives assessed.

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Table 1-2: Comparison of alternatives.

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

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

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proposed development, which has since lapsed.

Alternative Location N/A N/A N/A N/A Alternative locations for 2 - None identified the project will not be assessed as the applicant is the land owner, and therefore the proposed site is the only land available to the applicant for the proposed development. Incremental Alternative • Low maintenance costs. • Risk of bad odour NO NO Poor percolation rates in alternative - Sewerage • Simple and easy to on site. the development area do Technology alternative Technology 1 – septic operate • Possibility of soil not recommend for tank system contamination and septic tanks systems to overflowing is not be used. maintained well. • Susceptible to clogging by fats/oils, etc. thrown down drains. • Poor percolation rates in the area would result in the inadequate sewage treatment. Alternative • Lower odour risk • More complex and YES YES A package plant system is Sewerage • Lower risk of pollution. higher the preferred sewage

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Technology 2 – • Produces purified re- maintenance treatment alternative for commercially usable water which costs. the proposed supplied packaged complies with • Risk of pollution to development. plant system. responsible disposal surrounding requirements and environment is not satisfies limits for maintained. discharge to the environment.

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

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1.5 TERMS OF REFERENCE

The main objective of this report is to assess the terrestrial ecological environment as well as the potential impact that the proposed development may have on the terrestrial habitat.

The following terms of reference were used for the objectives of this study:

• Describe the study area in terms of land cover and terrestrial habitat. This will include a full desktop analysis on the fauna and flora. • Review relevant legislation, policies, guidelines and standards. • Conduct a site survey to determine the actual ecological state of the study area and identify any species of conservation concern. • This aspect of the report will specifically include the identification of the below in terms of fauna and flora - o Areas of high biodiversity; o The presence of species of conservation concern, including sensitive, endemic and protected species; o The presence of areas sensitive to invasion by alien species; and o The presence of conservation areas and sensitive habitats where disturbance should be avoided or minimised. • Produce a sensitivity map that illustrates areas with significant developmental constraints. • Describe the likely scope, scale and significance of direct and indirect positive and negative impacts resulting from the proposed development both on the footprint and the immediate surrounding area during construction and operation as well as the no-go option. • Provide a detailed description of appropriate mitigation measures that can be adopted to reduce negative impacts for each phase of the project, where required • Identify any need for future permitting. [NB: It is not the purpose of the studies to comply with or apply for any permitting requirements at this stage.]

1.6 APPROACH

The study site and surrounding areas were assessed using a two-phased approach. Firstly, a desktop and baseline assessment of the project area was conducted in terms of current vegetation classifications and biodiversity programmes and plans. For the terrestrial fauna and flora, the consideration of the following has been included:

• Council for Geoscience (2013) South African Geology; • Soil and Terrain (SOTER) Database of South Africa (2008); • The South African Vegetation Map (Mucina and Rutherford, 2012); • National Protected Areas Expansion Strategy (NPAES); • National Environmental Management: Biodiversity Act (NEMBA), 2004: List of Threatened Ecosystems (2011); and • Eastern Cape Biodiversity Conservation Plan (ECPCP).

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A site visit was conducted on 6 December 2018. The site visit was used to identify potential impacts of the proposed development on the surrounding environment and to inform the significance of the potential impacts identified.

1.7 ASSUMPTIONS AND LIMITATIONS

This report is based on the information available at the time of compiling the report and, as a result, is subject to the following assumptions and limitations:

• The report is based on the project description and the site layout provided to CES by the applicant; • Descriptions of the natural and social environments are based on limited fieldwork and available literature; • The report is pre-dominantly based on a combination of desktop and on-site analysis; • It should be emphasised that information, as presented in this document, only has reference to the study area as indicated on the project maps. Therefore, this information cannot be applied to any other area without a detailed investigation being undertaken.

1.8 PUBLIC CONSULTATION

The Public Participation Process (PPP) followed to date has been described in detail in the Draft Basic Assessment Report (DBAR). The DBAR will be made available for a 30-day public review period, and all comments and issues received during this PPP will be included in the Final reports. All proof and correspondence to date will be available in the DBAR and Final BAR.

No comments have been received to date that relates to the ecological environment. Any comments received on the Draft Ecological Report will be included in the Final Ecological Report and Final BAR.

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2 PROJECT TEAM

Appendix 6: Specialist Reports

1. (1) A specialist report prepared in terms of these Regulations must contain—

(a) details of—

(i) the specialist who prepared the report; and

(ii) the expertise of that specialist to compile a specialist report including a curriculum vitae;

(b) a declaration that the specialist is independent in a form as may be specified by the competent authority;

2.1 DETAILS OF THE SPECIALIST

2.1.1 Ms Caryn Clarke (Cand. Nat. Sci - Report Writer)

Caryn holds a M.Sc. degree in Environmental Science from Rhodes University. Her Master’s dissertation investigated climate change adaptation strategies of vulnerable rural households in Willowvale and Lesseyton, Eastern Cape. Her professional interests include climate change policy, renewable energy and various environmental impact assessments. Caryn has worked on numerous basic assessments projects including various linear developments such as roads and pipelines. She has extensive public participation and stakeholder engagement experience. Caryn is a registered Candidate Natural Scientist under the South African Council for Natural Scientific Professions (SACNASP; No: 500022/14).

2.1.2 Dr Greer Hawley (Pri. Nat. Sci. – Ecologist and Report Reviewer)

Dr Greer Hawley-McMaster has a B.Sc. degree in Botany and Zoology, a BSc (Honours) in Botany from the University of Cape Town and a PhD (Microbiology) from Rhodes University. Greer has a diverse skill set including biodiversity surveys and assessments (plants, fungi and terrestrial ecosystems), developing environmental management policy (EMP’s and EMF’s), analysis and interpretation of environmental and biodiversity spatial datasets, training, feasibility assessments, environmental impact assessments for a wide range of land use activity proposals, aquaculture feasibility assessments, alien invasive management planning and conservation management planning. Greer has undertaken work in a number of African countries and has specifically surveyed many parts of the Eastern Cape. As a Principal Consultant, Greer manages large projects and has experience with co- ordinating big specialist teams. Greer has recently completed the review of the Eastern Cape Biodiversity Conservation Plan (2019) and continues to develop the Eastern Cape Biodiversity strategy and Action Plan.

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2.1.3 Dr Alan Carter (Pri. Nat. Sci. – Review and Quality Control)

Alan is the executive of the EOH 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’ 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).

CURRICULUM VITEA CAN BE FOUND IN APPENDIX 2

2.2 DECLARATIONS

Role on Study Declaration of independence Team Report • I, Caryn Clarke, declare that, in terms of the National Environmental production Management Act, 1998 (Act No. 107 of 1998), as amended, and the Environmental Impact Assessment Regulations, 2014, as amended; • I act as the independent specialist in this application; • I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant; • I declare that there are no circumstances that may compromise my objectivity in performing such work; • I have expertise in conducting the specialist report relevant to this application, including knowledge of the Act, Regulations and any guidelines that have relevance to the proposed activity; • I will comply with the Act, Regulations and all other applicable legislation; • I have no, and will not engage in, conflicting interests in the undertaking of the activity; • I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority; • All the particulars furnished by me in this report are true and correct; and • I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of the Act. Report • I, Greer Hawley, declare that, in terms of the National Environmental Reviewer Management Act, 1998 (Act No. 107 of 1998), as amended, and the Environmental Impact Assessment Regulations, 2014, as amended; • I act as the independent specialist in this application; • I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;

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• I declare that there are no circumstances that may compromise my objectivity in performing such work; • I have expertise in conducting the specialist report relevant to this application, including knowledge of the Act, Regulations and any guidelines that have relevance to the proposed activity; • I will comply with the Act, Regulations and all other applicable legislation; • I have no, and will not engage in, conflicting interests in the undertaking of the activity; • I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority; • All the particulars furnished by me in this report are true and correct; and • I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of the Act. Report Final • I, Alan Carter, declare that, in terms of the National Environmental sign-off Management Act, 1998 (Act No. 107 of 1998), as amended, and the Environmental Impact Assessment Regulations, 2014, as amended; • I act as the independent specialist in this application; • I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant; • I declare that there are no circumstances that may compromise my objectivity in performing such work; • I have expertise in conducting the specialist report relevant to this application, including knowledge of the Act, Regulations and any guidelines that have relevance to the proposed activity; • I will comply with the Act, Regulations and all other applicable legislation; • I have no, and will not engage in, conflicting interests in the undertaking of the activity; • I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority; • All the particulars furnished by me in this report are true and correct; and • I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of the Act.

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3 ASSESSMENT METHODOLOGY

Appendix 6: Specialist Reports

1. (1) A specialist report prepared in terms of these Regulations must contain—

(e) a description of the methodology adopted in preparing the report or carrying out the specialised process inclusive of equipment and modelling used;

The aim of this assessment is to identify areas of ecological importance and to evaluate these in terms of their conservation importance. In order to do so, the ecological sensitivity of the area is assessed as well as an identification of potential plant and animal Species of Conservation Concern (SCC) that may occur in habitats present in the area. To a large extent, the condition and sensitivity of the vegetation will also determine areas with high biodiversity. This study also aims at identifying areas of high sensitivity and those that may be subject to significant impacts from the project.

The approach to determining the vegetation sensitivity of the study area is described below. Zones of low, moderate and high sensitive areas were identified by the presence or lack of the following:

• Degree of disturbance and transformation • Presence of plant and faunal species of conservation concern. • Vegetation types (which also constitute faunal habitats) of conservation concern. • Areas of high biodiversity. • The presence of important process areas such as: o Ecological corridors o Topographical features (especially steep and rocky slopes that provide niche habitats for both plants and animals)

A Geographical Information System (GIS) map was then drawn up depicting the different zones of sensitivity using available aerial imagery and relating this to the information gathered from the field survey.

It is not the aim of this study to produce a complete list of all plant species occurring in the region, but rather to examine a representative sample. It is however, important to note that areas of high sensitivity as well as SCC have been identified as far as possible, either from records from the site or a review of their habitat requirements, and whether or not these habitats occur within the site.

3.1 SPECIES OF CONSERVATION CONCERN

Data on the known distribution and conservation status for each potential plant SCC needs to be obtained in order to develop a list of SCCs. These plant species are those that are subject to significant impacts from the proposed activity. In general, these will be species that are already known to be

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threatened or at risk. Efforts to provide the conservation status (‘red list’ status) of individual species may provide additional valuable information on SCC (see http://www.iucnredlist.org/). SCC have been identified by means of a combination of applicable legislation, guidelines and conservation status lists. The following lists were utilised to cross reference conservation and protection statuses of various species:

• National Environmental Management: Biodiversity Act (No. 10 of 2004) - Chapter 4, Part 2; • Endangered and Protected Flora in the 1974 Provincial Nature Conservation Ordinance (PNCO) – Schedule 3 and 4; • 1976 List of Protected Trees (Government Gazette No. 9542 Schedule A) in the 1998 National Forest Act (NFA) as amended in November 2014; and • SA Red Data List.

The South African Red Data List of plants use the internationally recognised IUCN Red List Categories and Criteria to measure a species risk of extinction (Figure 3-1). Since the Red List of South African plants are used widely for conservation practices throughout South Africa, this list has been modified to identify species that are at low risk of extinction but of high conservation importance.

Species that are afforded special protection, which are protected by CITES (Convention on International Trade in Endangered Species of Wild Flora and Fauna) are also regarded as SCC (see http://www.cites.org/).

3.1.1 Definitions:

The South African (SA) Red List system contains nine categories, with the main purpose of classifying species from lowest (Least Concern) to highest (Critically Endangered) threat in terms of risk of extinction (see Figure 3-1). Species that are at high risk of extinction are placed in one of three categories: Vulnerable (VU), Endangered (EN) or Critically Endangered (CR). If a species is classified into one of these three categories, it is considered as a SCC.

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Figure 3-1: The SA Red List system categorizes species according to their risk of extinction (Source: SA Red Data Guidelines).

A species’ classification is guided by five criteria relating to different biological factors that indicate danger of extinction. A species should always be evaluated against all five criteria, but available data only need to meet the requirements for at least one criterion in order to classify a species as threatened. A species is always classified in the highest category of threat for which it meets the quantitative thresholds of at least one criterion.

The following management guidelines for threatened species are provided in Table 3-1 below (Source: SA Red Data Guidelines):

Table 3-1: Guidelines for the management of the various categories STATUS CRITERION* GUIDELINES FOR RECOMMENDATION a Please notify the Threatened Species Programme immediately and provide details of the location, size and threats to the subpopulation. The fact that a subpopulation of the species was found at a site zoned for development means that its Red List status has to be reviewed and is likely to be upgraded. * Refer to Table 2.2 for criteria descriptions No further loss of natural habitat should be permitted as the species is on the brink aCritically of extinction, and all other known subpopulations have been lost. The E Endangered subpopulation in question is likely to be newly discovered and the only remaining subpopulation of this species. Critically No further loss of natural habitat should be permitted as the species is on the A,B,C,D Endangered verge of extinction.

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STATUS CRITERION* GUIDELINES FOR RECOMMENDATION No further loss of habitat should be permitted as the species is likely to go extinct Endangered B,C,D in the near future if current pressures continue. All remaining subpopulations have to be conserved if this species is to survive in the long term. If the species has a restricted range (< 2 000 km2), recommend no further loss of habitat. If range size is larger, the species is possibly long- lived but widespread, and limited habitat loss may be considered under certain circumstances, such as the implementation of an offset whereby another viable, known subpopulation is Endangered A formally conserved in terms of the National Environmental Management: Protected Areas Act (Act 57 of 2003), and provided that the subpopulation to be destroyed does not occur (i) within a threatened ecosystem or (ii) within an area required for biodiversity conservation in terms of a relevant spatial biodiversity plan or (iii) on a site associated with additional ecological sensitivities. This species either constitutes less than 1 000 individuals or is known from a very restricted range. No further loss of habitat should be permitted as the species' aVulnerable D status will immediately become either Critically Endangered or Endangered, should habitat be lost. The species is approaching extinction but there are still a number of Vulnerable B,C subpopulations in existence. Recommend no further loss of habitat as this will increase the extinction risk of the species. If the species has a restricted range, < 2 000 km2, recommend no further loss of habitat. If range size is larger, the species is possibly long-lived but widespread, and limited habitat loss may be considered under certain circumstances, such as the implementation of an offset whereby another viable, known subpopulation is Vulnerable A formally conserved in terms of the Protected Areas Act, and provided that the subpopulation to be destroyed does not occur (i) within a threatened ecosystem or (ii) within an area required for biodiversity conservation in terms of a relevant spatial biodiversity plan or (iii) on a site associated with additional ecological sensitivities. This species is very poorly known, with insufficient information on its habitat, population status or distribution to assess it. However, it is highly likely to be threatened. If a Data Deficient species will be affected by a proposed activity, the aData Deficient D subpopulation should be well surveyed and the data sent to the Threatened Species Programme. The species will be reassessed and the new status of the species, with a recommendation, will be provided within a short timeframe. There is uncertainty regarding the taxonomic status of this species, but it is likely to be threatened. Contact the taxonomist working on this group to resolve its Data Deficient taxonomic status; the species will then be reassessed by the Threatened Species Programme. Currently known from fewer than 10 locations, therefore preferably recommend no loss of habitat. Should loss of this species' habitat be considered, then an offset that includes conserving another viable subpopulation (in terms of the Protected aNear D Areas Act) should be implemented, provided that the subpopulation to be Threatened destroyed does not occur (i) within a threatened ecosystem or (ii) within an area required for biodiversity conservation in terms of a relevant spatial biodiversity plan or (iii) on a site associated with additional ecological sensitivities.

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STATUS CRITERION* GUIDELINES FOR RECOMMENDATION The species is approaching thresholds for listing as threatened but there are still a number of subpopulations in existence and therefore there is need to minimise Near loss of habitat. Conservation of subpopulations is essential if they occur (i) within B,C Threatened a threatened ecosystem or (ii) within an area required for biodiversity conservation in terms of a relevant spatial biodiversity plan or (iii) on a site associated with additional ecological sensitivities. If the species has a restricted range, < 2 000 km2, then recommend no further loss of habitat. If range size is larger, the species is possibly long-lived but widespread, and limited habitat loss may be considered. Conservation of subpopulations is Near A essential if they occur (i) within a threatened ecosystem or (ii) within an area Threatened required for biodiversity conservation in terms of a relevant biodiversity conservation plan or (iii) on a site associated with additional ecological sensitivities. This is a highly range-restricted species, known from a single site, and therefore no loss of habitat should be permitted as it may lead to extinction of the species. aCritically Rare The Threatened Species Programme is not aware of any current threats to this species and should be notified without delay. The species is likely to have a restricted range, or be highly habitat specific, or have small numbers of individuals, all of which makes it vulnerable to extinction should aRare it lose habitat. Recommend no loss of habitat. The Threatened Species Programme is not aware of any current threats to this species and should be notified without delay. The species is declining but the population has not yet reached a threshold of concern; limited loss of habitat may be permitted. Should the species is known to Declining be used for traditional medicine and if individuals will not be conserved in situ, plants should be rescued and used as mother stock for medicinal plant cultivation programmes.

Table 3-2: The biological indicators of extinction risk as contained in each of the five SANBI criteria

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3.2 VEGETATION MAPPING

Mucina and Rutherford (2012 and updated in 2018) developed the National Vegetation map as part of a South African National Biodiversity Institute (SANBI) funded project: “It was compiled in order to provide floristically based vegetation units of South Africa, Lesotho and Swaziland at a greater level of detail than had been available before.” The map was developed using a wealth of data from several contributors and has allowed for the best national vegetation map to date, the last being that of A Cocks developed over 50 years ago. The SANBI Vegetation Map (herein referred to as the SA Veg Map, 2018) informs finer scale bioregional plans such as in fall STEP. This SA Veg Map (2018) project has two main aims:

• to determine the variation in and units of southern African vegetation based on the analysis and synthesis of data from vegetation studies throughout the region, and • to compile a vegetation map. The aim of the map was to accurately reflect the distribution and variation on the vegetation and indicate the relationship of the vegetation with the environment. For this reason, the collective expertise of vegetation scientists from universities and state departments were harnessed to make this project as comprehensive as possible.

The map and accompanying book describe each vegetation type in detail, along with the most important species including endemic species and those that are biogeographically important. This is the most comprehensive data for vegetation types in South Africa.

This is compared to actual conditions of vegetation observed onsite during the site assessment through mapping from aerial photographs, satellite images, literature descriptions (e.g. SANBI and ECBCP) and related data gathered on the ground.

The NFEPA programme provides strategic spatial priorities for conserving South Africa’s freshwater ecosystems and supports sustainable use of water resources. These priority areas are called Freshwater Ecosystem Priority Areas, or FEPAs. The system comprises a hierarchical classification process of defining a wetland based on the principles of the hydro-geomorphic (HGM) approach at higher levels, with structural features being included at the finer levels (SANBI, 2009).

3.3 RIVER AND WETLAND ASSESSMENT

Wetland ecosystem types were used by National Freshwater Ecosystem Priority Areas (NFEPA) for representing natural examples of the diversity of wetland ecosystem types across South Africa. Wetlands of the same ecosystem type are expected to share similar functionality and ecological characteristics. The biodiversity target for freshwater ecosystems in South Africa is 20%, which means that we should keep at least 20% of each wetland ecosystem type in a natural or near-natural condition. This serves to conserve many common species and communities, and the habitats in which they evolve. Information used to classify wetlands as FEPAs included:

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• Ramsar status; • Known threatened frog and waterbird occurrences; and • Expert knowledge on biodiversity importance.

For the purposes of this study Version 4 of the National Wetland Classification System (NWCS) was used as baseline information, as per SANBI’s BGIS interactive tool.

The NWCS uses hydrological and geomorphological traits to distinguish the direct factors that influence wetland function. This is presented as a 6-tiered structure with four spatially nested primary levels that are applied in a hierarchical manner between different wetland types on the basis of these direct factors (SANBI, 2009).

• Level 1: Distinguishes between marine, estuarine and inland ecosystems based on the degree of connectivity the systems have with the ocean; • Level 2: Categorises the regional wetland setting using a combination of biophysical attributes at the landscape level; • Level 3: Assesses the topographical position of inland wetlands; and • Level 4: Concerns the hydrogeomorphic (HGM) units as defined as follows: o Landform - considering the shape and localised setting of the wetland; o Hydrological characteristics - nature of water movement into, through and out of the wetland; and o Hydrodynamics - the direction and strength of flow through the wetland.

The HGM unit is considered the focal point for NWCS as the upper levels mean to classify the broad bio-geographical context for grouping functional wetland units at the HGM level, whilst the lower levels provide more descriptive detail.

As wetlands are formed under the influence of geology, hydrology and topography it is necessary to note these features when delineating a wetland.

• Geology: Geology influences the formation of a wetland by geological obstructions such as erosion resistant rock or impervious material close to the surface forcing groundwater to move close to or onto the soil surface; • Hydrology: The water transfer mechanisms such as source, movement and exit are important features of a wetland; and • Topography: The topography of the landscape influences the likelihood of whether a wetland will form. For instance, under the right conditions, wetlands may form in floodplains, valley bottoms, hillslopes, depressions and coastal flats.

A range of ‘hydro-geomorphic’ types can be defined by considering the above features. Six HGM units are defined for South African inland wetlands (SANBI, 2009):

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Figure 3-2: The HGM types for South African Inland wetlands (SANBI, 2009).

Important rivers are also classified according to the NFEPA rivers maps. These rivers are considered Freshwater Ecosystem Priority Areas (FEPAs). FEPAs are strategic spatial priorities for conserving freshwater ecosystems and supporting sustainable use of water resources. FEPAs are an essential part of an equitable and sustainable water resource strategy meaning that they need to stay in a good condition to manage and conserve freshwater ecosystems, and to protect water resources for human use. This means that the areas should be supported by good planning, decision-making and management to ensure that human use does not impact on the aquatic ecosystem.

3.4 BIODIVERSITY AND CONSERVATION PLANNING INITIATIVES

A key component of the current approach was to assess current biodiversity and ecological planning initiatives and management recommendations relative to the current proposed development, particularly including the following:

• The National Environmental Management: Biodiversity Act, (Act No. 10 OF 2004) (NEM:BA) provides a National List of Ecosystems that are threatened and in need of protection – GN 1002 of 2011; • Subtropical Thicket Ecosystem Plan (STEP); • Eastern Cape Biodiversity Conservation Plan (ECBCP); • South African National Botanical Institute (SANBI) report; • Great Kei Municipality Spatial Development Framework (SDF); and • Great Kei Municipality Strategic Environmental Assessment (SEA).

These are assessed in detail in section 5.9 below.

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3.5 SENSITIVITY ASSESSMENT

The sensitivity assessment approach entails identifying zones of high, moderate and low sensitivity according to a system developed by CES and used in numerous ecological studies.

It must be noted that the sensitivity zonings in this study are based solely on ecological characteristics and social and economic factors have not been taken into consideration. The sensitivity analysis described here is based on 11 criteria which are considered to be of importance in determining ecosystem and landscape sensitivity. The method predominantly involves identifying sensitive vegetation or habitat types, topography and land transformation, biodiversity patterns (hotspots) and biodiversity process areas (ecological infrastructure and corridors) (Table 3-3).

Although very simple, this method of analysis provides a good, yet conservative and precautionary assessment of the ecological sensitivity.

Table 3-3: Criteria used for the analysis of the sensitivity of the area. CRITERIA LOW SENSITIVITY MODERATE SENSITIVITY HIGH SENSITIVITY 1 Topography Level or even Undulating; fairly steep Complex and uneven slopes with steep slopes 2 Vegetation - Extensive Restricted to a particular Restricted to a specific Extent or habitat region / zone locality / site type in the region 3 Conservation Well conserved Not well conserved, Not conserved - has a status of fauna / independent of moderate conservation high conservation value flora or habitats conservation value value 4 Species of None, although No endangered or One or more special concern occasional vulnerable species, some endangered and - Presence and regional endemics indeterminate or rare vulnerable species, or number endemics more than 2 endemics or rare species 5 Habitat Extensive areas of Reasonably extensive Limited areas of this fragmentation preferred habitat areas of preferred habitat habitat, susceptible to leading to loss of present elsewhere and habitat fragmentation viable elsewhere in susceptible to populations region not fragmentation susceptible to fragmentation 6 Biodiversity Low diversity or Moderate diversity, and High species diversity, contribution species richness moderately high species complex plant and richness animal communities

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CRITERIA LOW SENSITIVITY MODERATE SENSITIVITY HIGH SENSITIVITY 7 Erosion Very stable and an Some possibility of Large possibility of potential or area not erosion or change due to erosion change to the instability of the subjected to episodic events site or destruction due region erosion to climatic or other factors

8 Rehabilitation Site is easily There is some degree of Site is difficult to potential of the rehabilitated difficulty in rehabilitation rehabilitate due to the area or region of the site terrain, type of habitat or species required to reintroduce 9 Disturbance due Site is very There is some degree of The site is hardly or very to human disturbed or disturbance of the site slightly impacted upon habitation or degraded by human disturbance other influences (alien invasive species) 10 Ecological Low ecological N/A High ecological function. function in the function. No (There are NO moderate Portions of entire landscape corridors or niche ecological functions. It is sections of the site (corridor, niche habitats considered either high or contains corridors or habitats) low) niche habitats 11 Ecological Low to no Some sections of the site Most of the site contains services (food, ecological services contain ecological services ecological services water filter, on site grazing, etc.)

A sensitivity map was developed with the aid of a satellite image so that the sensitive regions and vegetation types could be plotted (see Chapter 7). The following was also taken into account:

• Protected Areas: The National Environmental Management Protected Areas Act (Act No 57 of 2003; NEMPAA) was developed to provide for the protection and conservation of ecologically viable areas representative of South Africa’s biological diversity and its natural landscapes and seascapes. All protected areas within 10 km of the study site were listed. Impacts were identified, and mitigations proposed. The goal of the National Protected Areas Expansion Strategy (NPAES) is to achieve cost-effective protected area expansion for ecological sustainability and increased resilience to climate change. It sets targets for protected area expansion, provides maps of the most important areas for protected area expansion, and makes recommendations on mechanisms for protected area expansion. The NPAES has classified protected areas into three categories: formally protected areas, informally protected areas and focus areas. Focus areas are large, intact and unfragmented areas suitable for the creation or expansion of large protected areas.

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• Biodiversity and Conservation Planning Initiatives: Sensitive areas identified in biodiversity and conservation planning initiatives, as detailed in section 3.4 above.

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3.6 IMPACT RATING METHODOLOGY

CES has developed an evaluation criterion of 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 3-4 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 3-5). • 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.

When considering the final impact significance rating, the following criteria are considered in order to determine the post-mitigation impact significance rating:

• 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 3-4 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 3-4: 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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Indirect Impacts on the environment that are not a direct result of the project or 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 The resource will not be lost/destroyed provided mitigation measures are Resource will not be lost implemented. Resource will be partly The resource will be partially destroyed even though mitigation measures are lost implemented. Resource will be lost The resource will be lost despite the implementation of mitigation measures. MITIGATION POTENTIAL Easily achievable The impact can be easily, effectively and cost effectively mitigated/reversed. Achievable The impact can be effectively mitigated/reversed without much difficulty or cost. The impact could be mitigated/reversed but there will be some difficultly in Difficult ensuring effectiveness and/or implementation, and significant costs. The impact could be mitigated/reversed but it would be very difficult to ensure Very Difficult effectiveness, technically very challenging and financially very costly.

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Table 3-5: 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 are insufficient, even in combination with other low LOW LOW impacts, to prevent the development being approved. Impacts NEGATIVE POSITIVE 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 MODERATE MODERATE conjunction with other issues with moderate impacts, prevent its NEGATIVE POSITIVE implementation. Impacts 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 HIGH HIGH impact). Impacts on this particular issue would be considered by NEGATIVE POSITIVE society as 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.

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4 RELEVANT LEGISLATION

Environmental legislation relevant to the proposed development is summarised in Table 4-1 below. Biodiversity plans and programmes are discussed in Chapter 5, section 5.9, where they are used to describe the desktop ecological conditions of the study area.

Table 4-1: Environmental legislation relevant to the proposed development

ENVIRONMENTAL IMPLICATIONS FOR THE PROPOSED DEVELOPMENT LEGISLATION

Constitution Act This is the supreme law of the land. As a result, all laws, including those pertaining to the proposed development, must conform to the (Act No. 108 of 1996) 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. 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. (iii) Secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development. National Environmental The applicant must be mindful of the principles, broad liability and implications associated with NEMA and must eliminate or mitigate Management Act (NEMA) (Act any potential impacts. No. 107 of 1998) ECPTA must also be mindful of the principles, broad liability and implications of causing damage to the environment. The applicant must also comply with the EIA Regulations (2014, as amended) in the terms of the Act which specifies when an environmental authorisation is required and the nature of the EIA process.

National Environmental The National Environment Management: Biodiversity Act (No. 10 of 2004) (NEMBA) provides for the management and conservation of Management: Biodiversity Act South Africa’s biodiversity and the protection of species and ecosystems that warrant national protection. The objectives of this Act are (Act No. 10 of 2004) to: a) Provide, within the framework of the National Environmental Management Act;

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ENVIRONMENTAL IMPLICATIONS FOR THE PROPOSED DEVELOPMENT LEGISLATION

b) Manage and conserve of biological diversity within the Republic; and c) Promote the use of indigenous biological resources in a sustainable manner. In addition to this, Sections 50-62 of the Act provide details relating to the protection of threatened or protected ecosystems and species, while Sections 63-77 of the Act provide details relating to alien and invasive species with the purpose of preventing their introduction and spread, managing, controlling and eradicating of alien and invasive species. No protected species may be removed or damaged without a permit. The NEMBA Alien and Invasive The NEMBA Alien and Invasive Species List (Government Notice 599 of 2014) lists Alien and Invasive species that are regulated by the Species List (Government NEMBA Alien and Invasive Species Regulations (Government Notice 98 of 2014). Notice 599 of 2014)

National Forest Act (Act 84 of The NFA provides the legal framework for the protection and sustainable use of South Africa’s indigenous forests. Any area that has 1998) vegetation which is characterised by a closed and contiguous canopy and under storey plant establishment is defined as a ‘forest’ and as a result falls under the authority of the Department of Agriculture, Forestry and Fisheries (DAFF): Forestry sector. A clause in Chapter 3, Part 1 covers:

Prohibition on destruction of trees in natural forests Section 7 (1) No person may cut, disturb, damage or destroy any indigenous living tree in, or remove or receive any such tree from, a natural forest except in terms of (a) a licence issued under subsection (4) or section 23. Prohibition on destruction of protected trees Section 15 (1) No person may cut, disturb, damage or destroy any protected tree or possess, collect, remove, transport, export, purchase, sell, donate, or in any other manner acquire or dispose of any protected tree or any product derived from a protected tree except under a licence or exemption granted by the Minister to an applicant and subject to such period and conditions as may be stipulated. Effect of setting aside protected areas Section 10 (1) No person may cut, disturb, damage or destroy any forest produce in, or remove or receive any forest produce from, a protected area, except— (a) in terms of the rules made for the proper management of the area in terms of section 11(2)(b);

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ENVIRONMENTAL IMPLICATIONS FOR THE PROPOSED DEVELOPMENT LEGISLATION

(b) in the course of the management of the protected area by the responsible organ of State or person; (c) in terms of a right of servitude: (d) in terms of the authority of a licence granted under section 7(4) or 23; (e) in terms of an exemption under section 7(1)(b) or 24(6); or (f) in the case of a protected area on land outside a State forest, with the consent of the registered owner or by reason of another right which allows the person concerned to do so, subject to the prohibition in section 7(1).

No forest or trees that form part of a forest or forest association may be damaged or destroyed without a permit. No protected tree species may be damaged or destroyed without a permit. National Environmental The National Environmental Management: Protected Areas Act (No. 57 of 2003) (NEMPAA) mainly provides for the following: Management: Protected Areas (i) Declaration of nature reserves and determination of the type of reserve declared; Act (NEMPAA) (ii) Cooperative governance in the declaration and management of nature reserves; (Act No. 57 of 2003) (iii) A system of protected areas in order to manage and conserve biodiversity; and (iv) Utilization and participation of local communities in the management of protected areas.

The proposed development is located within a private nature reserve, and not within any provincial or national protected areas. National Water Act The National Water Act (No. 36 of 1998) (NWA) provides for fundamental reform of the law relating to water resources in South (Act No. 36 of 1998) Africa.

The purpose of the Act amongst other things is to: (iii) Ensure that the national water resources are protected, used, developed, conserved, managed and controlled in ways which take into account amongst other factors: o Promoting equitable access to water; o Promoting the efficient, sustainable and beneficial use of water in the public interest; o Facilitating social and economic development; o Protecting aquatic and associated ecosystems and their biological diversity; and o Reducing and preventing pollution and degradation of water resources.

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ENVIRONMENTAL IMPLICATIONS FOR THE PROPOSED DEVELOPMENT LEGISLATION

The NWA is concerned with the overall management, equitable allocation and conservation of water resources in South Africa. To this end, it requires registration of water users and licenses to be obtained for water use except for certain limited instances set out in Section 21 of the Act. These instances include domestic use, certain recreational use, where the use occurs in terms of an existing lawful use or where the Department of Water and Sanitation (DWS) has issued a general authorisation that obviates the need for a permit.

For the purposes of this Act, water uses for which a permit is required (amongst other), are defined in Section 21 as follows: (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 (k) using water for recreational purposes.” National Environmental The purpose of this Act relates to the proper disposal of waste. The Act also provides for the waste related activities where a Waste Management: Waste Act (59 of Licence is required. This includes the recycling and refining of waste. GN R 921 further lists the applicable Waste Management 2008) Activities which details activities that have or are likely to have a detrimental effect on the environment. Conservation of Agricultural The Conservation of Agricultural Resources Act (CARA) aims to control over-utilisation of the natural agricultural resources to Resources Act (Act No. 43 of promote the conservation of soil, water sources and vegetation through the combat of weeds and invader plants. Regulations 15 and 1983)

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ENVIRONMENTAL IMPLICATIONS FOR THE PROPOSED DEVELOPMENT LEGISLATION

16 under this Act, which relate problem plants, were amended in March 2001. The Act provides a list of declared weeds and invader plants as well as indicators of bush encroachment. These lists include: • Combating of category 1 plants (Section 15A) according to CARA (Act No 43 of 1983); and • Combating of category 2 plants (Section 15B) according to CARA (Act No 43 of 1983) In addition, section 6 of the Act makes provisions for control measures to be applied to achieve the objectives of the Act. These measures relate to inter alia: • Cultivation of virgin soil; • Protection of “vleis”, marshes, water courses and water sources; • The regulation of the flow pattern and run-off; • The protection of natural vegetation in the area; and • The restoration or reclamation of land which is eroded or disturbed.

An invasive species monitoring, control and eradication plan for land/activities under their control should be developed as part of the construction environmental plans in accordance with CARA.

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4.1 OTHER RELEVANT POLICY AND PLANS

In addition to the above, the following policy and spatial tools are applicable to the proposed development, and have been assessed in detail in Chapter 5, section 5.9 below.

• The SA Veg Map (SANBI, 2018); • The Subtropical Thicket Ecosystem Programme (STEP); • The Eastern Cape Biodiversity Conservation Plan (ECBCP); • The National Freshwater Ecosystem Priority Areas (NFEPA) project; • GKM Strategic Environmental Assessment (SEA) (2006); and • The Great Kei Local Municipality (GKLM) SDF.

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5 DESCRIPTION OF THE BIOPHYSICAL ENVIRONMENT

The study area and surrounding areas were described using a two-phased approach. Firstly, a desktop assessment of the site was conducted in terms of current vegetation classifications, biodiversity programmes and plans. This was followed by a site visit in order to assess the actual ecological state, current land-use, identify potential sensitive ecosystems and identify plant species associated with the proposed project activities.

5.1 BACKGROUND AND LITERATURE REVIEW

Published literature on the ecology of the area was referenced in order to describe the study site in the context of the region and the Eastern Cape Province. The following applicable documents/plans are included:

• The SA Veg Map (SANBI, 2018); • Council for Geoscience (2013) South African Geology; • Soil and Terrain (SOTER) Database of South Africa (2008); • Eastern Cape Biodiversity Conservation Plan (ECBCP); • National Environmental Management: Biodiversity Act (NEMBA), 2004: List of Threatened Ecosystems (2011); • Review of the SANBI Red Data List; • Convention on International Trade in Endangered Species (CITES), • International Union for Conservation of Nature (IUCN), • National Biodiversity Management: Biodiversity Act (NEMBA) List of Alien Invasive Vegetation; • Department of Agriculture, Forestry and Fisheries (DAFF) List of Protected Trees (2014); • Conservation of Agricultural Resources Act (CARA; 1983), • National Freshwater Ecosystem Priority Areas (NFEPA: 2011-2014); • National Spatial Biodiversity Assessment (NSBA: 2004); and • National Freshwater Ecosystem Priority Areas (2011-2014)

5.2 CLIMATE

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

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

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

092 026 018

13 20 10

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

Figure 5-1: Average rainfall and temperatures for the study area over a 12-month period.

5.3 TOPOGRAPHY, GEOLOGY AND SOILS

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

The elevation of the study area ranges from 6 to about 237 metres above sea level (Figure 5-2 south and Figure 5-3 east-west). The topography of the proposed development area is varied with large flat plateaus that slope gently to the south east. These flatter slopes give way to gently undulating ones around the drainage lines, and steep to very steep slopes in the iCwili River gorge and the Great Kei River gorge.

Figure 5-2: Elevation of the study area shown in a north to south direction

Figure 5-3: Elevation of the study area shown in an east to west direction

The geology of the area is made up of mudstones and sandstones of the Karoo sequence (Figure 5-4). In many cases, these have been intruded by dolerite dykes and sheets. One such dyke runs across the

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property in a south-east to north east direction and is perpendicular to the iCwili River. Dolerite dykes are well known borehole sites (for underground water). With the dyke cutting off the stream it should have excellent recharge potential. The soils are generally moderate to deep clay loams along the coast with undulating relief and moderate to deep sandy loams of undulating relief further inland with steep relief in the vicinity of the Great Kei River. The erodibility index of the soils in the region is recorded as being medium to high.

The Beaufort Group is the geologically dominant group in the district and forms part of the Karoo Supergroup (Figure 5-4). The Beaufort Group is divided into two subgroups, namely the Tarkastad and the Adelaide, which, in turn, can be themselves divided into formations. The Katberg and Balfour formation, make up the geology of this development. The Katberg formation is sandstone rich and is 500 to 1000 mm thick. The sandstone is well lithified and varies in composition from a fine grained, argillaceous variety to a medium coarse grained, arenaceous type. The sandstone is horizontally laminated, cross bedded or massive, and, on average, comprises 90% of the total thickness. The geology is responsible for the soil types and together they influence the runoff coefficient for the dams.

Figure 5-4: Geology of the study area

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5.4 VEGETATION

The following National and Provincial Plans are used to describe vegetation floristics that may potentially occur within the development footprint:

• SANBI classification (Mucina and Rutherford, 2018); and • DAFF Forestry classification.

5.4.1 SANBI Classification (Mucin and Rutherford, 2018).

The vegetation of the study area is shown in (Figure 5-5). According to the South Africa Vegetation Map (SA VEGMAP) (SANBI, 2018), the proposed development footprint falls largely within Bhisho Thornveld, and Hamburg Dune Thicket, and within a small percentage of the Transkei Coastal Belt.

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

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

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

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

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Conservation Status: According to the National Biodiversity Assessment (NBA, 2018), the following ecosystem threat status and conservation targets are applicable:

VEGETATION TYPE ECOSYSTEM THREAT STATUS CONSERVATION TARGET (NBA, 2018) (MUCINA ET AL., 2018)

Transkei Coastal Belt (CB 5) Least Concern 25%

Bisho Thornveld (SVs7) Least Concern 25%

Hamburg Dune Thicket Least Concern 19%

Figure 5-5: Vegetation of the study area.

5.4.2 Forest Classification

No state forests will be impacted by the proposed development. The nearest forest patches are shown in Figure 5-10 below (Transkei Coastal Forest patches -purples areas).

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5.5 FAUNA

The following section provides a detailed overview of the fauna likely to occur within the broader study area. The proposed project area is situated largely within the 3228CB Quarter Degree Square (QDS) area.

5.5.1 Birds

The Animal Demography Unit (ADU) was used to compile this section. Comprehensive species lists have been included in Appendix 2.

The Eastern Cape Province contains 62 threatened bird species, many of which are associated with wetlands or grassland species. There are no Eastern Cape endemic birds’ species, however nine species that occur in the Eastern Cape are endemic to South Africa.

According to Southern African Bird Atlas Project (SABAP 2, 2017), a total of 195 bird species occur within the 3235_2820 QDS. Of these species, three (3) are on the IUCN Red Data list. One (1) bird, the Bucorvus leadbeateri (Southern Ground-hornbill) is listed as vulnerable, and two (2) are listed as endangered (Morus capensis (Cape Gannet), Balearica regulorum (Grey Crowned-crane)).

Threatened species identified by the IUCN Red Data List that may be found in the broader study area (that are not contained in the SABAP 2, 2017 list) include:

• VU - Anthropoides paradiseus (Blue Crane), Bugeranus carunculatus (Wattled Crane), Oxyura maccoa (Maccoa Duck), Sagittarius serpentarius (Secretarybird), Poicephalus robustus (Cape Parrot), and the Polemaetus bellicosus (Martial Eagle); • EN – Gyps coprotheres (Cape Vulture), and Circus maurus (Black Harrier).

None of the above-mentioned threatened species were noted on site during the site visit.

5.5.2 Amphibians and Reptiles

South Africa has 350 species of reptiles, comprising 213 lizards, 9 worm lizards, 105 snakes, 13 terrestrial tortoises, 5 freshwater terrapins, 2 breeding species of sea turtle and 1 crocodile (Branch, 1998). Amphibians and certain reptiles are sensitive to habitat change and are therefore good indicators of land transformation. There are seven threatened and four endemic frog species in the Eastern Cape Province. One species, Heleophryne hewitti, is critically endangered and known from only four rivers in the Elandsberg range. The Province contains 19 threatened reptiles, of which 18 are endemic to Eastern Cape (Eastern Cape State of the Environment Report, 2004).

According to the IUCN Red List, seventy-six (76) Reptiles and twenty-one (21) possible Amphibians are found in the Eastern Cape. Of these, five (5) tortoise, twenty-two (22) snakes, twelve (12) Geckos, eight (8) Skinks and twenty-seven (27) lizard species may occur within the proposed project area.

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5.5.3 Mammals

Large game makes up less than 15% of the mammal species in South Africa and a much smaller percentage in numbers and biomass. In developed and farming areas, this percentage is greatly reduced, with the vast majority of mammals present being small or medium-sized. As a result of past farming of the land, indigenous mammal diversity is restricted.

Rangelands within the broader study area have been transformed to some degree and are largely used as grazing land for livestock (sheep, cattle and goats). The proposed development is to occur within the Great Kei River Private Game and Nature Reserve, therefore, various antelope species are known to occur within the study area.

IUCN Species of Least Concern which may occur within the study area include the Chlorocebus pygerythrus (Vervet Monkey), Canis mesomelas (Black-backed Jackal), and Procavia capensis (Rock Hyrax). The likely IUCN Red List of threatened mammals that may occur within the broader study area include:

• VU - Mystromys albicaudatus (White-tailed Rat); and • EN - Chrysospalax trevelyani (Giant Golden Mole)

None of the above-mentioned threatened species were noted on site during the site visit.

5.6 SURFACE WATER

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

5.6.1 National Freshwater Ecosystem Priority Areas (NFEPA), 2011-2014

The National Freshwater Ecosystem Priority Areas (NFEPA) project provides strategic spatial priorities for conserving South Africa’s freshwater ecosystems and supports sustainable use of water resources. These priority areas are called Freshwater Ecosystem Priority Areas, or ‘FEPAs’. FEPAs were identified based on: • Representation of ecosystem types and flagship free-flowing rivers; • Maintenance of water supply areas in areas with high water yield; • Identification of connected ecosystems; • Representation of threatened and near-threatened fish species and associated migration corridors; and • Preferential identification of FEPAs that overlapped with: o Any free-flowing river; o Priority estuaries identified in the National Biodiversity Assessment 2011; and

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o Existing protected areas and focus areas for protected area expansion identified in the National Protected Area Expansion Strategy.

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

The proposed upgrade of the MN10129 access road to the proposed development will cross the iCwili River , and internal roadways will cross and occur within 32 metres of several tributaries of the Great Kei River, and therefore will require a water use license approval from DWS (see Error! Reference s ource not found. below).

Figure 5-6: NFEPA Rivers and wetlands associated within the study area.

5.6.2 National Biodiversity Assessment (2018)

The National Biodiversity Assessment (NBA, 2018) is the primary tool for monitoring and reporting on the state of biodiversity in South Africa. It is used to inform policies, strategies and actions for managing and conserving biodiversity more effectively. It incorporates the data of the National

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Freshwater Ecosystem Priority Areas (NFEPA) project and the South African Inventory of Inland Aquatic Ecosystems (SAIIAE).

An important tool used in the NBA is conservation status. Conservation status aims at identifying threatened ecosystems and is based on the classification scheme developed by the IUCN to categorise species. Of the 120 rivers in South Africa that have been classified using this categorisation, 44 % are critically endangered, 27 % are endangered, 11 % are vulnerable and 18 % are least threatened.

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

It is recommended that the 1:100-year floodline of the Great Kei River be considered a no-go area, and 50 m buffers are applied to the iCwili River and smaller tributaries within the study area. The buffer areas are considered sensitive areas as they are important drainage areas, comprise of steep slopes susceptible to erosion and are likely to contain vegetation SCC’s. No development (other than authorised service infrastructure and the proposed dams) should occur within these buffer areas.

5.7 GROUNDWATER

The area is characterised by intrusive sills and dolerite dykes. Groundwater is found mainly in these rock matrices and is capable of yielding between 3 – 5 litres per second. The area dissected by two different dykes.

According to the Eastern Cape Water Resource Situation Assessment, groundwater in the area is under-utilised, although about 70% (mostly coastal) is unsuitable for human consumption without desalination.

A total of 5 existing boreholes were tested to determine yields and quality. Based on the results the water was determined to be Class 3 and unsuitable for human consumption without prior treatment. Borehole abstraction is not currently proposed, but may be considered in the future, should the development require it.

5.8 LAND USE

The study area is comprised of the following:

• Degraded cultivated/grazing land; • Degraded thicket and bushland; and • Largely intact thicket and bushland (with some scattered aliens).

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

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Figure 5-7: Land use map of the study area

5.9 BIODIVERSITY PLANNING AND CONSERVATION

5.9.1 Subtropical Thicket Ecosystem Programme (STEP)

The STEP project (now integrated into the SA VEGMAP, 2018) represents a plan to conserve the Thicket Biome (also known as Valley Bushveld or Valley Thicket), which covers an area of close to 42 000 km2 including large areas of the Eastern Cape and Parts of the GKLM. The thicket vegetation type provides for important economic activities in the region and has important ecosystem benefits. The GKLM Strategic Environmental Assessment (SEA) (2006) and SDF make particular reference to the STEP conservation targets and planning guidelines, and therefore, is relevant to the proposed development.

The STEP project resulted in the formulation of Megaconservancy Networks, formed by corridors of land identified as requiring special consideration to ensure sustainability. Areas outside of the Network are also classified based on their conservation status, providing an indication of the need for protection to ensure the retention of biodiversity. Guidelines for appropriate development within the Network and outlying areas are provided below.

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Figure 5-8: STEP Map (study area circled in red)

It can be seen from the map above that portions of the proposed Kei Mouth Eco Estate is located in areas designated as:

• Currently not vulnerable (majority of the development footprint); and • High Priority Conservation Network Area – STEP Kei Megaconservancy Network (thicket area along the Great Kei River).

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High Priority Conservation Network Area:

Concerning the High Priority Conservation Network Area, land can only withstand minimal loss of natural area through disturbance and developments. The following land-use recommendations are applicable:

Land-use Management: 1. As a rule, minimal loss of natural areas and minimal impacts should be allowed. 2. The Municipality should evaluate the site’s condition relative to impacts. 2a) If the site has had severe and extensive impacts, then the Municipality should recommend restoration of the portion of land which will remain undeveloped and its management/proclamation as a nature reserve area; 2b) If the site is relatively undisturbed, with medium to low impacts, then the Municipality should request a Special EIA. 3. For a proposed “listed activity” that by law requires EIA authorisation, the Municipality should recommend a Special EIA.

Restrictions: Minimal loss of natural areas and minimal disturbance should be allowed, and only on condition that there are net gains for the natural environment (e.g. the Municipality should recommend restoration of the portion of land which will remain undeveloped and its management/proclamation as a nature reserve area).

Opportunities: 1. Land in the Network should be subject to minimal loss of, or disturbance to, natural areas. 2. Within constraints (such as avoidance of spoiling scenery or wilderness, or infra-structure limitations), the Network land may be suitable for eco-friendly activities such as sustainable game farming and responsible ecotourism (hiking trails, etc.). 3. In those areas which have undergone severe impacts, this land presents opportunities for IDP projects for restoration.

Currently not vulnerable: Proposed disturbance or developments should preferably take place on portions which have already undergone disturbance or impacts rather than on portions that are undisturbed/undisturbed.

Conclusions: In terms of STEP land use guidelines, majority (90%) of the proposed development is located within an area classified as not vulnerable, and therefore development within this area is allowed, however, should target previously disturbed/impacted areas as much as practically possible. No development will take place within 100 m of the Great Kei River estuarine or riparian zone, and majority of the development will be located within open grassland areas on the tops of ridges, with minimal clearing of thicket vegetation required.

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Development within a STEP Network area should only allow for minimal disturbance/loss of natural areas, and as only 10% (1 Ha) of the entire proposed development footprint is to be located within a portion of the STEP Network area, it can be concluded that the proposed development is in line with the STEP land use guidelines.

5.9.2 Eastern Cape Biodiversity Conservation Plan (ECBCP)

The Eastern Cape Biodiversity Conservation Plan (ECBCP, 2007) attempts to map priority areas for conservation in the province, as well as assign land use categories depending on current conditions of unit areas and conservation targets that need to be achieved (Berliner et al. 2007). ECBCP, although mapped at a finer scale than the National Spatial Biodiversity Assessment is still, for the large part, inaccurate and “coarse” (Driver et al., 2005). Therefore, it is imperative that the status of the environment, for any proposed development MUST first be verified before the management recommendations associated with the ECBCP are considered (Berliner and Desmet, 2007). The ECBCP is currently under review.

The main outputs of the ECBCP are “critical biodiversity areas” or CBAs, which are allocated the following management categories:

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

These management categories are further sub-categorised as follows:

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

The proposed development falls within a CBA 1 Aquatic area (A1 and A2b categories), and a CBA 1 Terrestrial area (T1 and Reserve 2 categories) with the majority of the proposed development being located within a CBA Reserve 2, namely the Great Kei River Private Nature Reserve, which is classified as non-statutory protected area (see Figure 5-11 below).

According to the BLMCs, the area into which the proposed Kei Mouth Eco Estate falls is designated as:

• For terrestrial ecosystems: o Majority of area – BLMC1: Maintain natural state.

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• For aquatic ecosystems: o ABLMC 1: Transformation threshold of less than 10% of total area of sub-quaternary catchment,

Although the ECBCP (2007) does not detail the reasons for the relatively high conservation status of this area, they probably include: • Proximity to the coastline (1 km buffer strip around estuaries); • Incidence and status of water courses; • Undisturbed forests and 500 metre buffers; • Expert input on the area; • Bird populations; and • Important ecological corridors and network areas according to STEP (see previous section).

The proposed development will of the 599.2 Ha of the proposed application area, 577.1 Ha will remain as agricultural land and managed as a game farm, leaving 22.1 Ha remaining for the proposed development. The actual development footprint will, however, be less than 20 Ha as shown in Figure 1.1 above.

Majority of the development footprint, except for authorised routes of the internal roads and service pipelines, will target open grassland areas on the tops of ridges, with minimal clearing of intact thicket vegetation required. It is recommended that the proposed development be located at least 100 m from the 1:100-year floodline of the Great Kei River, to maintain important ecological corridors and network areas, as identified by STEP.

Although the applicable land-use management objective of the area requires that the land be maintained in a natural state, within minimal loss to biodiversity, the proposed development is in line with the STEP and GKLM SDF ‘Limited Development Areas’ land-use guidelines (refer to section 5.9.5 below). The site visit confirmed the study area was previously used for cultivation and livestock grazing, with evidence of disturbance and alien invasive vegetation infestation (decreasing in severity from east to west towards the Great Kei River).

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

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Figure 5-9: Critical Biodiversity Area assessment of the study area, as per the ECBCP (2007).

5.9.3 NEMBA Threatened Ecosystems

A national list of threatened ecosystems in need of protection was published through the National Environmental Management: Biodiversity Act (No. 10 of 2004) (NEMBA) (GN. 1002 of 2011). The proposed development does not fall within a NEMBA threatened ecosystem, as shown by Figure 5-10 below.

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Figure 5-10: NEMBA Threatened Ecosystems

5.9.1 Protected Areas and Expansion Areas

Portions of the proposed Kei Mouth Eco Estate is classified as non-statutory protected areas (Great Kei Game Reserve and Great Kei Private Nature Reserve – owned by the applicant) (see Figure 5-11 below). In addition, the proposed development is located within 5 km of the East London Coast Nature Reserve, Kei Mouth State Reserve, and the Nyara River Mouth to Great Kei River Mouth Marine Protected Area (MPA).

Target areas (focus areas) for expansion of the Protected Area network in South Africa were identified through a systematic biodiversity planning process undertaken as part of the development of the 2008 NPAES, as well as the 2012 provincial Protected Area Expansion Strategy. The proposed development falls within the Bisho Kei Focus Area (Figure 5-11 below).

Having the remaining application area (particularly the portions towards the Great Kei River) proclaimed as a private nature reserve should be considered.

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Figure 5-11: Protected Areas and Expansion Areas within and in close proximity to the study area

5.9.2 Plant Species of Conservation Concern

Plant species of conservation concern (SCC) comprise those species that are either threatened (Critically Endangered, Endangered, Vulnerable), rare or declining. The South African National Biodiversity Institute (SANBI) Plants of Southern Africa (POSA) plant database (http://posa.sanbi.org) was consulted, along with the categories indicated in the SANBI Threatened Species Programme website (http://redlist.sanbi.org/species.php?species) to identify potential SCC’s within the proposed study area.

In addition to SANBI, the international IUCN Red Data list, DAFF protected trees, the Provincial Nature Conservation Ordinance (PNCO), and CITES., was consulted to compile a detailed list of plant SCC’s that may potentially be found within the study area.

Table 5-1 below lists the potential plant SCCs potentially be found within the development footprint. Please refer to Appendix 1 for a detailed list of plant species potentially be found within the development footprint.

Table 5-1: Potential protected tree species found within the study area

GENUS AND SPECIES ENGLISH COMMON NAMES STATUS

Asclepias praemorsa Milkweed SANBI Red List: Least Concern

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GENUS AND SPECIES ENGLISH COMMON NAMES STATUS

PNCO Protected

Catha edulis Bushman's tea SANBI Red List: Least Concern DAFF Protected Tree

Curtisia dentata Assegai SANBI Red List: Near Threatened DAFF Protected Tree

Cynanchum ellipticum Monkey rope SANBI Red List: Least Concern PNCO Protected

Dietes bicolor Yellow wild iris SANBI Red List: Rare PNCO Protected

Mimusops caffra Coastal red milkwood SANBI Red List: Least Concern DAFF Protected Tree

Pittosporum viridiflorum Cheesewood SANBI Red List: Least Concern DAFF Protected Tree

Sideroxylon inerme subsp. inerme White milkwood SANBI Red List: Least Concern DAFF Protected Tree

Umtiza listerana Umtiza SANBI Red List: Vulnerable

All protected species will require a permit prior to their removal, should the proposed development require this.

5.9.3 Alien Invasive Vegetation

Table 5-2 details potential alien invasive vegetation likely to occur within the study area.

Table 5-2: Potential alien invasive found within the study area FAMILY GENUS SPECIES STATUS Araceae Pistia stratiotes - NEMBA Category 1b - CARA: Category 1; Asteraceae Cirsium vulgare - NEMBA – Category 1b Boraginaceae Echium plantagineum - CARA: Category 1; - NEMBA – Category 1b Cactaceae Opuntia Several species - CARA: Category 1; - NEMBA – Category 1b Convolvulaceae Ipomoea indica - CARA: Category 2; - NEMBA – Category 1b Convolvulus arvensis - CARA: Category 1; - NEMBA – Category 1b Fabaceae Acacia mearnsii - NEMBA – Category 2 Acacia longifolia - CARA: Category 1;

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- NEMBA – Category 1b Senna didymobotrya - CARA: Category 1; - NEMBA – Category 1b Myrtaceae Psidium guajava - CARA: Category 2; - NEMBA – Category 3 Solanaceae Cestrum laevigatum - CARA: Category 1; - NEMBA Category 1b Solanum Several species - NEMBA Category 1b Verbenaceae Lantana camara - NEMBA Category 1b

5.9.4 Great Kei Municipality Strategic Environmental Assessment (SEA)

The GKLM Strategic Environmental Assessment (SEA) (2006) identified the following management guidelines that are relevant to the proposed Kei Mouth Eco Estate:

Table 5-3: GKLM SEA Management Guidelines PRIORITY ENVIRONMENTAL MANAGEMENT AND SPATIAL PLANNING IMPLICATIONS AREA Tourism - All tourism projects should be screened for potential environmental impacts. - Tourism projects that require a change of land-use will require an Environmental Impact Assessment in terms of the EIA Regulations. - Tourism projects should capitalize on existing areas of tourism interest and potential before opening up other areas. - The potential for expanding game and nature reserves and other eco- tourism opportunities should be explored. - Ensure alignment with ADM Tourism Route initiative.

Environment - Need to conserve STEP and other conservation worthy and environmentally sensitive areas. - Consider allocating more land to conservation status. - Expand nature reserves.

Other relevant strategic matters have also been identified that are important in promoting sustainable development in GKLM. These include:

• Ensure compliance with relevant legislation and policy. • Increase monitoring and policing of illegal activities, particularly along the coastline. • Generally adhere to conservation principles, particularly the Subtropical Thicket Ecosystem Programme (STEP) conservation targets and planning guidelines (per Biodiversity Act). • Generally promote the conservation of environmental assets. • Development proposals should be linked to provision of sewage infrastructure, water and waste management services.

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• Promote tourism, particularly coastal, eco (nature reserves and game farms) and cultural tourism opportunities. • Agricultural activities should be focused on areas of high agricultural potential.

5.9.5 Great Kei Local Municipality Spatial Development Framework (SDF)

The Great Kei Local Municipality (GKLM) SDF, which incorporates environmental guidelines from the GKLM Strategic Environment Framework (SEA), provides guidelines for spatial planning within the GKLM. Table 5-4 below summarises these environmental guidelines.

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

• STEP Critically Endangered areas (refer to Figure 5-8); and • Rivers, estuaries and undisturbed riparian zones of rivers.

The current and planned zoning of the proposed development will largely remain as Agriculture (managed as a game farm), with the addition of Resort Zone 2 (Holiday housing and Resort Hotel/Lodge) and Special Zone (roadways and service infrastructure). This zoning within Limited Development Areas will have specific environmental guidelines that will need to be considered, as detailed in Table 5-4 below.

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Table 5-4: Summary of GKLM Environmental Guidelines for spatial planning NO-GO Areas GO-BUT Areas

Inside Urban Edges Limited Development Areas

No Development Areas Away from Urban Edge Adjacent to Urban Edge or within Transitional Area

Areas of high environmental sensitivity Urban Settlement: Limited by: Limited by: and conservation value: • Residential • EIA process; • EIA process; • Primary dune systems • Public-Funded Housing • Low density; • Low density; • Indigenous forests • Resort Development • Density/footprint/impact • Density/footprint/impact • Proclaimed nature reserves; restrictions; restrictions; • Business and Trade • STEP Protected, Process and • Not in areas of environmental • Not in areas of environmental • Other Critically Endangered areas; sensitivity; sensitivity;

• Rivers, estuaries and • Unique & Sustainable • Unique & Sustainable undisturbed riparian zones of Develop from Inside-Outward Developments; Developments; rivers; (Phasing) • Must show tangible economic • Must show tangible economic • Diverse coastal grasslands and benefits to broader community; benefits to broader coastal thicket vegetation community; BUT, no for: • Clustering of built form; types; and • Clustering of built form; • Environmentally sensitive • Aesthetic controls; • Dynamic coastal areas areas within the urban edge • Aesthetic controls; including primary and mobile • Mitigate impacts; Limited development in dunes and areas within 50m of • Mitigate impacts; Coastal Buffer Zone • Show net gains for the the high-water mark, including environment; coastal cliffs. • Lack of services

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NO-GO Areas GO-BUT Areas

Inside Urban Edges Limited Development Areas

No Development Areas Away from Urban Edge Adjacent to Urban Edge or within Transitional Area

• Appropriateness of development • Show net gains for the in Coastal Buffer Zone; and environment;

• Provision of services • Appropriateness of development in Coastal Buffer Zone; and

• Provision of services

Zoning: Open Space Zone III (nature Zoning: Various Zoning: Mixed – Agriculture Zone I/Resort Zoning: Mixed – Agriculture Zone reserve) or Special Zone: Conservation Zone I or II/Residential/Open Space/Special I/Resort Zone I or II/Residential/Open Zone Space/Special Zone

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6 SITE INVESTIGATION

A site investigation was conducted between on the 6 December 2018 in order to:

• Verify desktop findings; • Assess the actual ecological state; • Assess the current land-use; • Identify potential sensitive ecosystems; • Identify plant species communities associated with the proposed project activities; and • Identify animal species associated with the proposed project activities.

The site visit also served to inform potential impacts of the proposed project and to inform the significance of these impacts on the surrounding ecological environment.

6.1 OBSERVATIONS

The site investigation focussed on three main areas where development would be located and referred to as:

• Focus area A – North-central portion of the site (housing units on northern ridge); • Focus area B – Eastern portion of the site (Lodge and chalets on ridge above the Great Kei River); and • Focus area C – Southern portion of the site (Lodge and chalets on south-central ridge).

Figure 6-1: Focus areas during the site investigation

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FOCUS AREA A: AERIAL IMAGERY

Shows approximate position of 50 proposed units on the northern central portion of the site (photos taken where red dot is).

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FOCUS AREA A: SITE PHOTOGRAPHS

Figure A1: Looking West.

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Figure A2: Looking South East.

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Figure A3: Looking East. Figure A4: Looking East.

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Figure A5: Looking South East.

FOCUS AREA A: ECOLOGICAL FEATURES The main ecological features of the area are:

- The area comprises ridges, valleys and flattened areas corresponding to dense thicket forest in the valleys, and bush clumps interspersed by grassland on the hill tops. - Thicket comprises mostly Acacia karoo dominated thicket interspersed with grassy patches. - The area is characterised by thick bush clumps, often containing indigenous protected tree species typical of the Hamburg Dune Thicket and Bisho Thornveld. Sideroxylon inerme (milkwood) noted with various bush clumps. Although no specimens were found, the Umtiza listeriana tree is believed to be found. - There are valleys in between rides which are susceptible to erosion. - The general area has been historically disturbed and transformed by farming and livestock grazing. - Alien species, largely comprising of Acacia sp. such as Acacia mernsii (Black wattle), and Lantana camara and Melia azedarach (Syringa sp.) where noted on site. - No faunal species of special concern were noted in the area.

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FOCUS AREA A: COMMENTS ON PLACEMENT OF DEVELOPMENT - There will be no development in the thicket forest dominated valleys or close to water courses, except for the installation of underground pipelines. - Majority of the development is located within open grassland grazing area on the tops of ridges, with minimal clearing of thicket vegetation required.

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FOCUS AREA B: AERIAL IMAGERY AND PHOTOGRAPHS

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Shows approximate position of the eastern portion of the site (Lodge and chalets River bank of the Great Kei River – all development will be located on the ridge on ridge above Great Kei River) above, therefore, the riverbank will not be impacted.

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Thick bush clumps with indigenous (protected) tree species were found between Overlooking the area where the recreational facility and chalets are proposed (red grassy plains. Sideroxylon inerme (milkwood) noted on site. circled area). Looking South East.

FOCUS AREA B: ECOLOGICAL FEATURES The main ecological features of the area are:

- The area comprises of open grassy hill tops surrounded by steep slopes comprising dense thicket. - The steep slopes are likely susceptible to erosion. - The area has evidence of alien species, largely comprising of Acacia sp. such as Acacia mernsii (Black wattle), and Lantana camara and Melia azedarach (Syringa sp.). - The area is characterised by thick bush clumps, often containing indigenous protected tree species typical of the Hamburg Dune Thicket. Sideroxylon inerme (milkwood) noted with various bush clumps. Although no specimens were found, the Umtiza listeriana tree is believed to be found in some of the forested areas along the Great Kei River. - No faunal species of special concern were noted in the area.

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FOCUS AREA B: COMMENTS ON PLACEMENT OF DEVELOPMENT - All development is to be located on flattened areas of a ridge overlooking the Great Kei River, and above the 1 in 100-year flood line. - All development is to be located as far away from the river edge as possible. - There will be no development within dense thicket areas, as much as practically possible.

FOCUS AREA C: AERIAL IMAGERY

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Shows approximate position of the southern portion of the site (Lodge and chalets on central ridge and proposed dam) FOCUS AREA C: SITE PHOTOGRAPHS

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Figure C1: Looking South East. Figure C2: The area is dominated by flattened grassland areas surrounded by valleys dominated by Acacia karoo thicket.

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Figure C3: Overlooking the grassy ridge top where the proposed chalets and Figure C4: Overlooking the area where the proposed dam is to be located. lodge will be located. Looking West. FOCUS AREA C: ECOLOGICAL FEATURES The main ecological features of the area are:

- The area is dominated by flattened grassland areas surrounded by valleys corresponding to dense thicket forest, comprises mostly Acacia karoo dominated thicket, typical of the Transkei Coastal Belt and Bhisho Thornveld. - The general area has been historically disturbed and transformed by farming and livestock grazing. - Alien species, largely comprising of Acacia sp. such as Acacia mernsii (Black wattle). - No faunal species of special concern were noted in the area.

FOCUS AREA C: COMMENTS ON PLACEMENT OF DEVELOPMENT - There is no planned development in the thicket forest dominated valleys or close to water courses, except for the proposed dam (Figure C4 above) - The chalet and lodge development is located within open flattened grassland grazing area.

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7 SENSITIVITY ASSESSMENT

The sensitivity of the site was based on proximity to aquatic features, such as drainage channels, rivers and wetlands, slope, as well as status of natural vegetation found on site (including the vegetation threat status).

Vegetation:

The study area is comprised of the following:

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

Cultivated/grazing land and degraded thicket were allocated a low sensitivity rating, as these areas have been transformed/disturbed to a large degree and have a high degree of alien invasive species present. The remaining natural thicket and bushland areas of the Bisho Thornveld and Hamburg Dune Thicket were allocated a medium sensitivity rating, as these areas are largely undisturbed and are likely to contain SCC’s.

Rivers and Wetlands

Water is considered as a scarce resource in South Africa. All identified rivers (including drainages) and wetlands (artificial and natural) are protected by legislation and requires licensing from DWS to impact on them.

The 1:100-year floodline of the Great Kei River as well as all drainage channels within the study area were classified as having a high sensitivity rating. The 50 m drainage channel buffers were classified as having a medium sensitivity rating, as these areas are important drainage areas, comprise of steep slopes susceptible to erosion and are likely to contain vegetation SCC’s.

7.1 SENSITIVITY ALLOCATION

Sensitivity maps were developed based on the methodology presented in Table 6.1 below, for the study area. The following sensitivity criteria were allocated for the proposed development. The allocation of criteria was based on both the desktop biophysical description of the site as well as observations made during the site visit.

Table 7-1: Criteria used for the analysis of the sensitivity of the proposed development CRITERIA LOW SENSITIVITY MODERATE SENSITIVITY HIGH SENSITIVITY 1 Topography Level or even Undulating; fairly steep Complex and uneven with slopes steep slopes

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CRITERIA LOW SENSITIVITY MODERATE SENSITIVITY HIGH SENSITIVITY 2 Vegetation - Extensive Restricted to a particular Restricted to a specific Extent or habitat throughout the region / zone locality / site type in the region region 3 Conservation Well conserved/ Not well conserved, Not conserved - has a high status of fauna / independent of moderate conservation value conservation value flora or habitats conservation value

4 Species of None, although No Species of Conservation One or more Species of conservation occasional regional Concern, some Conservation Concern, or concern - endemics indeterminate or rare more than 2 endemics or Presence and endemics rare species number 5 Habitat Extensive areas of Reasonably extensive areas Limited areas of this fragmentation preferred habitat of preferred habitat habitat, susceptible to leading to loss of present elsewhere elsewhere and habitat fragmentation viable in region not susceptible to fragmentation populations susceptible to fragmentation 6 Biodiversity Low diversity or Moderate diversity, and High diversity and species contribution species richness moderately high species richness richness (in natural vegetated areas - thicket) 7 Erosion potential Very stable and an Some possibility of erosion or Large possibility of erosion or instability of area not subjected change due to episodic to the site or destruction the region to erosion events due to climatic or other factors

8 Rehabilitation Site is easily There is some degree of Site is difficult to potential of the rehabilitated difficulty in rehabilitation of rehabilitate due to the area or region the site terrain, type of habitat or species required to reintroduce 9 Disturbance due Site is very There is some degree of The site is hardly or very to human disturbed or disturbance of the site slightly impacted upon by habitation or degraded human disturbance other influences (alien invasive species) 10 Ecological Habitat widely Intermediate role in Key habitat involved in function represented in the ecological function ecological processes landscape not (ecological corridors and specifically network areas or key niche harbouring any habitats) unique habitat features…etc.

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CRITERIA LOW SENSITIVITY MODERATE SENSITIVITY HIGH SENSITIVITY 11 Ecological Little to no Some ecological services. Various ecological services. Services ecological services Areas should be conserved.

Table 7-2 below summarises the findings of the sensitivity assessment.

Table 7-2: List of criteria contributing to the sensitivity map SITE ELEMENT SENSITIVITY MAPPING RULE SENSITIVITY ALLOCATION

Cultivated/grazing land − Topography is low and even; Low sensitivity

− Little natural vegetation invaded by aliens;

− No SCC;

− Habitat not susceptible to fragmentation;

− Rehabilitation can be achieved;

− High levels of degradation and disturbance;

− Low biodiversity; and

− Low ecological functions/ services.

Natural vegetated areas Degraded thicket and bushland: Low sensitivity

− Topography is low and even;

− Extensive vegetation in region;

− Low conservation status;

− Habitat not susceptible to fragmentation; and

− Rehabilitation is easy;

Intact grassland, thicket and bushland: Moderate sensitivity − Moderate biodiversity;

− Some SCC’s present;

− Some degree of degradation/ disturbance;

− Key habitats involved in ecological processes; and

Riparian Zones − 50 m drainage channel buffer areas; Moderate sensitivity − Riparian vegetation restricted to riparian zone;

− SCCs occur in some areas;

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SITE ELEMENT SENSITIVITY MAPPING RULE SENSITIVITY ALLOCATION

− Moderate biodiversity and ecological services offered

Rivers/Watercourses − Rivers, drainage channels and 1:100-year floodline of High sensitivity the Great Kei River;

− 100 m buffer area from the 1:100-year floodline of the Great Kei River Estuary. − Ecological corridors, and habitats relatively susceptible to fragmentation − Undulating topography susceptible to erosion

Figure 7-1 below reflects the ecological sensitivity identified for the proposed study area.

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Figure 7-1: Sensitivity map of the study area

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It can be seen from the sensitivity map that majority of the proposed development occurs within areas of LOW to MODERATE sensitivity, with only the service infrastructure (roads, dams, underground water and sewer pipelines, and electrical cables) crossing areas of HIGH sensitivity. The lodge and chalets proposed to be constructed on the ridge top overlooking the Great Kei River must not be constructed within 100m from the 1:100-year floodline of the Great Kei River (must be considered a No-Go area), as to maintain important ecological corridors. The service infrastructure must follow the existing tracks/prop within the study area, therefore, the amount of natural vegetation required to be cleared will be minimal.

The placement of the buildings largely falls within open grassland areas, however, there will be some thicket vegetation (bush clumps) required to be cleared. This will be minimal when taking into consideration, that only 3.7% of the total 599.2 Ha consolidated area will be occupied by residential erven, lodges and chalets, and associated infrastructure, while 96.3% of the natural vegetation will be conserved (managed as a game farm). In addition, the proposed development will be constructed in a phased manner, as explained in section 1 above, therefore, the environmental impact will be spread out over several years.

It is recommended that thicketed areas be avoided as much as practically possible, and previously degraded/developed areas and open grassy areas be targeted for the proposed buildings and layout of the service infrastructure. Rivers, drainage channels (including their 50m buffers) and 1:100-year floodline of the Great Kei River, as well as their riparian areas, must be considered as No-Go areas and be avoided (except where authorised for service infrastructure).

All protected plant/tree species should be preserved on site as much as possible. However, should the proposed development require their removal/relocation, the relevant permit/s must be obtained prior from the relevant authorities. A search and rescue walkthrough of the surveyed construction footprint must be undertaken by a suitably qualitied individual (ECO and/or botanist) prior to vegetation clearance to ensure that all required permits are obtained, and relocation is undertaken where necessary.

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8 IMPACT ASSESSMENT

8.1 IMPACT IDENTIFICATION

Table 8-1 below provides a breakdown of the impact identification process into overall themes, potential issues, and the source of the issue across all project phases of the proposed development. It also identifies the potential receptors of each issue identified and the action taken to further assess each issue during the Basic Assessment process. The impact assessment methodology detailed in section 3.6 above was used to assess the impacts detailed in Table 8-1 below.

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Table 8-1: Impact identification PHASE POTENTIAL ASSESSMENT THEME POTENTIAL ISSUES SOURCE OF ISSUE PLANNING RECEPTORS CONSTRUCTION OPERATIONAL ACTIONS & DESIGN Clearance of Natural Vegetation clearance Flora in study area and Riparian X X Vegetation Loss of Species of Vegetation clearance SCC in study area X Conservation X Assessed in the Concern (SCC) Biological Ecological Impact Land use, development Biodiversity, Inadequate Assessment footprint Ecological Corridors, protection of high X X X Flora & Fauna in conservation areas study area Control of alien Inappropriate alien Terrestrial X X X invasive plant species vegetation management plan Environment

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8.2 IMPACT ASSESSMENT

The following tables provide a detailed assessment the ecological impacts identified in section Table 8-1 above.

Table 8-2: Planning and Design Phase Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANCE NATURE ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES POST- OF IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION PLANNING & DESIGN PHASE BIOLOGICAL Loss of natural During the planning and design phase, Direct, Project Long Term Definite Moderately HIGH • The development footprint must MODERATE and riparian the inappropriate design of the Indirect, Level severe NEGATIVE be surveyed and demarcated NEGATIVE vegetation development and associated Cumulative prior to construction infrastructure will lead to the commencing to ensure that unnecessary loss of natural there is no unnecessary loss of vegetation. natural vegetation outside the approved footprint. • The design and layout of the development and associated infrastructure must have as minimal impact on the natural vegetation as possible. • The placement of the estate buildings must be planned in such a way as to avoid intact thicket/bushland, as much as possible. • Service infrastructure must follow the road reserve, as much as practically possible. • A Rehabilitation Plan must be developed during the pre- construction to include details on rehabilitating disturbed natural areas once construction has been completed.

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SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANCE NATURE ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES POST- OF IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION PLANNING & DESIGN PHASE • An ECO must be appointed pre- construction to ensure that the pre-construction requirements area adhered to, i.e. walkthroughs conducted, and management plans are developed. Loss of Species of During the planning and design phase, Direct Project Permanent Possible Moderately MODERATE • A search and rescue walkthrough LOW Conservation inadequate planning for search and Level severe NEGATIVE must be undertaken by a suitably NEGATIVE Concern (SCC) rescue activities will lead to the loss of qualified individual, pre- identified and unidentified plant and construction, to identify any animal SCC. potential plant SCC’s located within the surveyed construction footprint. This should ideally be undertaken with the ECO and Contractor/Developer present. • All relevant permits must be obtained from the competent authority prior to construction in order to remove/relocate any plant SCC’s. Inadequate During the planning and design phase, Direct Localised Long-Term Probable Moderately LOW • A Conservation Management MODERATE protection of high the planning and of the Kei Mouth Eco Indirect Beneficial POSITIVE Plan must be developed for the POSITIVE conservation Estate in a manner which promotes Cumulative Eco Estate by a suitably qualified areas conservation and adheres to the individual, which must include ECBCP, will positively contribute to addressing issues such as: conservation goals within the local • Identification of No-Go and area. sensitive areas, including the regulation of specific activities within such areas • Hunting • Inappropriate use of vehicles • Inappropriate stocking of game (e.g. overstocking and inappropriate species) • Introduction of dangerous animals

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SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANCE NATURE ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES POST- OF IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION PLANNING & DESIGN PHASE • Types of vehicles that will be permitted in the conservation areas (i.e. of access roads) • Domestic pets • Vegetation and Alien species control and management • Fire control and veld burning • Fencing • Access control • Others • Having the remaining application area (particularly the portions towards the Great Kei River) proclaimed as a private nature reserve should be considered. Control of alien During the planning and design phase, Direct Localised Long Term Probable Severe HIGH • During the planning and design MODERATE invasive plant inadequate planning for the removal NEGATIVE phase, an Alien Vegetation NEGATIVE species and management of alien vegetation Management Plan must be could result in the invasion of alien complied to be implemented vegetation in both terrestrial and during construction and riparian areas during the construction operation of the estate to reduce and operation phase. the establishment and spread of undesirable alien plant species.

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Table 8-3: Construction Phase Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANCE NATURE ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES POST- OF IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION CONSTRUCTION PHASE: FOR ALL ALTERNATIVES BIOLOGICAL Loss of During the construction Direct Project Medium Probable Severe HIGH • All No-Go areas, such as riparian areas, 100m LOW Riparian and phase, indiscriminate Cumulative Level term NEGATIVE inland from the 1:100-year floodline of the NEGATIVE Natural removal of riparian Great Kei River and 50 m buffers applied to the Vegetation vegetation at rivers and iCwili River and smaller tributaries within the water crossing sites, or study area, must be avoided during encroachment into construction. surrounding areas could lead • No development (other than authorised to destabilisation of bank service infrastructure and the proposed dams) structures and an increase in must occur within these no-go areas. erosion rates. The clearing of • Where unavoidable (i.e. service infrastructure, natural vegetation may lead water-crossings), construction must be done to the destruction of in a manner that is minimally invasive, i.e. habitats and the loss of labour intensive rather than heavy machinery. identified and unidentified • The ECO should monitor construction activities plant SCC. undertaken within and near licensed water- crossings, and ensure that no unnecessary vegetation clearing takes place. • Removal of the alien invasive vegetation should be prioritised. • Vehicles and machinery should not encroach into areas outside the surveyed/demarcated development footprint. • Areas within the construction footprint that have been cleared must be rehabilitated in terms of soil stabilisation and revegetation as soon as possible. Loss of During the construction Direct Project Permanent Possible Moderately MODERATE • Should the ECO identify any SCC’s within the LOW Species of phase, the clearing of Level severe NEGATIVE development footprint, these should be NEGATIVE Conservation natural vegetation may lead demarcated and avoided until the necessary Concern to the destruction of permits are in place and relocated outside of (SCC) habitats and the loss of the footprint area by a suitably qualified identified and unidentified individual/botanist. plant SCC. • The contractor’s staff must not poach or trap wild animals. • The contractor’s staff must not harvest any natural vegetation.

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SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANCE NATURE ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES POST- OF IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION Protection of Construction undertaken in Direct Localised Long Term Possible Moderately MODERATE • The land-use management recommendations LOW high accordance with the land- Beneficial NEGATIVE of the ECBCP and GKLM SDF must be applied NEGATIVE conservation use management guidelines as much as possible. areas of the ECBCP and GKLM SDF • No-Go areas, such as riparian zones, 100 m will positively contribute to from the 1:100-year floodline of the Great Kei the conservation of the local River and 50m from the smaller tributaries and biota. intact thicket vegetation, should be kept free of direct and indirect impacts potentially resulting from the development. Control of During the construction Direct Localised Long Term Probable Moderately MODERATE • The conditions set out in the Alien Vegetation LOW alien phase, vegetation clearing, Cumulative Severe NEGATIVE and Rehabilitation Plan must be implemented NEGATIVE invasive and poor rehabilitation of and adhered to. plant species disturbed areas may lead to • All temporarily cleared areas must be the permanent degradation rehabilitated back to their original condition. of ecosystems and promote • Only topsoil from the immediate area must be the establishment and used for rehabilitation. spread of alien vegetation species.

Table 8-4: Operational Phase Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANCE NATURE ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES POST- OF IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION OPERATIONAL PHASE: FOR ALL ALTERNATIVES BIOLOGICAL Inadequate During the operational phase, Direct Localised Long-Term Probable Moderately LOW POSITIVE • The land-use guidelines and MODERATE protection of the management of the property Beneficial principles of the ECBCP and GKLM POSITIVE high conservation in accordance with the land-use SDF must be included in the Home areas guidelines and principles of the Owners Agreement. ECBCP and GKLM SDF will • All applicable management plans contribute to biodiversity must be implemented and included conservation within the local in Home Owners Agreement, ie.: area. • Operational Environmental Management Programme (EMPr) • Stormwater Management Plan; • Erosion Management Plan;

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SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANCE NATURE ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES POST- OF IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION • Waste management Plan; • Traffic Management Plan; • Conservation Management Plan; • Environmental Monitoring Programme (water quality); • Alien Species Management Plan; and • Rehabilitation and Maintenance Plan Control of alien During the operational phase, Direct Localised Long Term Possible Moderately MODERATE • The Alien Vegetation Management LOW invasive plant the lack of an effective Alien Cumulative severe NEGATIVE Plan must be included as part of the NEGATIVE species Vegetation Management Plan developments on-going post-construction could lead to maintenance plan to reduce the large scale alien plant invasion establishment and spread of during the operational phase. undesirable alien plant species throughout the operational phase.

Table 8-5: No-Go Alternative Impact Assessment NATURE SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANCE ISSUE DESCRIPTION OF IMPACT OF SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES POST- IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION Proposed Kei The No-Go Alternative will result in Direct Localised Long Term Definite No effect NO No mitigation proposed NO Mouth Eco the status-quo being maintained. SIGNIFICANCE SIGNIFICANCE Estate Protection of The No-Go Option would not result in Direct Localised Long Term Definite Moderately MODERATE No mitigation proposed MODERATE high the promotion of conservation within Indirect severe NEGATIVE NEGATIVE conservation the local area. areas

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Table 8-6: Cumulative Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANCE NATURE ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES POST- OF IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION Biodiversity The clearing of natural vegetation Cumulative Localised Medium Probable Moderately MODERATE • The Conservation Management LOW results in land transformation, alien term severe NEGATIVE Plan must be developed and NEGATIVE plant invasion and habitat loss implemented. Hydrology & During the construction phase, Cumulative Localised Medium Probable Moderately MODERATE • An Erosion Management Plan LOW Geohydrology Surface water impacts, such as term severe NEGATIVE must be developed and NEGATIVE water surface and/or groundwater implemented. contamination and sedimentation (increased dust and sediment generation) may extend beyond the • A Waste Management Plan immediate project site must be developed and implemented. • Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practice must be adhered to. Changes to surface flow dynamics • Storm Water Management may have negative effects on the Plan must be developed and aquatic environment beyond the implemented. immediate project site Local land capability may be Cumulative Localised Medium Probable Moderately MODERATE • An Erosion Management Plan LOW Soils reduced due to loss of topsoil, term severe NEGATIVE must be developed and NEGATIVE erosion and soil contamination implemented.

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9 IMPACT STATEMENT

9.1 PROJECT SUMMARY

The proposed Kei Mouth Eco Estate will be located on 3 farms with a combined area of 599.2 Ha. The proposed development will have the following activities:

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

The associated proposed activities include:

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

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

9.2 IMPACT STATEMENT

9.2.1 Summary of impacts

Table 9-1 below summaries the impact assessment for all phases of the development.

Table 9-1: Summary of ecological impacts PLANNING & DESIGN PHASE Significance Significance Theme Impacts pre-mitigation post-mitigation Loss of natural and During the planning and design phase, the HIGH MODERATE riparian vegetation inappropriate design of the development and NEGATIVE NEGATIVE associated infrastructure will lead to the unnecessary loss of natural vegetation.

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Loss of Species of During the planning and design phase, MODERATE LOW NEGATIVE Conservation inadequate planning for search and rescue NEGATIVE Concern (SCC) activities will lead to the loss of identified and unidentified plant and animal SCC. Inadequate During the planning and design phase, the LOW POSIITVE MODERATE protection of high planning and of the Kei Mouth Eco Estate in a POSITIVE conservation areas manner which promotes conservation and adheres to the ECBCP, will positively contribute to conservation goals within the local area. Control of alien During the planning and design phase, HIGH MODERATE invasive plant inadequate planning for the removal and NEGATIVE NEGATIVE species management of alien vegetation could result in the invasion of alien vegetation in both terrestrial and riparian areas during the construction and operation phase. CONSTRUCTION PHASE Significance Significance Theme Impacts pre-mitigation post-mitigation Loss of Riparian During the construction phase, indiscriminate HIGH LOW NEGATIVE and Natural removal of riparian vegetation at rivers and NEGATIVE Vegetation water crossing sites, or encroachment into surrounding areas could lead to destabilisation of bank structures and an increase in erosion rates. The clearing of natural vegetation may lead to the destruction of habitats and the loss of identified and unidentified plant SCC. Loss of Species of During the construction phase, the clearing of MODERATE LOW NEGATIVE Conservation natural vegetation may lead to the destruction of NEGATIVE Concern (SCC) habitats and the loss of identified and unidentified plant SCC. Protection of high Construction undertaken in accordance with the MODERATE LOW NEGATIVE conservation areas land-use management guidelines of the ECBCP NEGATIVE and GKLM SDF will positively contribute to the conservation of the local biota. Control of alien During the construction phase, vegetation MODERATE LOW NEGATIVE invasive plant clearing, and poor rehabilitation of disturbed NEGATIVE species areas may lead to the permanent degradation of ecosystems and promote the establishment and spread of alien vegetation species. OPERATIONAL PHASE Significance Significance Theme Impacts pre-mitigation post-mitigation Inadequate During the operational phase, the management LOW POSITIVE MODERATE protection of high of the property in accordance with the land-use POSITIVE conservation areas guidelines and principles of the ECBCP and GKLM SDF will contribute to biodiversity conservation within the local area.

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

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In summary,

Table 9-2 below provides a breakdown of the total significance ratings for all impacts, pre- and post- mitigation. All significant impacts rated as HIGH pre-mitigation, can be reduced to LOW or MODERATE significance rating post-mitigation.

Table 9-2: Summary of the ecological impact assessment significance, pre- and post-mitigation PRE-MITIGATION POST-MITIGATION

LOW MODERATE HIGH LOW MODERATE HIGH

Planning and 1+ 1 2 1 2 (1+) 0 Design

Construction 0 3 1 4 0 0

Operation 1+ 1 0 1 1+ 0

TOTAL 0 (2+) 4 3 6 2 (2+) 0

9.2.2 Cumulative impacts

Table 9-3 below provides a summary of cumulative impacts assessed. All cumulative impacts can be reduced to low significance rating post-mitigation.

Table 9-3: Summary of the cumulative impact assessment CUMULATIVE IMPACTS Significance Significance Theme Impacts pre-mitigation post-mitigation Biodiversity The clearing of natural vegetation results in land MODERATE LOW transformation, alien plant invasion and habitat NEGATIVE NEGATIVE loss/fragmentation. Surface water impacts, such as water surface MODERATE LOW and/or groundwater contamination and NEGATIVE NEGATIVE sedimentation (increased dust and sediment Hydrology & generation) may extend beyond the immediate Geohydrology project site. Changes to surface flow dynamics may have negative effects on the aquatic environment beyond the immediate project site. Local land capability may be reduced due to loss MODERATE LOW Soils of topsoil, erosion and soil contamination. NEGATIVE NEGATIVE

9.2.3 No-Go alternative

The No-Go alternative would be the optimum environmental outcome provided that the environmental integrity of the land is retained. However, the No-Go option carries the risk of the individual sale of the 3 farms at some future date where the following risks would be relevant:

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• Difficult to control the activities of 3 individual farmers. • Ongoing farming and poor land-use management (e.g. cultivation and tunnels). • Internal fencing can prohibit animal movement. • Loss in critical biodiversity areas, habitat fragmentation due to farming activities. • Loss of landscape connections (ecological corridors) and ecological processes due to farming activities. • Introduction and spread of invasive alien species.

Overall, the No-Go option would result in a lost opportunity to conserve about 96.3% of the 599.2 Ha of land in question.

Table 9-4: Summary of the No-Go alternative assessment NO-GO ALTERNATIVE Significance Significance Theme Impacts pre-mitigation post-mitigation Proposed Kei The No-Go Alternative will result in the status- NO NO Mouth Eco Estate quo being maintained. SIGNIFICANCE SIGNIFICANCE Protection of high The No-Go Option would not result in the MODERATE MODERATE conservation areas promotion of conservation within the local area. NEGATIVE NEGATIVE and ecological processes

9.2.4 Compatibility with Biodiversity Planning Initiatives

A key component of this component of the ecological impacts assessment was to assess the impacts of the proposed Kei Mouth Eco Estate against current biodiversity and ecological planning initiatives and associated land-use management recommendations. The results of this analysis are summarised below:

SA VEGMAP (SANBI, 2018) Development of the land in question should aim to conserve 25% for the Transkei Coastal Belt (CB 5) and Bisho Thornveld (SVs7) elements respectively.

Subtropical thicket ecosystem Plan (STEP) Proposed development is located in an area designated by STEP as: • Currently not vulnerable (majority of the development footprint); and • High Priority Conservation Network Area – STEP Kei Megaconservancy Network (narrow strip of vegetation along the steep banks of the Great Kei River).

The relevant STEP land-use recommendations suggest that the land in question: • Can only withstand minimal loss of natural area through disturbance and developments. • Within constraints (such as avoidance of spoiling scenery or wilderness, or infra-structure limitations), the Network land may be suitable for eco-friendly activities such as sustainable game farming and responsible ecotourism (hiking trails, etc.).

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• For the area “currently not vulnerable”, disturbance or developments should preferably take place on portions which have already undergone disturbance.

Eastern Cape Biodiversity Conservation Plan (ECBCP) In terms of the ECBCP, the area into which the proposed Kei Mouth Eco Estate is designated as: • For terrestrial ecosystems: BLMC 1: Maintain natural states.

Recommended land-uses or land use change include: • Maintain biodiversity in near natural state with minimal loss of ecosystem integrity. • No transformation of natural habitat should be permitted. • Conservation and game farming (conditional) is recommended. • Communal and commercial livestock, cropping, airy farming, timber and settlements are not recommended. • Less than 10 % of total area of sub-quaternary catchment should be transformed. • Appropriate buffers, ranging from 100 metres to 32 metres should be applied to rivers and other water resources. • The ten principles of land use planning for biodiversity persistence should be adopted.

Great Kei Municipality Spatial Development Framework (SDF) and Strategic Environmental Assessment (SEA) The Kei Mouth Eco Estate is consistent with the recommendations of the GKLM SDF and SEA.

It is our opinion that the proposed Kei Mouth Eco Estate project is not inconsistent with the objectives of various biodiversity plans or programmes for the area in question. Perhaps the most limiting recommendations out of all the plans is the ECBCP, which, amongst other items mentioned above, generally recommends that:

• Biodiversity must largely be maintained in a natural state with minimal loss of ecosystem integrity. • No transformation of natural habitat should be permitted. • Conservation and game farming (conditional) is recommended. • Communal and commercial livestock, cropping, dairy farming, timber and settlements are not recommended.

Again, it is our opinion that the overall concept for the Kei Mouth Eco Estate carries significant environmental benefits, where only about 3% of the land will be transformed and where 96% of the land will be conserved.

9.2.5 Sensitivity assessment

Majority of the proposed development occurs within areas of LOW to MEDIUM sensitivity, with only the service infrastructure (roads, dams, underground water and sewer pipelines, and electrical cables) crossing areas of HIGH sensitivity. The lodge and chalets proposed to be constructed on the ridge top

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overlooking the Great Kei River must not be constructed within 100m from the 1:100-year floodline of the Great Kei River (must be considered a No-Go area), as to maintain important ecological corridors. The service infrastructure must follow the existing tracks/prop within the study area, therefore, the amount of natural vegetation required to be cleared will be minimal.

The placement of the buildings largely falls within open grassland areas, however, there will be some thicket vegetation (bush clumps) required to be cleared. This will be minimal when taking into consideration, that only 3.7% of the total 599.2 Ha consolidated area will be occupied by residential erven, lodges and chalets, and associated infrastructure, while 96.3% of the natural vegetation will be conserved (managed as a game farm). In addition, the proposed development will be constructed in a phased manner, as explained in section 1 above, therefore, the environmental impact will be spread out over several years.

It is recommended that thicketed areas be avoided as much as practically possible, and previously degraded/developed areas and open grassy areas be targeted for the proposed buildings and layout of the service infrastructure. Rivers, drainage channels (including their 50m buffers) and 1:100-year floodline of the Great Kei River, as well as their riparian areas, must be considered as No-Go areas and be avoided (except where authorised for service infrastructure).

All protected plant/tree species should be preserved on site as much as possible. However, should the proposed development require their removal/relocation, the relevant permit/s must be obtained prior from the relevant authorities. A search and rescue walkthrough of the surveyed construction footprint must be undertaken by a suitably qualitied individual (ECO and/or botanist) prior to vegetation clearance to ensure that all required permits are obtained, and relocation is undertaken where necessary.

9.3 RECOMMENDATIONS

9.3.1 Planning and design phase

• The development footprint must be surveyed and demarcated prior to construction commencing to ensure that there is no unnecessary loss of natural vegetation outside the approved footprint. • The design and layout of the development and associated infrastructure must have as minimal impact on the natural intact vegetation as possible. • The placement of the estate buildings must be planned in such a way as to avoid intact thicket/bushland, as much as possible. • Service infrastructure must follow the road reserve, as much as practically possible. • A Rehabilitation Plan must be developed during the pre-construction to include details on rehabilitating disturbed natural areas once construction has been completed. • An ECO must be appointed pre-construction to ensure that the pre-construction requirements area adhered to, i.e. walkthroughs conducted, and management plans are developed. • A search and rescue walkthrough must be undertaken by a suitably qualified individual, pre- construction, to identify any potential plant SCC’s located within the surveyed construction footprint. This should ideally be undertaken with the ECO and Contractor/Developer present. • All relevant permits must be obtained from the competent authority prior to construction in order to remove/relocate any plant SCC’s.

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• A Conservation Management Plan must be developed for the Eco Estate by a suitably qualified individual, which must include addressing issues such as: o Identification of No-Go and sensitive areas, including the regulation of specific activities within such areas o Hunting o Inappropriate use of vehicles o Inappropriate stocking of game (e.g. overstocking and inappropriate species) o Introduction of dangerous animals o Types of vehicles that will be permitted in the conservation areas (i.e. of access roads) o Domestic pets o Vegetation and Alien species control and management o Fire control and veld burning o Fencing o Access control o Others • Having the remaining application area (particularly the portions towards the Great Kei River) proclaimed as a private nature reserve should be considered. • During the planning and design phase, an Alien Vegetation Management Plan must be complied to be implemented during construction and operation of the estate to reduce the establishment and spread of undesirable alien plant species.

9.3.2 Construction Phase

• All No-Go areas, such as riparian areas, 100m inland from the 1:100-year floodline of the Great Kei River and 50 m buffers applied to the iCwili River and smaller tributaries within the study area, must be avoided during construction. • No development (other than authorised service infrastructure and the proposed dams) must occur within these no-go areas. • Where unavoidable (i.e. service infrastructure, water-crossings), construction must be done in a manner that is minimally invasive, i.e. labour intensive rather than heavy machinery. • The ECO should monitor construction activities undertaken within and near licensed water- crossings and ensure that no unnecessary vegetation clearing takes place. • Removal of the alien invasive vegetation should be prioritised. • Vehicles and machinery should not encroach into areas outside the surveyed/demarcated development footprint. • Areas within the construction footprint that have been cleared must be rehabilitated in terms of soil stabilisation and revegetation as soon as possible. • Should the ECO identify any SCC’s within the development footprint, these should be demarcated and avoided until the necessary permits are in place and relocated outside of the footprint area by a suitably qualified individual/botanist. • The contractor’s staff must not poach or trap wild animals. • The contractor’s staff must not harvest any natural vegetation.

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• The land-use management recommendations of the ECBCP and GKLM SDF must be applied as much as possible. • No-Go areas, such as riparian zones, 100 m from the 1:100-year floodline of the Great Kei River and 50m from the smaller tributaries and intact thicket vegetation, should be kept free of direct and indirect impacts potentially resulting from the development. • The conditions set out in the Alien Vegetation and Rehabilitation Plan must be implemented and adhered to. • All temporarily cleared areas must be rehabilitated back to their original condition. • Only topsoil from the immediate area must be used for rehabilitation.

9.3.3 Operational phase

• The land-use guidelines and principles of the ECBCP and GKLM SDF must be included in the Home Owners Agreement. • All applicable management plans must be implemented and included in Home Owners Agreement, i.e.: o Operational Environmental Management Programme (EMPr) o Stormwater Management Plan; o Erosion Management Plan; o Waste management Plan; o Traffic Management Plan; o Conservation Management Plan; o Environmental Monitoring Programme (water quality); o Alien Species Management Plan; and o Rehabilitation and Maintenance Plan • The Alien Vegetation Management Plan must be included as part of the developments on-going maintenance plan to reduce the establishment and spread of undesirable alien plant species throughout the operational phase.

9.4 CONCLUSION

It is the opinion of CES that NO FATAL FLAWS are associated with the proposed Kei Mouth Eco Estate, and that all ecological impacts can be adequately mitigated to reduce the risk or significance of impacts to an acceptable level, provided that the mitigation measures detailed above are implemented.

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10 REFERENCES

IUCN. 2012. Red List of Threatened Species. IUCN Species Survival Commission, Cambridge Available: http://www.iucnredlist.org/ (Accessed 011/07/2019).

MUCINA, L. & RUTHERFORD, M.C. 2012 and 2018. The vegetation of South Africa, Lesotho and Swaziland. SANBI, Pretoria.

Nature and Environmental Conservations Ordinance No 19 of 1974.

NEM:BA. 2004. National Environmental Management Act: Biodiversity Act (No. 10 of 2004).

NEM:BA. 2011. National list of ecosystems that are threatened and in need of protection. Government Notice No. 1002, 9 December 2011.

NEM:BA. 2014. National Environmental Management Act: Biodiversity Act (No. 10 of 2004) – Draft Alien and Invasive Species lists, 2014. Government Gazette, No. 37320, 12 February 2014.

NFA. 1998. National Forests Act (No. 84 of 1998).

NFA. 2013. List of protected trees: Notice of the list of protected tree species under the National Forest Act (No. 84 of 1998). Government Gazette No 37037, Notice 877, 22 November 2013.

Websites:

POSA (http://posa.sanbi.org/)

SANBI (http://bgis.sanbi.org/)

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APPENDIX 1: SPECIES LIST’S

Plant and tree species list likely to be found within the broader study area (POSA, 2019).

Family Genus Species Status SANBI Red List: Least Concern Apocynaceae Asclepias praemorsa PNCO Protected SANBI Red List: Least Concern Apocynaceae Cynanchum ellipticum PNCO Protected Ebenaceae Diospyros dichrophylla SANBI Red List: Least Concern SANBI Red List: Rare Iridaceae Dietes bicolor PNCO Protected Loranthaceae Agelanthus kraussianus SANBI Red List: Least Concern Myrsinaceae Rapanea melanophloeos SANBI Red List: Least Concern

SANBI Red List: Least Concern; Pittosporaceae Pittosporum viridiflorum DAFF Protected Tree Rubiaceae Anthospermum galpinii SANBI Red List: Least Concern Rutaceae Vepris lanceolata SANBI Red List: Least Concern

Avifaunal species found within the 3235_2820 QDS (SABAP, 2017)

Ref Common_species Common_group Genus Species 160 African Goshawk Accipiter tachiro 159 Black Sparrowhawk Accipiter melanoleucus 606 African Reed-warbler Acrocephalus baeticatus 603 Great Reed-warbler Acrocephalus arundinaceus 604 Lesser Swamp-warbler Acrocephalus gracilirostris 607 Marsh Warbler Acrocephalus palustris 258 Common Sandpiper Actitis hypoleucos 396 Half-collared Kingfisher Alcedo semitorquata 89 Egyptian Goose Alopochen aegyptiacus 804 Thick-billed Weaver Amblyospiza albifrons 95 African Black Duck Anas sparsa 96 Yellow-billed Duck Anas undulata 97 Red-billed Teal Anas erythrorhyncha 551 Sombre Greenbul Andropadus importunus 52 African Darter Anhinga rufa 692 African Pipit Anthus cinnamomeus 694 Plain-backed Pipit Anthus leucophrys 622 Bar-throated Apalis Apalis thoracica 625 Yellow-breasted Apalis Apalis flavida 393 Narina Trogon Apaloderma narina 322 Lemon Dove Aplopelia larvata 380 African Black Swift Apus barbatus 383 White-rumped Swift Apus caffer

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55 Black-headed Heron Ardea melanocephala 56 Goliath Heron Ardea goliath 54 Grey Heron Ardea cinerea 214 Grey Crowned Crane Balearica regulorum 672 Cape Batis Batis capensis 673 Chinspot Batis Batis molitor 84 Hadeda Ibis Bostrychia hagedash 609 Little Rush-warbler Bradypterus baboecala 610 Barratt's Warbler Bradypterus barratti 368 Spotted Eagle-owl Bubo africanus 430 Southern Ground-hornbill Bucorvus leadbeateri 275 Spotted Thick-knee Burhinus capensis 274 Water Thick-knee Burhinus vermiculatus 152 Jackal Buzzard Buteo rufofuscus 154 Steppe Buzzard Buteo vulpinus 422 Trumpeter Hornbill Bycanistes bucinator 255 Sanderling Sanderling Calidris alba 627 Green-backed Camaroptera Camaroptera brachyura 448 Knysna Woodpecker Campethera notata 373 Fiery-necked Nightjar Caprimulgus pectoralis 4131 Burchell's Coucal Centropus burchellii 570 Familiar Chat Cercomela familiaris 584 Brown Scrub-robin Cercotrichas signata 588 White-browed Scrub-robin Cercotrichas leucophrys 394 Pied Kingfisher Ceryle rudis 772 Amethyst Sunbird Chalcomitra amethystina 233 Common Ringed Plover Charadrius hiaticula 237 Kittlitz's Plover Charadrius pecuarius 238 Three-banded Plover Charadrius tricollaris 235 White-fronted Plover Charadrius marginatus 352 Diderick Cuckoo Chrysococcyx caprius 758 Greater Double-collared Sunbird Cinnyris afer 760 Southern Double-collared Sunbird Cinnyris chalybeus 167 African Marsh-harrier Circus ranivorus 648 Lazy Cisticola Cisticola aberrans 646 Levaillant's Cisticola Cisticola tinniens 639 Wailing Cisticola Cisticola lais 634 Wing-snapping Cisticola Cisticola ayresii 637 Neddicky Neddicky Cisticola fulvicapilla 348 Jacobin Cuckoo Clamator jacobinus 390 Speckled Mousebird Colius striatus 312 African Olive-pigeon Columba arquatrix 311 Speckled Pigeon Columba guinea

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523 Cape Crow Corvus capensis 522 Pied Crow Corvus albus 524 White-necked Raven Corvus albicollis 578 Chorister Robin-chat Cossypha dichroa 579 Red-capped Robin-chat Cossypha natalensis 863 Brimstone Canary Crithagra sulphuratus 859 Yellow-fronted Canary Crithagra mozambicus 867 Streaky-headed Seedeater Crithagra gularis 344 Black Cuckoo Cuculus clamosus 340 Common Cuckoo Cuculus canorus 765 Grey Sunbird Cyanomitra veroxii 766 Olive Sunbird Cyanomitra olivacea 450 Cardinal Woodpecker Dendropicos fuscescens 452 Olive Woodpecker Dendropicos griseocephalus 517 Fork-tailed Drongo Dicrurus adsimilis 518 Square-tailed Drongo Dicrurus ludwigii 712 Black-backed Puffback Dryoscopus cubla 58 Great Egret Egretta alba 59 Little Egret Egretta garzetta 872 Cinnamon-breasted Bunting Emberiza tahapisi 874 Golden-breasted Bunting Emberiza flaviventris 843 Common Waxbill Estrilda astrild 816 Fan-tailed Widowbird Euplectes axillaris 818 Long-tailed Widowbird Euplectes progne 114 Lanner Falcon Falco biarmicus 70 White-backed Night-Heron Gorsachius leuconotus 231 African Black Oystercatcher Haematopus moquini 402 Brown-hooded Kingfisher Halcyon albiventris 400 Mangrove Kingfisher Halcyon senegaloides 149 African Fish-eagle Haliaeetus vocifer 771 Collared Sunbird Hedydipna collaris 506 Rock Martin Hirundo fuligula 493 Barn Swallow Hirundo rustica 502 Greater Striped Swallow Hirundo cucullata 503 Lesser Striped Swallow Hirundo abyssinica 495 White-throated Swallow Hirundo albigularis 442 Lesser Honeyguide Indicator minor 441 Scaly-throated Honeyguide Indicator variegatus 398 African Pygmy-Kingfisher Ispidina picta 833 African Firefinch Lagonosticta rubricata 740 Black-bellied Starling Lamprotornis corruscus 737 Cape Glossy Starling Lamprotornis nitens 709 Southern Boubou Laniarius ferrugineus

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707 Common (Southern) Fiscal Lanius collaris 708 Red-backed Shrike Lanius collurio 287 Kelp Gull Larus dominicanus 138 Long-crested Eagle Lophaetus occipitalis 431 Black-collared Barbet Lybius torquatus 703 Cape Longclaw Macronyx capensis 704 Yellow-throated Longclaw Macronyx croceus 723 Grey-headed Bush-shrike Malaconotus blanchoti 395 Giant Kingfisher Megaceryle maximus 664 Southern Black Flycatcher Melaenornis pammelaina 129 Yellow-billed Kite Milvus aegyptius 458 Rufous-naped Lark Mirafra africana 44 Cape Gannet Morus capensis 685 African Pied Wagtail Motacilla aguimp 686 Cape Wagtail Motacilla capensis 688 Mountain Wagtail Motacilla clara 655 African Dusky Flycatcher Muscicapa adusta 656 Ashy Flycatcher Muscicapa caerulescens 219 Denham's Bustard Neotis denhami 268 Common Whimbrel Numenius phaeopus 745 Red-winged Starling Onychognathus morio 521 Black-headed Oriole Oriolus larvatus 519 Eurasian Golden Oriole Oriolus oriolus 844 African Quailfinch Ortygospiza atricollis 527 Southern Black Tit Parus niger 786 Cape Sparrow Passer melanurus 784 House Sparrow Passer domesticus 4142 Southern Grey-headed Sparrow Passer diffusus 48 Cape Cormorant Phalacrocorax capensis 50 Reed Cormorant Phalacrocorax africanus 47 White-breasted Cormorant Phalacrocorax carbo 256 Ruff Ruff Philomachus pugnax 419 Green Wood-hoopoe Phoeniculus purpureus 546 Terrestrial Brownbul Phyllastrephus terrestris 599 Willow Warbler Phylloscopus trochilus 671 Yellow-throated Woodland-warbler Phylloscopus ruficapilla 85 African Spoonbill Platalea alba 799 Cape Weaver Ploceus capensis 790 Dark-backed Weaver Ploceus bicolor 791 Spectacled Weaver Ploceus ocularis 797 Village Weaver Ploceus cucullatus 800 Yellow Weaver Ploceus subaureus 241 Grey Plover Pluvialis squatarola

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436 Red-fronted Tinkerbird Pogoniulus pusillus 171 African Harrier-Hawk Polyboroides typus 208 African Purple Swamphen Porphyrio madagascariensis 649 Tawny-flanked Prinia Prinia subflava 511 Black (Southern race) Saw-wing Psalidoprocne holomelaena 188 Red-necked Spurfowl Pternistis afer 545 Dark-capped Bulbul Pycnonotus tricolor 509 Brown-throated Martin Riparia paludicola 576 African Stonechat Saxicola torquatus 178 Red-winged Francolin Scleroptila levaillantii 72 Hamerkop Hamerkop Scopus umbretta 857 Cape Canary Serinus canicollis 665 Fiscal Flycatcher Sigelus silens 823 Bronze Mannikin Spermestes cucullatus 290 Caspian Tern Sterna caspia 291 Common Tern Sterna hirundo 299 Little Tern Sterna albifrons 298 Swift Tern Sterna bergii 314 Red-eyed Dove Streptopelia semitorquata 316 Cape Turtle-dove Streptopelia capicola 733 Common Starling Sturnus vulgaris 386 Alpine Swift Tachymarptis melba 4133 Knysna Turaco Tauraco corythaix 715 Black-crowned Tchagra Tchagra senegalus 713 Southern Tchagra Tchagra tchagra 722 Bokmakierie Bokmakierie Telophorus zeylonus 717 Olive Bush-shrike Telophorus olivaceus 719 Orange-breasted Bush-shrike Telophorus sulfureopectus 682 African Paradise-flycatcher Terpsiphone viridis 81 African Sacred Ibis Threskiornis aethiopicus 427 Crowned Hornbill Tockus alboterminatus 323 African Green-pigeon Treron calvus 263 Common Greenshank Tringa nebularia 262 Marsh Sandpiper Tringa stagnatilis 264 Wood Sandpiper Tringa glareola 680 Blue-mantled Crested-flycatcher Trochocercus cyanomelas 1105 Olive Thrush Turdus olivaceus 319 Tambourine Dove Turtur tympanistria 321 Emerald-spotted Wood-dove Turtur chalcospilos 418 African Hoopoe Upupa africana 245 Blacksmith Lapwing Vanellus armatus 846 Pin-tailed Whydah Vidua macroura 1172 Cape White-eye Zosterops virens

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APPENDIX 2: C.V.’S

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Caryn Lee Clarke Registration number: 500022/14

Candidate Natural Scientist

Environmental Science

23 July 2014 31 March 2019 Greer L. Hawley-McMaster Curriculum Vitae

CONTACT DETAILS

Name of Company CES – Environmental and Social Advisory Services Designation Principal Consultant Profession Environmental Consultant

Years with firm 11 (Eleven) Years E-mail [email protected] Office number +27 (0)43 7267809 / 8313

Nationality South African

Professional Body SACNASP: South African Council for Natural Scientific Profession

Key areas of expertise  Environmental Impact Assessment (Aquaculture, renewable energy, waste water treatment, agriculture)  Environmental Management and Planning  Biodiversity/Conservation Management  Biodiversity/Ecological Assessments PROFILE

Dr Greer Hawley has a BSc degree in Botany and Zoology and a BSc Honours in Botany from the University of Cape Town. She completed her PhD thesis (Microbiology) at Rhodes University. Greer has been involved in a number of diverse activities. The core academic focus has been in the field of taxonomy both in the plant and fungal kingdom. Greer's research ranges from fresh water and marine algae, estuarine diatoms, plant species classification in the fynbos and forest vegetation and fungal species identification and ecology. Greer has been involved in environmental and biodiversity impact assessments and environmental and biodiversity management projects both in South Africa and other African countries. Greer has recently assisted with the completion of the Eastern Cape Biodiversity Conservation Plan (2019), the Eastern Cape Biodiversity Strategy and Action Plan and assisted with the generation of the Western Cape State of the Coast Report. She is currently involved with developing the Environmental Management Framework for the King Cetshwayo District Municipality.

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Greer L. Hawley-McMaster Curriculum Vitae

EMPLOYMENT  1998 : Botanical consultant: University of Cape Town EXPERIENCE Laboratory assistant: University of Cape Town  1999 : Undergraduate Tutor: University of Cape Town  2000- 2001 : Temporary administrative positions: Robert Half International, London Assistant Office Manager: Warwick House, London Office administration: West London Magistrates Court, London  2002: Laboratory Assistant: Amphigro  2002- 2007: Undergraduate Tutor: Botany and Microbiology, Rhodes University  2006- 2007: Laboratory researcher: Abalone Probiotic isolation and testing, Rhodes University  2007: Laboratory assistant and product quality control: Mycoroot (Pty) Ltd, Grahamstown  2007- present : Principal Environmental Consultant - Coastal & Environmental Services

POST GRADUATE STUDENT SUPERVISION

 2005 – 2007: 3 Honours students in the Mycology Unit, Rhodes University  2006: MSc student in the Mycology Unit, Rhodes University.  2016-2018: Co-supervisor of a PhD student in the Mycology Unit, Rhodes University

ACADEMIC   PhD Microbiology Rhodes University 2008  QUALIFICATIONS BSc Hons Botany University of Cape Town 1999  BSc Natural Science (Botany and Zoology) University of Cape Town 1998

COURSES  Rhodes University-Coastal & Environmental Services: Environmental Impact Assessment Course 2008  Training in Greenhouse Gas Accounting for Forest Inventories Greenhouse Gas Management Institute 2009

CONSULTING ENVIRONMENTAL MANAGEMENT EXPERIENCE EXPERIENCE Specialist studies  Eastern Cape Biodiversity Conservation Plan review and Biodiversity Strategy and Action Plan (2016-2019). I am currently responsible for a number of roles on this project, including the following: • Project manager • Biodiversity data collection and analysis • Part of planning team • One of the report writing authors • Client and stakeholder liaison

 Waaihoek Wind Energy Facility (2013-2015): EIA and Ecological Sensitivity Assessment This assessment, located just east of Utrecht in KZN, involved two elements:

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Greer L. Hawley-McMaster Curriculum Vitae

an EIA and a detailed vegetation survey of Grassland and Thornveld (Savanna) culminating in an ecological sensitivity map.  Olivewood Golf Estate (2014): EIA and Ecological Sensitivity Assessment This assessment, located 25km north of East London in the Eastern Cape, involved two elements: an EIA and a detailed vegetation survey of Thicket, Thornveld (Savanna) and Forest vegetation culminating in an ecological sensitivity map.  Eastern Cape Biofuel Strategic Environmental Assessment (2014-2016) This assessment involved the detailed assessment of optimal grow areas against environmental constraints. The product was aimed at selecting the best clustered areas of growth potential, outlining the respective environmental constraints within these clusters, in order to guide investor interests. Detailed mapping analysis was undertaken.  Balama Graphite Mine and Tete Iron Mine, Mozambique (2013): Biodiversity Survey and Ecological Sensitivity Assessment These assessments were both located in Mozambique. Detailed biodiversity surveying and assessment of ecological sensitivity (identify NO-GO areas) were undertaken.  Addax BioEnergy (2009/2010), Biodiversity and Ecological Impact Assessment AND Carbon Stock Impact Assessment, Sierra Leone. The above specialist studies were submitted as separate deliverables and are described separately.  Biodiversity and Ecological Impact Assessment: This study involved the survey of a 60 000 ha site in Sierra Leone. The vegetation types were described and assessed in terms of biodiversity and overall ecological sensitivity. In addition, the area was surveyed by local experts for the presence of rare and endangered faunal species, for inclusion into the report. All vegetation types were mapped using GIS. The assessment was compiled for international review in accordance with World Bank standards.  Carbon Stock Impact Assessment: In accordance with the EU directive, Biofuel production needs to demonstrate a 30% reduction in carbon emissions compared to fossil fuels. For this reason, a Carbon Stock study was carried out to determine site specific carbon stocks. This study included field calculations, vegetation and soil sampling and carbon stock calculations according to internationally accepted standards and using best practice guidelines. Using the detailed GIS vegetation maps, total carbon stocks could be calculated. Sample collection included local academic soil scientists. This study and associated methodology was compiled according to the International Panel on Climate Change (IPCC) standards.  Wild Coast Forest Survey: (2009-2010) Department of Water and Forestry / Eastern Cape Parks Board initiative The forest survey included substantial field work and data collection of the following: plant species identification, GPS mapping of forest boundaries, forest-typing and identifying and quantifying disturbance impacts.  Mncwasa Water Scheme (2009): Ecological Sensitivity Assessment This assessment involved a detailed vegetation survey of forest vegetation and wetlands along anticipated and alternative pipeline routes. The survey included an assessment of the environmental sensitivity along the route and recommendations for mitigation and environmentally acceptable alternatives.

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 Peregrine Dunes Golf Estate (2009): Vegetation Rehabilitation Plan and Ecological Impact Assessment The Ecological Impact Assessment and Rehabilitation Plan were represented as two reports for the same project. The work carried out on the Ecological Impact Assessment included report revision writing. The Rehabilitation Plan was submitted as part of the Environmental Management Plan and incorporated elements of re-vegetation, alien plant removal and rehabilitation, landscape restoration, based on widely accepted concepts of soil ecology and plant succession ecology.

Feasibility studies  Coega IDZ Aquaculture Feasibility Study: Aspects of this study included the consideration of the environmental sustainability, economic and financial viability of the proposed project as well as an assessment of environmental risks and alternative project designs.  Ndakana Wind farm Feasibility Study  Nkanya Lodge Feasibility Study: Eastern Cape Development Corporation (ECDC) initiative Aspects of this study included the consideration of the economic and financial viability of the proposed project as well as the environmental risks and alternative technologies.

Full Scoping and Environmental Impact Assessments (South African National Environmental Management: EIA regulations)  Buffalo City Municipality R72 national road re-alignment (2007-2008): Sleeper site Responsibilities included: Project Management, budget management, written report, public participation and engagement with key stakeholders throughout the EIA process. Environmental approval obtained.  Wild Coast Abalone expansion and processing plant (2008) Responsibilities included: Project management, budget management, written reports, public participation and stakeholder engagement with key stakeholders. Environmental approval obtained.  Qolora Aquaculture Development Zone (2011) Responsibilities included: Project management, budget management, written reports, public participation and stakeholder engagement with key stakeholders. Environmental approval obtained.  All Saints Hospital Waste Water Treatment Works (2012) written reports, public participation and stakeholder engagement with key stakeholders. Environmental approval obtained.  Jamestown Waste Water Treatment Works (2012) Responsibilities included: Project management, budget management, written reports, public participation and stakeholder engagement with key stakeholders. Environmental approval obtained.  Ntabankulu Waste Water Treatment Works (2012) Responsibilities included: Project management, budget management, written reports, public participation and stakeholder engagement with key stakeholders. Environmental approval obtained.  Qamata: No-gate Waste Water Treatment Works (2012) Responsibilities included: Project management, budget management,

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written reports, public participation and stakeholder engagement with key stakeholders. Environmental approval obtained.  St Patricks Hospital Waste Water Treatment Works (2014) Responsibilities included: Project management and report review.

State of Environment (SoER), Environmental Management Plans (EMP) and Environmental Management Frameworks (EMF) for:  OR Tambo District Municipality SoER and EMP, Eastern Cape Province, South Africa (2009-2010). Accepted by council.  Joe Gqabi District Municipality SoER and EMP, Eastern Cape Province, South Africa. (2011)  Mnquma Local Municipality SoER and EMP, Eastern Cape Province, South Africa (2012)  Western Cape Province, State of the Coast Report, South Africa (2018)  King Cetswayo District Municipality Environmental Management Framework, KwaZulu-Natal Province, 2017-2019. Activities: o Field survey of district municipality through aerial surveying and field work reporting of whole district municipality (incorporating 4-7 local municipalities). o Continued interaction with municipal representatives and key stakeholders o Workshops held with key role-players and decision-makers o Review of planning documents and integrated development programs. o Identification of key environmental issues o Selection of priority environmental issues o Development of Environmental Management Action Plans directly aimed at mitigating priority issues.

o Collection and analysis of data

o Reporting on selected indicators

o Collection and analysis of spatial data Responsibilities: o Project manager, o Project lead, o Budget management, o Report writing, o Team delegation and management and o Client liaison.

Additional Specialist studies  Sensitive Ecology Assessment: Mncwasa Water Scheme (2009)  Vegetation Rehabilitation Plan: Peregrine Dunes Golf Estate (2009)  Ecological Impact Assessment: Peregrine Dunes Golf Estate (2009)  Vegetation Assessment: Atterbury Development (2008)  Wild Coast Forest Survey: (current) DWAF/EC Parks initiative (2009-2010)  Biodiversity and Ecological Impact Assessment, Sierra Leone, Addax Biofuels (2009-2010)

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Greer L. Hawley-McMaster Curriculum Vitae

 Land use Impact Assessment, Sierra Leone, Addax Biofuels (2009-2010)  Thyspunt – Melkhout Eskom Power line, Ecological Impact Assessment  Ecological Impact Assessment: Chaba WEF  Ecological Impact Assessment: Thomas River WEF  Ecological Impact Assessment: Qunu Renewable Energy Facility  Ecological Impact Assessment: Ncora Renewable Energy Facility  Ecological Impact Assessment: Ngqamakwe Renewable Energy Facility  Ecological Impact Assessment: Qumbu Wind Energy Facility  Terrestrial Ecology Impact Assessment: Qolora Aquaculture Zone  Toboshane Valley Estate: Ecological Impact Assessment  Toboshane Valley Estate: Conservation Management Plan  Biodiversity and Impact Assessment: Niassa Green Resource, Mozambique  Biodiversity and Impact Assessment: Balama Graphite Mine  Biodiversity and Impact Assessment: Tete Iron Ore Mine

Alien Invasive Monitoring, Control and Eradication Plans  ACSA East London Alien Invasive Plant assessment and eradication programme (2009 and 2016)  Rehabilitation and Restoration (including alien plant removal) Plan: Peregrine Dunes Golf Estate (2010)  Alien Invasive Plant Monitoring and Control Plan for the following Wind Energy Facilities:  Chaba WEF (2011)  Komga WEF (2016

 2018 (June): Hawley G and Desmet P. Eastern Cape Biodiversity Conservation Plan (Draft 3) and the Strategy and Action Plan. Thicket Forum  2017 (June): Hawley, G, Berliner, D and Desmet P. Eastern Cape Biodiversity PUBLICATIONS Sector Plan and Biodiversity Strategy and Action Plan. Biodiversity Planning Forum.  2017: Hawley, G, Berliner, D and Desmet P. Eastern Cape Biodiversity Sector Plan and Biodiversity Strategy and Action Plan. Thicket Forum  2016 (June): Hawley, G, Berliner, D and Desmet P. Eastern Cape Biodiversity Sector Plan and Biodiversity Strategy and Action Plan. Biodiversity Planning Forum.  2016: Hawley, G, Berliner, D and Desmet P. Eastern Cape Biodiversity Sector Plan and Biodiversity Strategy and Action Plan. Thicket Forum  2016: Hawley, G, Berliner, D and Desmet P. Eastern Cape Biodiversity Sector Plan and Biodiversity Strategy and Action Plan. International Association of Impact Assessment, South Africa.  2010: Hawley, GL, McMaster AR and Carter AR. The Environmental and Social Impact Assessment, and associated issues and challenges associated with Biofuels. African, Caribbean and Pacific Group of States (ACP), Science and Technology Programme, Sustainable Crop Biofuels in Africa.  2009: Hawley, GL, McMaster AR and Carter AR. Carbon, carbon stock and life-cycle assessment in assessing cumulative climate change impacts in the environmental impact process. International Association of Impact Assessors.  2008: Hawley GL and Dames JF. Ectomycorrhizal species diversity above- and

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below ground comparison in Pinus patula (Schlecht et Cham) plantations, South Africa. South African Society for Microbiology (Poster).  2006: Hawley, GL and Dames, JF. Morphological and molecular identification of ectomycorrhizal fungi in Pinus plantations. South African Society of Microbiology.

CERTIFICATION

I, the undersigned, certify that to the best of my knowledge and belief, this CV correctly describes me, my qualifications, and my experience. I understand that any wilful misstatement described herein may lead to my disqualification or dismissal, if engaged.

GREER LEIGH HAWLEY-MC MASTER Date: January 2019

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