DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 3.4 Applicable listed activities comment, will be amended accordingly. 3.4.1 Activity 14 of Government Notice (“GN”) No. R. 983 of 4 December 2014 may be triggered by the proposed development. Confirmation of whether dangerous goods 3.4.1 No dangerous goods will be will be stored on the proposed site and the volume thereof (if any) must be provided stored on site, and this is why in the EIA Report. this activity has been omitted. 3.4.2 Activity 28 of GN No. R. 984 of 4 December 2014 will be triggered by the 3.4.2. Please note that this proposed development as an Atmospheric Emissions Licence (“AEL”) in terms of the activity will be included as an National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) amendment to the application (“NEM:AQA”) is required. following the submission of the Air Quality Impact Assessment. 3.4.3 A revised Application Form may have to be submitted to the competent authority upon confirmation of the above-mentioned listed activities. 3.4.3 Please see above, thank you for highlighting this.

3.5.1 Agreed. The EIA report will 3.5 Alternatives investigate technology 3.5.1 According to the DSR, two site alternatives were identified and a site selection alternatives for these sites. matrix was undertaken to determine the preferred location of the proposed 3.6.1 This was included in the development. This includes site 1 (Cape Farm No. 1183 and Portion 93 of Cape Farm FSR, Chapter 6. No. 4, Atlantis) and site 2 (Portion 1 of Portion 4 of Cape Farm No, 1183, Atlantis). It is further noted that site 2 is the preferred site alternative based on the environmental 3.6.2. Noted, thank you. Chapter attributes, spatial character and proximity to sensitive human structures. 7 9Plan of Study) highlights the Alternatives for the generation of electricity from a non-renewable resource have ToR’s for all the studies which been identified, but were considered as not feasible for further assessment. The EIA are being conducted, as well as Report must therefore provide an assessment of the technology alternatives to be the three studies already considered for the proposed development. When selecting the preferred conducted. alternative, please be advised that the alternative with the least environmental 3.6.3. Noted, thank you. impacts must be deemed as the most reasonable and feasible alternative. 3.7.1. Correct.

3.7.2. This will be verified and 3.6 Impact assessment updated. 3.6.1 It is noted that a preliminary scoping phase impact assessment was conducted

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP based on existing information and the results of this preliminary assessment will be 3.7.3. Correct. Please note that verified by the relevant specialists during the EIA phase. A list of the potential an Avifaunal Assessment is also impacts associated with the proposed development must be provided in the Final going to be conducted to assess Scoping Report to be submitted to the competent authority. the impacts of the transmission lines. 3.6.2 All the potential impacts associated with the proposed development are to be assessed and/or reported on in the EIA Report. 3.8. An Emergency Response Plan will be included in the Draft 3.6.3 A detailed description of storm water and effluent management must be EIA report, which will be able to included in the EIA Report and the Environmental Management Programme be commented on and amended (“EMPr”) must provide suitable prevention/ mitigation measures for these aspects. accordingly.

3.9. The EAP will obtain this 3.7 Specialist reports confirmation in the EIA phase. 3.7.1 It is understood that the following specialist reports (conducted as part of a 3.10.1 Noted, thank you. previous EIA process) will be used to assess some of the potential impacts identified

as part of this EIA application:

(i) Botanical Assessment (compiled by Bergwind Botanical Surveys and Tours, dated June/July 2012); (ii) Paleontological Assessment (compiled by G. Avery, dated July 2012); and (iii) Archaeological Input (compiled by ACO Associates, dated 10 July 2012). 3.7.2 The mentioned specialist reports along with updated statements have been included in the DSR. It is important to note that the specialist reports all refer to the

development on Portion 1 and Portion 4 of Cape Farm No. 1183, Atlantis.

3.7.3 It is further understood that the following specialist assessments will be undertaken as part of the EIA reporting phase, being an Air Quality Impact Assessment; Noise Impact Assessment; and a Risk Assessment.

3.8 Plan of Study for EIA

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 3.8.1 The Plan of Study for EIA must include the compilation of an Emergency Response Plan (as per the City of Cape Town’s requirements) since the proposed site

is located within the 16km Urgent Protective Zone of the Koeberg nuclear power plant.

3.9 Confirmation of services 3.9.1 Confirmation that the local authority has sufficient, spare unallocated capacity to provide water, sewage disposal, refuse removal and electricity services must be

included in the EIA Report.

3.10 General

3.10.1 The DSR incorrectly refers to this Department’s Guideline on Need and Desirability, 2010. The correct reference is the Guideline on Need and Desirability dated March 2013, which forms part of the EIA Guideline and Information Document

Series (March 2013).

4. Directorate: Waste Management – Gary Arendse ([email protected]; Tel: (021) 483 3872):

4.1 Section 4.2.1 of the DSR must be amended to include the applicability of the National 4.1 This is noted, thank you. Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) and its subordinate Please note no hazardous and/or legislation to the proposed development. Your attention is drawn to GN No. No. 926 of 29 general waste will be stored on November 2013: National Norms and Standards for the Storage of Waste. Please be advised site and this legislation does not that the storage of hazardous and general waste in excess of 80m³ and 100m³ respectively, apply. excluding the storage of waste in lagoons or the temporary storage of such waste, would 4.2 The Draft EMPr will contain require the applicant to comply with said norms and standards. detailed information regarding the disposal and management of

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP waste. 4.2 The EIA Report must provide detailed information on the volume of waste to be 4.3. Noted, this will be included. generated and how waste from the proposed CCGT plant and associated infrastructure

during the construction and operational phase will be managed. The waste management hierarchy (reduction, re-use and recycling of waste) must be implemented to ensure that the disposal of waste should only be as a last resort. Any resulting waste generated during the

construction/commissioning and operation of the proposed development which cannot be re-used or recycled, must be disposed of at a licensed waste disposal facility.

4.3 The EMPr to be included with the EIA Report must address the prevention and management of potential leaks and spillages of hazardous substances. Any hazardous

substances and fuel must be kept in storage areas that are bunded and with a capacity to contain 110% of the volume of any hazardous substances and fuel. Spill kits must be available on-site for clean-up of potential spills.

5. Directorate: Air Quality Management – Peter Harmse

([email protected]; Tel: (021) 483 8343):

5.1 Noise and dust management: 5.1.1 This is noted and these 5.1.1 The Air Quality Impact Assessment to be undertaken during the EIA phase must impacts will be taken into take cognisance of the National Dust Control Regulations (GN No. R. 827) of 1 consideration. November 2013, promulgated in terms of NEM:AQA. These regulations prohibit a person from conducting any activity in such a way as to give rise to dust in such 5.1.2 The Draft EIA report will quantities and concentrations that the dust or dust fall may have a detrimental include this regulation, as well as effect on the environment, including health. the Draft EMPr. 5.1.2 It is noted that a Noise Impact Assessment will be conducted during the EIA 5.2.1. Odour may be briefly phase. Please be advised that Section 8.7.2 of the Plan of Study for EIA must be discussed in the DEIR, however, amended to indicate that noise generated from the installation and operation of the this is not deemed a significant

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP CCGT facility (gas turbines/gas engines, electric generators, dry cooling systems, impact in the Scoping Phase. possible rail car noise, etc.) must comply with the Western Cape Noise Control 5.2.2. Please note that an Air Regulations (Provincial Notice 200/2013) of 20 June 2013. Quality Impact Assessment is being conducted for the proposed development. 5.2 Impact management: 5.2.3 Noted, thank you. 5.2.1 The EIA Report must indicate whether the proposed development will result in any offensive odour impacts. Your attention is drawn to Section 35(2) of NEM:AQA, which states that an occupier of the premises must take all reasonable steps to

prevent the emission of any offensive odour caused by any activity at the gas-to- power plant. Any offensive odour complaints must be recorded, reported and investigated, should it be required.

5.2.2 It is expected that possible emissions to air from a gas turbine facility would

include carbon dioxide, water vapour, carbon monoxide, oxides of nitrogen, and minor emissions of metals and metal compounds and organics. 5.2.3 Other emissions of air pollutants are expected from gas venting during commissioning, maintenance shutdowns and from process vents. The Air Quality

Impact Assessment must identify appropriate management and mitigation measures to address the emission sources from the proposed CCGT facility.

5.3 Atmospheric emission listed activities: 5.3.1 Section 4.2.1 of the DSR must be amended to indicate that an AEL is required 5.3.1 This will be included in the and must indicate the atmospheric emission listed activity(ies) that will be triggered DEIR. by the proposed CCGT facility. 5.3.2 Thank you, this will be considered in the specialist study. 5.3.2 The proposed development triggers the following atmospheric emission listed activity identified in GN No. 893, promulgated in terms of Section 21 of NEM:AQA, being Category 1 (Combustion Subcategory 1.4 (Gas Combustion Installations) which

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP is described as “Gas combustion (including gas turbines burning natural gas) used primarily for steam raising or electricity generation” and is applicable to “All

installations with design capacity equal to or greater than 50MW heat input per unit, based on the lower calorific value of the fuel used”.

5.3.3 The proposed development may also include the storage of petroleum 5.3.3 At the Scoping Level products. It should be noted that Subcategory 2.4 (Storage and Handling of assessment, it is not foreseen Petroleum Products) is applicable to “All permanent immobile liquid storage facilities that any petroleum will be at a single site with a combined storage capacity of greater than 1 000 cubic meters”. stored on site, however, this will The EIA Report must indicate the petroleum storage capacity of the CCGT facility to be investigated further in the EIA determine whether Subcategory 2.4 of GN No. 893 is triggered by the proposed phase. development.

5.3.4. Noted, thank you. 5.3.4 The design and operation of the CCGT facility must comply with the Minimum

Emission Standard as listed under the above-mentioned subcategories. 5.3.5. This comment is being

considered after the Final 5.3.5 Please be advised that in terms of Section 36(5)(c) of the NEM:AQA, 2004 that Scoping Report has been the Minister responsible for environmental affairs is the licensing authority for the submitted to the Competent AEL application. This Directorate strongly recommends that the AEL application be Authority, however, due to the submitted to the licensing authority when the Final Scoping Report is submitted to December shutdown period of the competent authority. the DEA as per the regulations, the EAP will aim to submit the

AEL application with the Draft 6. Please direct all enquiries to the officials indicated in this correspondence should you EIA report, so as to streamline require any clarity on any of the issues/comments provided. the process. 6. Noted, thank you. 7. The Department reserves the right to revise initial comments and request further 7. Noted, thank you. information based on the information received.

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 2 1/12/2016 1. Spatial Planning and Urban Design (Ms L Steenkomp / L. Kruger-Fountain) EAP: CSIR thanks CoCT for these comments. Email 1.1 The Spatial Planning & Urban Design department's previous comment has sufficiently been included in the revised draft scoping report. 1.1 Noted, thank you. Morné Theron 2.1 Thank you for this comment Environmental and and apologies for no prior Heritage Management 2. City of Cape Town: Transport for Cape Town (Mr J Massyn) clarification. A scoping-level Branch-Environmental 2.1 City of Cape Town: Transport for Cape Town (TCT) indicated in the City's previous Traffic Assessment for these Resource Management comment that the proposed access off Neil Hare Road on the northern end of the site which routes has been included in the Department (ERMD) necessitates a level crossing across the railway line, is not supported. TCT indicated that FSR (Chapter 6). Following this City of Cape Town access should be taken off Neil Hare Road on the southern boundary or Gideon Basson Road. comment, we will revise our Municipality This comment by TCT was included in the revised scoping report's comments and responses traffic assessment to consider table, but no response from the EAP is recorded against this comment. these comments in the Draft EIA report.

2.2 The Traffic Assessment 2.2 In addition Chapter 2 (page 2-7) states that the access from the north is preferable whilst (Chapter 6 FSR) stated the it also states that the access from the south is more viable. Conversely if is again stated in the following: Services Report (Appendix I. Section 8.1, page 10) that the preferred access to the site if off Neil Hare Road on the northern end of the site. The aforementioned contradictions are Section 8 of the GIBB report confusing and it should be clarified which access will be used. discusses the proposed road access to this site. The proposed

access roads to be used are 2.3 TCT reiterates that only the access to the site should be taken from the south off Neil showed in Figure 6.2 below. The Hare Road or Gideon Basson Road. The primary reason for a southern access point being that preferred access onto the local it will eliminate the railway crossing. road network will be at the northern end of the site onto

Neil Hare Road. Neil Hare Road is 3. City of Cape Town: Specialized Health Services: Air Quality Branch (Ms L. Motthys) linked to Dassenberg Road via an “unnamed” road. The junction 3.1 The revised draft scoping report has sufficiently incorporated the initial comments between the site access and Neil submitted by the Air Quality Branch. As such the Branch is satisfied with the initial impacts Hare Road, as well as the identified by the EAP and included in the proposed Plan of Study for the EIA. junction of Neil Hare Road and

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP “unnamed” road and “unnamed” road and 4. City of Cape Town: Economic Development (Mr C. Hewett) Dassenberg Road will all have to be widened to accommodate the sweep area for extra-large 4.1 The Department indicated that it is satisfied with the EAP's response to its comments on vehicle turning requirement. the initial draft scoping report (DSR) as outlined in chapter 5 of the revised DSR. It is worth to note that the department is fully supportive of renewable energy generation in Atlantis. The The access location from the site City of Cape Town established a green technology manufacturing and renewable energy hub onto Neil Hare Road will result in in Atlantis in 2011 in response to the Department of Energy's Renewable Energy Independent crossing an operational railway Power Producer Programme (REIPPP). Localisation of manufacturing and the resultant job track. A level crossing and right creation is one of the key priorities of government through the REIPP programme. of way servitude will have to be negotiated with Transnet to

facilitate a road over rail level 5. City of Cape Town: Environmental Resource Management (Mr M. Theron) crossing to gain access onto Neil Hare Road. 5.1 It has come to the City of Cape Town's attention that the Surveyor General's office converted all Cape Farms in Atlantis Industrial (which are zoned Industrial) to Atlantis 2.3 As seen above, this Industrial Erven. The City's Corporate 315 system has recently converted all Cape Allotment contradicts the route proposed (CA) or farm numbers, to the new erf numbers. As such the erf numbers reflected in the in the FSR. The access routes will revised draft scoping report are outdated. be re-assessed to consider your comments. 5.1.1 Option 1's new erf number is 171 (was previously Remainder CFM 1183 and Portion 4 of CFM 93): and 3.1 Noted, thank you. 4.1 Noted, thank you. 5.1.2 Option 2's new erf number is 277 (was previously Portion l and 4 of CFM 1 183) 5.1 Thank you for bringing this to our attention; this will be

amended going forward. This 5.2 Chapter 1, Introduction, Locality Map (pg 1-3): Specify the property erf numbers on the will form part of the EA. plans. Site 1 (Erf 171) and Site 2 (Erf 277) for ease of reference. 5.2 This will be amended in the DEIR. 5.3 All other comment on, and/or errors to the previously DSR raised by the Environmental

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP Resource Management department have adequately been addressed in the revised DSR. 5.3 Noted, thank you, Noted, thank you. The City therefore concurs with the proposed Plan of Study for the EIA phase as well as the Terms of References for the specialist studies. The abovementioned comment must be included in the draft EIR. Kindly submit the draft Environmental Impact Assessment Report (once available) to this office in the form of l x hard copy and l x CD version.

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1.5 DEA’s COMMENTS ON THE FINAL SCOPING REPORT

The section presents the issues raised following the submission of the Final Scoping Report to DEA. A copy of these comments is included in Appendix G of this Draft EIA report.

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 1 01/02/2017 The Scoping Report (SR) and Plan of Study for Environmental Impact Assessment Response from EAP: (PoSEIA) dated November 2016 and received by this Department on 06 January 2017 Email refer. i. Noted. Please see Chapter 6 for the full Impact Assessment. Mr. Sabelo Malaza This Department has evaluated the submitted SR and the PoSEIA dated November ii. Noted. Please Chapter 4 for a list 2016 and is satisfied that the documents comply with the minimum requirements of of the activities applied for. Chief Director: IEA the Environmental Impact Assessment (EIA) Regulations, 2014. The SR is hereby iii. Please see Chapter 2, Section 2 accepted by the Department in terms of Regulation 22(a) of the EIA Regulations, Department of 2014. where this table provided by Environmental Affairs DEA has been included. You may proceed with the EIA process in accordance with the tasks contemplated in iv. Please see Chapter 2, Section 2.1 the PoSEIA and the requirements of the EIA Regulations, 2014. for the corner co-ordinates of the site, as well as Chapter 2 for All comments and recommendations made by all stakeholders and Interested and a map indicating the corner co- Affected Parties (I&APs) in the draft SR and submitted as part of the final SR must be taken into consideration when preparing an Environmental Impact Assessment ordinates of the site. Please note report (EIAr) in respect of the proposed development. Please ensure that all that all this GIS information as mitigation measures and recommendations in the specialist studies are addressed requested has also been and included in the final EIAr and Environmental Management Programme (EMPr). submitted electronically on a CD to DEA along with this report. Please ensure that comments from all relevant stakeholders are submitted to the v. Please see Chapter 2 for a map Department with the final EIAr. This includes but is not limited to the Western Cape of the proposed layout of the Department of Environmental Affairs and Development Planning, the Department of Agriculture, Forestry and Fisheries (DAFF), the provincial Department of Agriculture, facility drawn to scale, and

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP SENTECH, the Department of Transport, the Department of Water and Sanitation Chapter 2 for a description of all (DWS), the South African National Roads Agency Limited (SANRAL), the South associated infrastructure. African Heritage Resources Agency (SAHRA), the Endangered Wildlife Trust (EWT), vi. This Appendix H of the report BirdLife SA, the Department of Mineral Resources, Cape Nature and the Department (Appendix H) provides a detailed of Environmental Affairs: Air Quality Management and Biodiversity and Conservation Directorates. comments and responses report for the scoping phase (and all You are also required to address all issues raised by Organs of State and l&APs prior iterations of the scoping reports to the submission of the EIAr to the Department. to date) and the process up to date. Please ensure that the EIAr and EMPr comply with Appendix 3 and Appendix 4 of vii. Please see Chapter 4 Regulation 2014, before submission to the Department. You are also required to highlighting the public address all issues raised by organs of state and l&APs prior to the submission of the ElAr to the Department. participation process undertaken for this project to Proof of correspondence with the various stakeholders must be included in the EIAr. date. Appendices C to H include Should you be unable to obtain comments, proof should be submitted to the proof of the steps taken in the Department of the attempts that were made to obtain comments. PPP.

viii. Please see the comments and The EAP must, in order to give effect to Regulation 8, give registered l&APs access responses above and how the to, and an opportunity to comment on the report in writing within 30 days before submitting the final EIAr to the Department. comments on the Draft Scoping Report were addressed. In addition, the following additional information is required for the EIAr: ix. CSIR agrees that long-term planning is desirable for all i. The draft EIAr must provide an assessment of the impacts and environmental management mitigation measures for each of the listed activities applied for. activities. However, we ii. The listed activities represented in the ElAr and the application form must be the same and correct. respectfully submit that it is iii. The EIAr must provide the technical details for the proposed facility in a neither practical, not physically table format as well as their description and/or dimensions. A sample possible to pre-empt potential for the minimum information required is listed under point 2 of the EIA infrastructure and/or technology

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP information required for gas facilities below. which may, or may not replace iv. The EIAr must provide the four corner coordinate points for the the proposed development in 30 proposed development site (note that if the site has numerous bend years’ time. Firstly, any future points, at each bend point coordinates must be provided) as well as the development of the site, post- start, middle and end point of all linear activities. decommissioning, is subject to a v. The ElAr must provide clearly indicate the following:  The envisioned area for the proposed facility; i.e. placing of all separate and wholly unrelated associated infrastructure should be mapped at an appropriate Environmental Authorisation scale. (EA) application process which  Areas of the facilities to be utilised during the different phases of cannot reasonably be conflated the operation. with the present EA application  Indicate the power output for all phases of the development. to develop a gas-to-power  The preferred layout and length of the 132kV power line. facility. Secondly, the rate of  Description of all associated infrastructure. This description must technological advance, include, but is not limited to the following: o Power lines; particularly within the field of o Internal roads infrastructure; and; energy generation technology, o All supporting onsite infrastructure such as laydown area, precludes the possibility of any guard house and control room etc. reasonably accurate speculation o All necessary details regarding all possible locations and as to future upgrading of the sizes of the proposed satellite substation and the main facility to more advanced substation. vi. The ElAr must also include a comments and response report in technologies. Thirdly, it stands accordance with Appendix 2 h (iii) of the EIA Regulations, 2014. to reason that speculation vii. The EIAr must include the detail inclusive of the PPP in accordance with regarding uncertain future Regulation 41 of the EIA Regulations. developments, unrelated to the viii. The EIAr must adhere to the all the comments issued by this current application, and based Department on the draft SR dated 14 November 2016. on potential future technology; ix. Details of the future plans for the site and infrastructure after should not form part of a facts- decommissioning in 20-30 years and the possibility of upgrading the proposed infrastructure to more advanced technologies. based EIA assessment. Lastly, CSIR is not in a position to

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP x. The terms of reference (ToR) for the following specialist studies are speculate on the content of accepted to be assessed in the assessment phase: future Integrated Resource Planning (IRP) and Integrated Electricity Planning (IEP) policy NAME ORGANISATION ROLE/STUDY TO BE documents which would UNDERTAKEN ultimately determine whether Mr Mark Zunckel uMoyo-Nilu Consulting Air Quality Specialist Study the proposed facility should be (Pty) Ltd decommissioned or upgraded Dr Brian Williams SafeTech Noise Impact Study once it reached the end of its Mr. Mike Riscom (Pty) Ltd Risk Assessment operational life. Oberholzer x. Noted. Dr. Graham Avery N/A Palaeontology Study xi. Your attention is respectfully Dr. Lita Webley ACO Associates Archaeology Assessment drawn to Chapter 6 (Traffic) of Dr. David Bergwind Botanical Terrestrial Ecology Study the EIA Report. This section McDonald Surveys and Tours presents the findings of a Mr Chris van Chris van Rooyen Avifauna (birds) previous Traffic Impact Rooyen Consulting Assessment Assessment (TIAs) conducted in connection with proposed industrial-scale developments on xi. A traffic impact assessment must be conducted and included in the Portion 1 of Portion 4 of Cape draft EIAr. The terms of reference for the traffic impact assessment must include: Farms 1183 (i.e. Site 2), and the a. Evaluation of the impacts of the proposed development on existing neighbouring Eskom Ankerlig road network and traffic volumes; Gas-to-Power development. b. Identification of the position and suitability of the preferred access Your attention is further drawn road alternative; to the findings contained under c. Evaluation of the roadway capacity of the road network; the heading “Traffic Impact d. Confirmation of the associated clearances required for the Statement” on page 6-18 of the necessary equipment to be transported from the point of delivery Scoping Report, which states

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP to the various sites; that, based on the available e. Confirmation of the freight and transport requirements during evidence as per the previous construction, operation and maintenance; traffic studies conducted for the f. Propose origins and destinations of equipment; and two projects quoted above; no g. Determination of (Abnormal) Permit requirements if any. TIA for the proposed Atlantis xii. A social impact assessment must be conducted and included in the draft Gas-to-Power project is required. EIAr. The terms of reference for the social impact assessment must Subsequently, it is the EAP’s include: considered opinion that a SIA is a. A description of the socio-economic context of the area; not required for the present b. A description of the development planning context; application. c. Discussion of the social benefits for the area; xii. Your attention is respectfully d. Identification and assessment of the socio-economic impacts of the proposed development in the area throughout all the phases of the drawn to paragraph 4.10, page development; and 18 of Appendix H to the Scoping e. Recommendation of the mitigation of identified negative impacts Report, which contains the and enhancement of identified positive impacts. Environmental Authorisation xiii. A specialist study must be conducted to investigate and assess the issued by the Western Cape climate change risks associated with the proposed development. Department of Environmental xiv. The air quality assessment must also Identify and predict the significance of direct, indirect and cumulative risks / impacts arising Affairs and Development from the activity for the key stages of the project including Planning (DEADP) for the preconstruction, construction, operation and post-closure; and identify development of a green management and mitigation measures and actions that addresses the manufacturing facility on Portion direct, indirect and cumulative risks and impacts. 1 of Portion 4 of Cape Farms 1183 xv. It is noted that the LNG supply for the proposed development depends (i.e. Site 2). According to on the finalisation of the proposed gas pipeline between Saldanha Bay paragraph 4.10, DEADP already and the Caltex Tableview Refinery, as such, the EIAr must clearly assess the preferred connection route and indicate the terms of reference for considered the impact of an assessment of all associated impacts. industrial-scale development on xvi. The EIAr must clearly indicate information on services required on the the socio-economic conditions site, e.g. sewage, refuse removal, water and electricity.

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DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP xvii. Where specialist studies are conducted in-house or by a specialist other of the study area, and than a suitably qualified specialist in the relevant field, such specialist subsequently concluded that an reports must be peer reviewed by a suitably qualified external specialist industrial facility, developed on in the relevant field. The terms of reference for the peer review must Portion 1 of Portion 4 of Cape include: Farms 1183, will not have a a. A CV clearly showing expertise of the peer reviewer; b. Acceptability of the terms of reference; detrimental impact socio- c. Is the methodology clearly explained and acceptable; economic impact. On the d. Evaluate the validity of the findings (review data evidence); contrary, DEADP finds that such e. Discuss the suitability of the mitigation measures and a development will have an recommendations; employment creation and f. Identify any short comings and mitigation measures to address the economic growth benefit to the short comings; g. Evaluate the appropriateness of the reference literature; larger Atlantis area. h. Indicate whether a site-inspection was carried out as part of the Subsequently, it is the EAP’s peer review; and considered opinion that a SIA is i. Indicate whether the article is well-written and easy to understand. not required for the present xviii. Should the appointed specialists specify contradicting application. recommendations, the EAP must clearly indicate the most reasonable xiii. Please note that the ToR for the recommendation and substantiate this with defendable reasons; and Air Quality Specialist study was where necessary, include further expertise advice. xix. It is imperative that a reliable water source is secured for the success of amended to include climate this project. The Department requests proof of availability of water for change impacts for the the facility from the relevant authority. proposed project. Please see xx. The ElAr must adequately assess and provide a comparative analysis for Appendix M for the Air Quality alternative water sources for the proposed development. The preferred and Climate Change Specialist water source alternative must further motivate the preferred Study. technology choice for the facility. xiv. Please see the impact xxi. A cumulative assessment must be undertaken for the sourcing of water as the facility is located in a water stressed area. assessment section of Appendix xxii. The ElAr must assess the impacts of use of water on site (sourcing, M. treating, disposing etc.) xv. The gas supply pipeline does not

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 77 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP xxiii. The ElAr must provide a detailed description of the need and form part of this EA application desirability, not only providing motivation on the need for clean energy and is not part of the proposed in South Africa of the proposed activity. The need and desirability must project infrastructure. It is also indicate if the proposed development is needed in the region and if therefore our respectful the current proposed location is desirable for the proposed activity compared to other sites. The need and desirability must take into submission that the gas pipeline account cumulative impacts of the proposed development in the area. route and its associated studies xxiv. Due to the presence of a similar electricity generation facility in the fall beyond the scope of this EIA area, all the specialist assessments must include a cumulative process. environmental impact assessment for all identified and assessed xvi. Please see Appendix I for a full impacts. The cumulative impact assessment must indicate the municipal services report for this following: site. A more specific description a. Identified cumulative impacts must be clearly defined, and where possible the size of the identified impact must be quantified and is provided in Chapter 3, Section indicated, i.e. hectares of cumulatively transformed land. 3.3.11. Please note the City of b. Detailed process flow and proof must be provided, to indicate how Cape Town Municipality was the specialists recommendations, mitigation measures and consulted for this information. conclusions from the various similar developments in the area were xvii. There are no specialist studies taken into consideration in the assessment of cumulative impacts conducted in house. Please see and when the conclusion and mitigation measures were drafted for the Appendices pertaining to the this project. c. The cumulative impacts significance rating must also inform the specialist studies which include need and desirability of the proposed development. CV’s. d. A cumulative impact environmental statement on whether the xviii. Noted. proposed development must proceed. xix. Please refer to Appendix M for the municipal services report. xxv. Please note that information on location of renewable energy We would like to strongly developments can be accessed from https://www.environment.gov.za/mapsgraphics. reiterate that the operation of xxvi. A copy of the final site layout map and alternatives. All available this facility will be implementing biodiversity information must be used in the finalisation of the layout a dry-cooling system specifically map. Existing infrastructure must be used as far as possible e.g. roads. due to the fact that this is a

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 78 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP The layout map must indicate the following: water scarce region. Only a. Positions of the power island, steam turbine and generator, fuel domestic water will be needed storage tanks, water storage reservoir and tanks, water and gas and this will be provided by the supply pipelines; municipality. Please refer to b. Permanent laydown area footprint; Chapter 2 where it is stated that c. Internal roads indicating width (construction period width and operation period width) and with dry cooling technology is d. numbered sections between the other site elements which they preferred for this project. serve (to make commenting on sections possible); xx. Please refer to response xix e. Wetlands, drainage lines, rivers, stream and water crossing of roads above and note that this facility and cables indicating the type of bridging structures that will be will be dry cooled. used; xxi. Please refer to response xix f. The location of sensitive environmental features on site eg. CBAs, heritage sites, wetlands, drainage lines etc. that will be affected by above and note that this facility the facility and its associated infrastructure; will be dry cooled. g. Substation(s) and/or transformer(s) sites including their entire xxii. Please refer to Part B: EMPr for a footprint; description of waste and storm h. Connection routes (including pylon positions) to the water management. Appendix distribution/transmission network; M also highlights what municipal i. All existing infrastructure on the site, especially roads; services are prepared for this j. Buffer areas; k. Buildings, including accommodation; and site. l. All “no-go” areas. xxiii. Please see Chapter 1, Table 1.1 xxvii. An environmental sensitivity map indicating environmental sensitive for detailed information on areas and features identified during the EIA process. needs and desirability. xxviii. A map combining the final layout map superimposed (overlain) on the xxiv. Please refer to Chapter 6 for a environmental sensitivity map. full assessment of the xxix. A shapefile of the preferred development layout/footprint must be submitted to this Department. The shapefile must be created using the cumulative impacts for the Hartebeesthoek 94 Datum and the data should be in Decimal Degree proposed project. Format using the WGS 84 Spheroid. The shapefile must include at a xxv. Noted. minimum the following extensions i.e. .shp; .shx; .dbf; .prj; and, .xml xxvi. Please see Chapter 2 for the final

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 79 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP (Metadata file). If specific symbology was assigned to the file, then the site layout map including all the avl and/or the .Iyr file must also be included. Data must be mapped at a listed requirements. scale of 1:10 000 (please specify if an alternative scale was used). The xxvii. Please see Chapter 2 and 3 for an metadata must include a description of the base data used for environmental sensitivity map. digitizing. The shapefile must be submitted in a zip file using the EIA application reference number as the title. The shape file must be xxviii. Please see Chapter 2 for a map submitted to: layout map superimposed with environmental sensitivities. xxix. Shapefiles with the mentioned Postal Address: requirements are being Department of Environmental Affairs submitted to the Department Private Bag X44? electronically along with this Pretoria 0001 Draft EIA report.

Physical address: EMPr: Environment House 473 Steve Biko Road i – xvii. Please note all of these Pretoria requirements have been included in the EMPr which is attached to this report as For Attention: Muhammad Essop Part B. Integrated Environmental Authorisations Strategic Infrastructure Developments Other responses from the EAP: Telephone Number: (012) 399 9406 Email Address: [email protected]  Please see Heritage Western Cape’s comment on this The Environmental Management Programme (EMPr) to be submitted as part of the application in Appendix Q. ElAr must include the following:  Please see comments below i. All recommendations and mitigation measures recorded in the ElAr and the specialist studies conducted. from Eskom on this project as ii. The final site layout map. requested by DEA in their iii. Measures as dictated by the final site layout map and micro-siting. acceptance of Scoping

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 80 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP iv. An environmental sensitivity map indicating environmental sensitive (01/02/2017). areas and features identified during the EIA process.  Please note that all information v. A map combining the final layout map superimposed (overlain) on the requested in Annexure A of this environmental sensitivity map. letter were submitted to the vi. An alien invasive management plan to be implemented during construction and operation of the facility. The plan must include Department, either mitigation measures to reduce the invasion of alien species and ensure electronically (i.e. the GIS that the continuous monitoring and removal of alien species is information) or herewith undertaken. contained in this report. vii. A plant rescue and protection plan which allows for the maximum transplant of conservation important species from areas to be transformed. This plan must be compiled by a vegetation specialist familiar with the site and be implemented prior to commencement of the construction phase. viii. A re-vegetation and habitat rehabilitation plan to be implemented during the construction and operation of the facility. Restoration must be undertaken as soon as possible after completion of construction activities to reduce the amount of habitat converted at any one time and to speed up the recovery to natural habitats. ix. An open space management plan to be implemented during the construction and operation of the facility. x. A traffic management plan for the site access roads to ensure that no hazards would result from the increased truck traffic and that traffic flow would not be adversely impacted. This plan must include measures to minimize impacts on local commuters e.g. limiting construction vehicles travelling on public roadways during the morning and late afternoon commute time and avoid using roads through densely populated built-up areas so as not to disturb existing retail and commercial operations. xi. A storm water management plan to be implemented during the construction and operation of the facility. The plan must ensure compliance with applicable regulations and prevent off-site migration

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 81 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP of contaminated storm water or increased soil erosion. The plan must include the construction of appropriate design measures that allow surface and subsurface movement of water along drainage lines so as not to impede natural surface and subsurface flows. Drainage measures must promote the dissipation of storm water run-off. xii. A fire management plan to be implemented during the construction and operation of the facility. xiii. An erosion management plan for monitoring and rehabilitating erosion events associated with the facility. Appropriate erosion mitigation must form part of this plan to prevent and reduce the risk of any potential erosion. xiv. An effective monitoring system to detect any leakage or spillage of all hazardous substances during their transportation, handling, use and storage. This must include precautionary measures to limit the possibility of oil and other toxic liquids from entering the soil or storm water systems. xv. Measures to protect hydrological features such as streams, rivers, pans, wetlands, dams and their catchments, and other environmental sensitive areas from construction impacts including the direct or indirect spillage of pollutants. xvi. An air quality management plan. xvii. Emergency preparedness response plan.

The EAP must provide detailed motivation if any of the above requirements is not required by the proposed development and not included in the EMPr.

The EAP must provide the final detailed Site Layout Plan as well as the final EMPr for approval with the final ElAr as this Department needs to make a decision on the EA, EMPr and Layout Plan.

Please ensure that all the relevant Listing Notice activities are applied for, that the Listing Notice activities applied for are specific and that they can be linked to the

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 82 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP development activity or infrastructure in the project description.

You are hereby reminded that should the ElAr fail to comply with the requirements of this acceptance letter, the project will be refused in accordance with Regulation 24t1 Nb) of the EIA Regulations, 2014.

The applicant is hereby reminded to comply with the requirements of Regulation 45 with regard to the time period allowed for complying with the requirements of the Regulations, and Regulations 43 and 44 with regard to the allowance of a comment period for interested and affected parties on all reports submitted to the competent authority for decision-making. The reports referred to are listed in Regulation 43(1).

Furthermore, it must be reiterated that, should an application for Environmental Authorisation be subject to the provisions of Chapter II, Section 38 of the National Heritage Resources Act, Act 25 of 1999, then this Department will not be able to make nor issue a decision in terms of your application for Environmental Authorisation pending a letter from the pertinent heritage authority categorically stating that the application fulfils the requirements of the relevant heritage resources authority as described in Chapter II, Section 38(8) of the National Heritage Resources Act, Act 25 of 1999. Comments from SAHRA and/or the provincial department of heritage must be provided in the ElAr.

You are requested to submit two (2) electronic copies (CD/DVD) and one (1) hard copies of the ElAr to the Department as per Regulation 23(1) of the EIA Regulations, 2014.

Please also find attached information that must be used in the preparation of the ElAr. This will enable the Department to speedily review the ElAr and make a decision on the application.

You are hereby reminded of Section 24F of the National Environmental Management Act, Act No 107 of 1998, as amended, which stipulates that no activity may

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 83 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP commence prior to an Environmental Authorisation being granted by the Department. 2 09/02/2017 I have previously provided feedback to Rudolph du Toit wrt “grid connectivity and capacity”. You were copied in the email. See attached: Email A major project is planned for the Koeberg 400 kV busbar, and that project has been Mr. Ahmed Hansa subjected to many technical hurdles. It is therefore recommended that we consider integration at Ankerlig only. Eskom Grid Planning (Western Cape) Ankerlig has constraints with regards to servitudes and line crossings that will have to be overcome. There are also Eskom plans to increase the generation at this Power Station in the long term.

On the 400 kV side, we have opted to utilise one of the 400/132 kV transformer bays as a feeder bay for the new Ankerlig-Sterrekus Double Circuit Line so 400 kV spare feeder bays are limited, possibly non-existent. Connection at 400 kV may be possible with a loop-in and out as opposed to dedicated feeders. We would possibly have to wait for this double circuit line to be completed to aid with power evacuation under N-2 considering that this new generation will form part of a generation pool (Koeberg + Ankerlig) already exceeding 2000 MW. This is a Grid Code requirement for generation exceeding 1000 MW.

With one transformer bay available, integration at 132 kV will therefore be reliant on a single 400/132 kV 500 MVA transformer which will not suffice for more than 500 MW, a site visit will have to be undertaken to determine the availability of space for a second transformer, possibly a third. We also have to avoid crossing a planned 132 kV dedicated offsite supply line for Koeberg. This makes access to the substation very restrictive, a cable solution may have to be evaluated at 132 kV if this is a preferred integration option which is quite unlikely. We may also need clarification as to whether the newly built 132 kV busbar is dedicated for the offsite supply or whether it can zoned to accommodate customers/generators. Nonetheless, it will require 400/132 kV transformation.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 84 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP

In summary, integration will most likely be at 400 kV and will be dependent on the planned new double circuit 400 kV Ankerlig-Sterrekus 400 kV line scheduled for completion in 2019.

Additional information pertaining to you query can be sourced from the following: The Grid Connection Capacity Assessment of the 2022 Transmission Network (GCCA- 2022) document will help you to establish the available capacity across the national grid for the connection of new generation at the substations on the Eskom transmission network that may be in service by 2022 based on both approved and proposed new transmission infrastructure projects. The GCCA-2022 includes all of the projects that are expected to be completed by 2022 as contained in the Transmission Development Plan (TDP) for the period 2015-2024 (issued in October 2014). This is to provide developers and investors with an indication of the potential available capacity for the connection of new generation at or within the supply areas of the transmission substations on the Eskom transmission network by 2022 based on the 2014 TDP.

You may also find additional information related to your query in the current version of the TDP (2016-2025) (released in October 2015).

Should you require additional information to that contained in the above, kindly contact the Grid Access Unit (GAU) with regards to a formal application.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 85 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT Scoping and Environmental Impact Assessment for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

APPENDIX I:

Municipal Services Report for the site

GREEN - CAPE

Atlantis Industrial Factory Site

Portion of CA1183-4-1 Neil Hare Road

Services Report on Existing Civil and Electrical Infrastructure

October 2012

J31157

Arcus GIBB (Pty) Ltd Reg. 1992/007139/07

Cape Town, South Africa 14 Kloof Street, Cape Town, 8000 Tel: +27 (0)21 469 9100 Fax: +27 (0)21 424 5571

ATLANTIS FACTORY SITE PORTION OF CA1183-4-1 NEIL HARE ROAD SERVICES REPORT ON EXISTING CIVIL AND ELECTRICAL INFRASTRUCTURE

CONTENTS

Chapter Description Page

1 INTRODUCTION 3

2 ATLANTIS WATER RESOURCES MANAGEMENT SCHEME (AWRMS) 3

3 TOPOGRAPHY AND GEOLOGY 3

4 SITE PREPARATION 4

4.1 Introduction 4

4.2 Terracing 4

4.3 Construction and Lay-down Areas 5

4.4 Roads 5

4.5 General comments 6

5 POTABLE WATER FOR DOMESTIC CONSUMPTION AND FIRE- FIGHTING 6

6 FOUL SEWER (WASTE WATER) 7

7 STORM WATER DRAINAGE 8

7.1 Municipal Network (background) 8

7.2 Municipal Policy Governing Storm Water Drainage 8

7.3 Management of Drainage off Site 9

8 ROAD ACCESS 10

8.1 Local Road Network 10

8.2 Access route to N7 Freeway 10

9 ELECTRICAL 10

10 REFUSE REMOVAL 11

11 SITE CLEARANCE AND BULK EARTHWORKS COST (ESTIMATE) 11

Atlantis 2nd Factory Sites Services Report 1 October 2102.docx Rev 2 / Oct 2012

12 CONCLUSION 11

12.1 Geology 11

12.2 Site Survey 12

12.3 Storm Water Drainage 12

12.4 Potable Water and Foul Sewer 12

12.5 Effluent (Foul Sewer) 12

12.6 Traffic Access 12

12.7 Electrical 13

APPENDICES

Appendix 1: Industrial Area Site Layout Appendix 2: Access onto Neil Hare Road Appendix 3: Vehicular Routing to N7 via Dassenberg Road (R307), West Coast Road (R27) and Melkbosstrand Road (M19) Appendix 4: Schedule of Quantities with estimated rates (based on recent / similar projects)

Atlantis 2nd Factory Sites Services Report 1 October 2102.docx Rev 2 / Oct 2012

1 INTRODUCTION

This document reports on existing infrastructure services, site preparation, traffic access requirements and site clearance and bulk earthworks cost to a vacant site within the Atlantis Industrial area with respect to the establishment of a factory manufacturing components for wind power generation industry. The site location is indicated on Appendix 1 and is approximately 45.45 hectares in extent, rectangular in shape roughly 300 m wide by 1515 m long.

This report comments on site features, site preparation and existing infrastructure services as follows:

1. Topography and Geology 2. Site Preparation 3. Potable Water 4. Foul Sewer (domestic and industrial effluent) 5. Storm Water 6. Electrical 7. Refuse Waste 8. Road Access and traffic

It also includes acknowledgement of guidelines concerning disposal of stormwater run-off and effluent (domestic and industrial) discharge as proposed by Atlantis Water Resource Management Scheme.

2 ATLANTIS WATER RESOURCES MANAGEMENT SCHEME (AWRMS)

There are strict guidelines set out by the AWRMS concerning the disposal of stormwater and effluent from sites within the Atlantis Industrial Zone. The purpose of these guideline is to ensure quality of potential waste water (stormwater and effluent), which is used to artificially recharge the Atlantis Aquifer, is of a quality which minimise contamination of ground water resource used as potable water supply for the Atlantis district, alternatively to dispose of unsuitable effluent to prevent contamination of the ground water.

3 TOPOGRAPHY AND GEOLOGY

The site is densely covered with Port Jackson trees and appears to be rising in elevation from south to north. Observations indicate the site profile was re-shaped and bulk earthworks has occurred sometime in the past, however the dense growth of vegetation makes it difficult to form a reliable assessment of the terrain.

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Emanating from a limited walk about inspection of the site, the site generally indicates a likely probability of uniform underlay of aeolian (wind-blown deposited) sand. Usually these aeolian deposited sands are typically loose within the upper horizon (up to 1.5 m depth) becoming more dense with increasing depth.

No detailed geotech investigation has been undertaken, however based on observation of improvements (development) on adjacent sites, particularly the metal foundry to the east of the site, it is possible to achieve appropriate founding conditions for buildings, hard-stand storage areas and vehicle access circulation.

4 SITE PREPARATION

4.1 Introduction

This section provides general recommendations for the following site preparation operations:

Terracing Construction and lay-down areas Access roads

4.2 Terracing

Prior to commencement of construction the site will have to be terraced to form a level platform on which the plant installations can be constructed. The terrace can be constructed using compacted sand excavated from the site (natural or stabilised), or using selected imported fill of G7 minimum standard. A wearing course for the terrace may be constructed of stabilised sand using a minimum of 8 % cement (requires laboratory verification), or alternatively from imported commercial gravel (G5). However, a stabilised wearing course will be liable to cracking under loads. In order to prepare the terrace we recommend the following sequence of earthworks:

1. Over the entire area of the proposed site, strip all vegetation and organic soils and spoil on site to form screening berms.

Prepare the exposed in-situ surface sands by sub-grade compaction: o Compacted layer thickness ±200 mm o Density 90 % Mod AASHTO o Moisture OMC ±2 %

2. Terrace fill can be constructed using the aeolian sands or imported gravel material. The thickness of the fill will be determined by the settlement criteria of light structures that are to be founded in the terraced fill.

Compacted layer thickness 150 mm

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o Density 100 % Mod AASHTO for aeolian sand o 95 % Mod AASHTO for G7 imported fill o Moisture OMC ±2 %

3. In load bearing areas (ie building ffotprints), cut sections should be over- excavated and backfilled to create a terrace similar to the fill sections, i.e. thickness and density. The terrace should be capped with a wearing course at least 300 mm thick of selected imported commercial fill (G6 or better compacted to min 95 % Mod AASHTO density) should be used to form a wearing course in preference to stabilised in-situ sands.

During construction of the engineered fill, the contractor should conduct regular density tests as required by SANS 1200 DM (or similar specification) using either the Nuclear Density Method or the Sand Replacement Method. The moisture contents from the nuclear density tests should always be confirmed by oven drying tests. Occasional checks on the accuracy of the nuclear test results should be carried out by conducting sand replacement tests in parallel with the nuclear tests to verify Nuclear Density Method results.

The side slopes of temporary excavations within the loose erodible sands should be trimmed back to approximately 1:1.5. Fill slopes and permanent cut slopes should be trimmed at 1:2 and should be protected against wind and run-off erosion.

4.3 Construction and Lay-down Areas

Once the site has been leveled and terraced as described in Section 4.2, the resulting surface should be adequate to service construction traffic, serve as lay down areas and for supporting temporary structures.

Light, temporary structures such as site offices can be founded on slab-at-grade foundations on the terrace.

Crane outriggers may require local strengthening of the terrace, or other measures to safely carry these relatively high and concentrated loads.

4.4 Roads

Plant access roads must be designed for the expected traffic. The design should be based on the following sub-grade classes (refer TRH4):

In-situ sand, un-compacted CBR < 3 In-situ sand compacted to 90% Mod AASHTO CBR ~3 In-situ sand compacted to 95% Mod AASHTO CBR 3 to 7 Sand fill compacted to 100% Mod AASHTO CBR 7 to 15 Compacted Terrace of imported selected fill CBR > 15

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Blend of in-situ sand and imported gravel compacted to 96% Mod AASHTO density CBR > 25

Materials for sub-base and base layers will have to be imported commercial gravel or crushed stone (min G5 or better compacted to minimum 96 % Mod AASHTO density).

4.5 General comments

It may be difficult to effectively remove the vegetation and organic soils from the aeolian sands without stripping large volumes of the surface sands. Since the soils are predominantly non-plastic and fine grained, they will erode easily under the action of wind and water. For this reason protection measures such as vegetation must be introduced to reduce erosion or wash-away on banks and in areas where there is no terrace capping.

The soils on site are also low in nutrient content, allowing only the hardiest of vegetation to survive. Topsoil may have to be imported to form a thin mantle over the non-terraced areas of the site. Alternatively, fertilisers will have to be added to sustain growth in the sands.

Due to the fine grading of the soils, dust may be a problem and dust suppression will be required during construction. This can be mitigated by use of water sprinkler system to suppress airborne dust during earthworks and construction.

Soils in both cut and fill are likely to be non-plastic with low cohesion, gradients up to 3 m in height should not be steeper than 1 vertical and 1,5 horizontal for temporary slopes and 1:2 or flatter for permanent slopes. Higher slopes, whether cut or fill, will need to be assessed as part of the bulk earthworks design once a materials management programme has been established. It may be necessary to provide lateral support for higher cuts and fills in the form of geotextile reinforced concrete- block retaining walls, gabions or similar.

Bulk earthworks and terrace construction should be completed before commencing with the piling contract in order to provide access and a stable platform for the piling operations and that the foundation excavations be formed into the completed terrace rather than constructing the foundations on a partially formed terrace and then completing the terrace construction around the foundations. Backfill above the foundations should be compacted to the same density as the remainder of the terrace to avoid zones of high porosity and permeability around the foundations.

5 POTABLE WATER FOR DOMESTIC CONSUMPTION AND FIRE-FIGHTING

The site is serviced from a 150 mm diameter pressurised pipe-line located along the western boundary of the site. The municipal pipeline provides for both domestic and fire-fighting requirements. Pressure within the pipeline is maintained between 7 to 9 bars, should water be required at higher pressure then booster pumps will have to be installed by the developer.

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6 FOUL SEWER (WASTE WATER)

In the Atlantis district there are two parallel municipal gravity pipeline in the adjacent road network. Generally effluent is divided into two categories namely:

1. Domestic effluent generated from toilets, showers, hand basins and kitchen sinks. 2. Industrial effluent which could include noxious effluents (bye produfrom manufacturing process).

Industrial effluent is be treated on site in a “bioretention” facility to remove heavy and noxious elements. The “bioretention” facility then discharges into a separate municipal waste-water system specifically provided for effluent not suitable for recharging the ground water aquifer. Ideally this facility should be located such that “scrubbed/treated” effluent can gravitate into the dedicated municipal pipeline for industrial effluent.

Buildings which generate domestic effluent, and which require connection to the municipal sewerage reticulation should be situated close to the adjacent road to ensure domestic effluent can gravitate into the dedicated municipal pipeline for conveyance to treatment works for domestic wastewater.

The site is serviced by a 300 mm gravity pipeline adjacent to the western and south section of the eastern boundary. Buildings requiring connection into the municipal pipeline should be situated as close to the municipal sewer lines to ensure waste water can gravitate into the municipal pipeline without pumping.

7 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

7 STORM WATER DRAINAGE

7.1 Municipal Network (background)

The pipe network in the adjacent municipal roads is designed to take the pre- development 1:2 year recurrence interval storm run-off for low traffic volumes areas to 1:10 year recurrence interval storm run-off for prime commercial developments. The balance of the run-off is conveyed within defined overland flow routes utilising streets to discharge into green belts comprising parks and playing fields where flood peak attenuation techniques are applied in accordance with the CoCT’s Management of Urban Storm Water Impacts Policy” document

7.2 Municipal Policy Governing Storm Water Drainage

7.2.1 General Comments

During May 2009 the City of Cape Town (CoCT) introduced a “Management of Urban Storm Water Impacts Policy” document for the purpose of minimising the undesirable impact of storm water runoff from developed areas into natural watercourses and wetlands via storm water culverts.

The policy document requires existing and new developments to comply with the following:

1. Ensure storm water discharged into the municipal drainage network is free from urban pollutants thereby improving the quality of the run-off discharging into natural watercourses and wetlands. 2. Control the quantity and rate of runoff to protect municipal infrastructure, downstream properties and floodplains from frequent nuisance floods and adverse impacts from extreme flooding.

7.2.2 Consequence of new Municipal Policy

The new policy came into effect in May 2009 and consequently requires brownfield and new developments to comply with the policy protocol in respect to the quality and quantity of stormwater runoff emanating from improvements to property.

The consequence to property owners / developers are as follows:

1. Construction of structures at source (i.e. on site) to remove in addition to suspended solids (SS) and total phosphates (TP),and trap litter, oil and grease, to approved levels to ensure a minimum standard of the quality of runoff discharged from developed sites. 2. Attenuate runoff to pre-development levels for 1:10 year recurrence interval

Run-off from surfaced / improved areas (i.e. hard-stands, etc) will have to be conveyed to a lined bio-retention facility, to:

1. improve the quality of the water

8 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

2. Monitor the quality of the water before its released into the appropriate municipal infrastructure. (ie poor quality water into the industrial effluent network).

7.3 Management of Drainage off Site

The AWRMS describes stormwater run-off as three distinct categories on the grounds of water quality namely:

1. Base flow – run-off/drainage from watering activities and subsoil drains. 2. “First flush” - generated from run-off produced by showers from the earlier part of the rainy season. 3. “Better quality water” – from heavier downfalls in the latter part of winter rainy season.

In the instance of development of this site, only items 2 and 3 above are applicable

It is possible to construct infrastructure to manage the disposal of “first flush” run-off and “better quality run-off” by means of a diversion mechanism at the outlet of an on- site “lined bio-retention” basin. This will ensure contaminated run-off can be diverted into the waste-water system for industrial effluent and as the quality of retained water improves, if suitable for aquifer recharge, it can be diverted into the municipal network conveying effluent to the treatment works linked to recharge basin.

9 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

8 ROAD ACCESS

8.1 Local Road Network

The preferred access onto the local road network will be at the northern end of the site onto Neil Hare Road (refer Appendix 2) to avoid:

1. Road under Rail Bridge on Neil Hare Road to the west of the site. 2. Circuitous route if access was on the south side of the site onto Neil Hare Road.

Neil Hare Road is linked to Dassenberg Road via an “unnamed” road. The junction between the site access and Neil Hare Road, as well as the junction of Neil Hare Road and “unnamed” road and “unnamed” road and Dassenberg Road will all have to be widened to accommodate the sweep area for extra-large vehicle turning requirement.

The access location from the site onto Neil Hare Road will result in crossing an operational railway track. A level crossing and right of way servitude will have to be negotiated with Transnet to facilitate a road over rail level crossing to gain access onto Neil Hare Road.

8.2 Access route to N7 Freeway

Access to the N7 freeway will be as follows (refer Appendix 3):

1. Westward along Dassenberg Road (R307) to the junction with the West Coast Road (R27). 2. Southward along the West Coast Road to the intersection with Melkbosstrand Road (M19). 3. Eastward along Melkbosstrand Road (M19) to the junction with the N7 freeway.

Localised road widening of junctions and intersection en route will require municipal (CoCT) and Provincial Roads Department approvals.

A Traffic Impact Assessment (TIA) study is not required, however a study of vehicle movements to and from the industrial area onto the major routes must be considered.

9 ELECTRICAL

The City of Cape Town is the supplier of electricity to the Atlantis Industrial area. Currently the power supply network capacity in the area is limited.

The municipality indicates they could provide up to 2MVA to the site. Anything larger than 2 MVA can be accommodated, but with significant implications to their network.

10 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

10 REFUSE REMOVAL

The removal of refuse (solid waste) is managed by the municipality, alternatively this service can be provided by private contractors, depending on developers needs.

11 SITE CLEARANCE AND BULK EARTHWORKS COST (ESTIMATE)

Based on the footprint required for development (i.e. the north half of the site, approximately 20 hectares) the estimated cost for site clearance and bulk earthworks is approximately R7,200,000.00 (refer Appendix 4) for breakdown of cost.

12 CONCLUSION

12.1 Geology

A geological survey is required to guide the engineering and manage the use of in- situ materials to achieve cost effective construction of terracing, construction and lay- down areas and roads.

Based on heavy construction recently completed in the area (namely the Eskom Ankerlig Power Generation Plant) the following general considerations apply to this site:

1. The natural near-surface soils are loose and unsuitable for founding. 2. Basic preparation of the site should comprise cut, fill and compaction of the aeolian sands, once the site has been cleared of vegetation. 3. The terrace can be constructed using the aeolian sands (natural and/or stabilised) from the site or using imported selected fill. 4. To provide a trafficable surface and a stable platform for piling and/or other construction activities it is recommended that the plant terrace is capped with a minimum 300 mm thick layer of cement stabilised sand using 8 % cement or with an imported commercial (G5) gravel wearing course. 4. Light and flexible structures can be founded directly on the compacted terrace. The thickness of the terrace will govern the settlement of these foundations. 6. Heavy, dynamically loaded or settlement sensitive structures, such as the turbine units, should be founded on pile substructure. 7. If necessary seismic considerations and corrosion protection should be designed by specialist consultants. 8. The design of dynamic loaded structures should be confirmed once the plant layout is finalised. It is recommended that further geophysical tests are carried out once the terrace has been constructed to verify the dynamic properties of the terrace and sub-soils.

11 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

12.2 Site Survey

A topographical survey of the site is necessary to:

1. Determine platform levels for the building footprint and storage areas relative to the adjacent road levels and 2. Plan earthworks to minimise contamination of materials and calculate extent of earthworks.

12.3 Storm Water Drainage

Storm water retention / attenuation will have to be provided in the form of lined bio- retention facilities to comply with municipal by-laws and the Atlantis Water Resources Management Scheme to ensure control release of site discharge into appropriate municipal network. These facilities are to be designed such that they effectively contain and prevent accidental leakage and discharge of retained run-off.

12.4 Potable Water and Foul Sewer

Generally service connections (potable water and foul sewer) to the site are installed by the developer (i.e. the City of Cape Town), however they might not be in the position dedicated by the preferred placement of the building footprint. In this instance an application to the Municipality for new service connections would be necessary.

12.5 Effluent (Foul Sewer)

A dual on site effluent piped conveyance system will have be provided to separate domestic effluent from industrial effluent and these will have to be connected into the dual parallel Municipal network. Domestic effluent can be discharged directly into the municipal network provided for conveyance thereof and industrial effluent treated on site before release into the municipal network.

12.6 Traffic Access

As no rezoning is necessary there is no requirement for a Traffic Impact Assessment. However, due to the abnormal transport vehicle operating from the site, irrespective of whether access is onto the municipal of provincial road network, substantial localised road widening will be required. Applications for these improvements would have to be addressed with the relevant authorities.

12 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

12.7 Electrical

Once details of electrical requirement are received from the developer further discussions will be engaged with the Municipality to determine accommodating the power requirement within their local network.

13 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

Appendix 1

Industrial Area Site Layout

Appendix 2

Access onto Neil Hare Road

ALL DIMENSIONS AND LEVELS ARE TO BE VERIFIED ON SITE BY THE CONTRACTOR BEFORE COMMENCING ANY WORK.

This document and all the information thereon remains the property of ARCUS GIBB (Pty) Ltd. and may not be copied, reproduced or transmitted in part or in full without the written consent of ARCUS GIBB (Pty) Ltd. This document should not be relied on nor used in circumstances other than those for which it was originally prepared and for which ARCUS GIBB (Pty) Ltd. was commissioned, as defined on this document. Refer to the contract for full terms and conditions.

ARCUS GIBB (Pty) Ltd. shall not be liable for the consequences of using this document other than for the purpose for which it was commissioned. Any user and any other person using or relying on the document for such other purpose, will by such use or reliance be taken to confirm his agreement to indemnify ARCUS GIBB (Pty) Ltd. for all loss or damage resulting there from.

ON ORIGINAL

15 25 5 0 10 20 30 40MM

GENERAL NOTES:

N Ch Ap Date Details o d pd Revisions

Client

GREEN CAPE

14 Kloof Street, Cape Town 8001 Tel : +27 21 469-9100 PO Box 3965, Cape Town 8000 Fax: +27 21 424-5571

Approved By

Drawn By Designed By Reviewed By

B MENTOR

Project ATLANTIS INDUSTRIAL FACTORY SITE PORTION OF CA1183-4-1 NEIL HARE ROAD

Description

SITE 1 LAYOUT 1 ACCESS TO NEIL HARE ROAD

Scale Date 1 : 2 500 SEPT 2011

Project No Drg. No Rev P8424 102

Appendix 3

Vehicular Routing to N7 via Dassenberg Road (R307), West Coast Road (R27) and Melkbosstrand Road (M19)

Appendix 4

Schedule of Quantities with estimated rates (based on recent / similar projects)

DOCUMENT CONTROL SHEET (FORM IP180/B)

CLIENT : GREEN CAPE PROJECT NAME : ATLANTIS FACTORY SITES PROJECT No. : J31157

TITLE OF Services Report on Existing Civil and Electrical Infrastructure DOCUMENT : ELECTRONIC P:\J31157 (LAND AVAILABLILITY IN ATLANTIS)\Doc\Reports\Atlantis 2nd Factory LOCATION : Sites Services Report 21 November 2011.docx Approved By Reviewed By Prepared By

NAME NAME NAME ORIGINAL AN MacKAY DATE SIGNATURE SIGNATURE SIGNATURE 30 November 2011

Prepared by Prepared By Prepared By

NAME NAME NAME ORIGINAL

DATE SIGNATURE SIGNATURE SIGNATURE

Approved By Reviewed By Prepared By

NAME NAME NAME REVISION AN MacKAY DATE SIGNATURE SIGNATURE SIGNATURE November 2011

This report, and information or advice, which it contains, is provided by Arcus GIBB solely for internal use and reliance by its Client in performance of Arcus GIBB duties and liabilities under its contract with the Client. Any advice, opinions, or recommendations within this report should be read and relied upon only in the context of the report as a whole. The advice and opinions in this report are based upon the information made available to Arcus GIBB at the date of this report and on current SA standards, codes, technology and construction practices as at the date of this report. Following final delivery of this report to the Client, Arcus GIBB will have no further obligations or duty to advise the Client on any matters, including development affecting the information or advice provided in this report. This report has been prepared by Arcus GIBB in their professional capacity as Consulting Engineers. The contents of the report do not, in any way, purport to include any manner of legal advice or opinion. This report is prepared in accordance with the terms and conditions of the Arcus GIBB contract with the Client. Regard should be had to those terms and conditions when considering and/or placing any reliance on this report. Should the Client wish to release this report to a Third Party for that party's reliance, Arcus GIBB may, at its discretion, agree to such release provided that: (a) Arcus GIBB written agreement is obtained prior to such release, and (b) By release of the report to the Third Party, that Third Party does not acquire any rights, contractual or otherwise, whatsoever against Arcus GIBB and Arcus GIBB, accordingly, assume no duties, liabilities or obligations to that Third Party, and (c) Arcus GIBB accepts no responsibility for any loss or damage incurred by the Client or for any conflict of Arcus GIBB interests arising out of the Client's release of this report to the Third Party.

Arcus GIBB (Pty) Ltd Website : www.arcusgibb.co.za Postal Address : PO Box 3965, Cape Town Physical Address : 14 Kloof Street, Cape Town Contact Person : Adrian MacKAY Email Address : [email protected] Telephone No. : +27 (0)21 469 9225 Fax No. : +27 (0)21 424 5571

File original in relevant section in the Quality File. Rev 2 / Sept 2009 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT Scoping and Environmental Impact Assessment for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

APPENDIX J:

Botanical Assessment Bergwind Botanical Surveys & Tours CC.

14A Thomson Road

Claremont

Cape Town 7708

28 September 2016

TO WHOM IT MAY CONCERN

Confirmation of applicability of botanical impact assessment on Farm CA1183 Portion 1 of Portion 4, Atlantis Industrial Area (‘the property’)

A botanical survey and impact assessment was carried out on Farm CA1183 Portion 1 of Portion 4, Atlantis Industrial Area (‘the property’) by my associate Mr Paul Emms in June / July 2012. The assessment examined the clearing of the property for development purposes. The intended development did not proceed.

The property is now (2016) earmarked for development of the Atlantis Gas-to-Power Facility. This would require the same clearing of the property as it would have for the former development.

This letter serves to confirm that the anticipated impact of clearing the property of vegetation would have no greater or lesser negative impact now with development of the Atlantis Gas-to-Power Facility than it would have had the former development proceeded on the same property.

Yours sincerely,

Dr D.J. McDonald Pr. Sci. Nat. Botanical Specialist Director / Owner

tel +27 21 671-4056 mobile 082-876-4051 e-mail [email protected] web www.bergwind.co.za

CK2005\138289\23

Botanical Assessment for proposed industrial development on Farm CA1183 Portion 4 and Portion 1, Atlantis Industrial Area, City of Cape Town

Paul Emms in association with

Dr David J. McDonald Bergwind Botanical Surveys & Tours CC. 14A Thomson Road, Claremont, 7708 Tel: 021-671-4056 Fax: 086-517-3806

Prepared for Doug Jeffery Environmental Consultants

June 2012 / July 2012 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

DECLARATION

This botanical assessment was conducted by Mr Paul Emms in collaboration with Dr David J. McDonald BSc. Hons. (Botany), MSc (Botany) and PhD (Botany), a botanical ecologist with over 30 years’ experience in the field of Vegetation Science. Dr McDonald is registered as an Ecological Scientist with the South African Council for Natural Scientific Professions (SACNASP), Registration No. 400094/06.

General declaration: • We have acted as the independent specialist in this application • We have performed the work relating to the application in an objective manner, even if this has resulted in views and findings that are not favourable to the applicant • We declare that there are no circumstances that may compromise our objectivity in performing such work; • We 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; • We will comply with the Act, regulations and all other applicable legislation; • We have no, and will not engage in, conflicting interests in the undertaking of the activity; • We 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 us are true and correct; and • We realise that a false declaration is an offence in terms of Regulation 71 and is punishable in terms of section 24F of the Act.

Dr David J. McDonald Pr. Sci. Nat.

2 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

CONTENTS

1. Introduction ...... 4 2. Terms of Reference ...... 4 3. Study Area ...... 5 3.1 Locality and general description ...... 5 3.2 Geology, topography and soils ...... 6 3.3 Climate ...... 6 4. Evaluation Method ...... 6 5. Limitations and assumptions ...... 7 6. The Vegetation ...... 9 6.1 General description and context ...... 9 6.2 The vegetation of Farm 1183 Portion 4 & Portion 1 ...... 9 7. Impact Assessment ...... 19 7.1 The ‘No-Go’ Alternative ...... 19 7.2 Direct impacts ...... 19 7.3 Indirect impacts ...... 26 7.4 Cumulative impacts ...... 26 8. Recommendations and Conclusions ...... 26 9. References ...... 27

3 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

1. Introduction

A proposed industrial development is planned for a strip of land (Farm CA1183 Portion 4 & Portion 1) in the Atlantis Industrial Area. The proposed site consists of an undeveloped, linear strip of land, sandwiched between the eastern loop of Neil Hare Road at the western side of Atlantis. The Atlantis Industrial Area contains several remnant patches of threatened vegetation types and species of conservation concern, which present an obstacle for an area zoned for industrial development. The remaining undeveloped portions of land within the Atlantis Industrial Area have therefore recently been acquired by the City of Cape Town (CCT) for the purpose of allowing for biodiversity offsets. A biodiversity offset is defined as ‘conservation actions intended to compensate for residual, unavoidable harm to biodiversity’. (ten Kate et al., 2004 in Brownlie and Botha, 2009). The purpose of biodiversity offsets is to secure and add priority conservation areas instead of achieving no net loss of habitat. The CCT has also acquired a substantial portion of land outside the Atlantis Industrial Area which contains the same or better quality vegetation which would allow for the possibility of offsets – adding substantially to the protection of these threatened ecosystems in a consolidated portion of land. The proposed offset ratios are 1:1 ha for ENDANGERED vegetation and 2:1 ha for CRITICALLY ENDANGERED vegetation types (inside urban edge).

The proposed industrial development site required a botanical assessment in order to determine the potential impacts on the vegetation and to describe any areas of sensitivity. In addition the feasibility of an offset option was considered. The environmental assessment process is being managed by Doug Jeffery Environmental Consultants who appointed Bergwind Botanical Surveys and Tours CC to carry out the botanical assessment.

2. Terms of Reference

The following additional terms of reference were considered:

• Provide a description of the vegetation of the site and areas of sensitivity. • Check for the possible presence of wetlands with reference to the City of Cape Town’s wetland mapping; • Identify and describe biodiversity patterns at community and ecosystem level (main vegetation type, plant communities in vicinity and threatened/ vulnerable ecosystems species), at species level (species of conservation concern, presence of alien species) and in terms of significant landscape features;

4 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

• Provide mitigation options with respect to the long-term management of vegetation affected. • Comment on whether or not biodiversity processes would be affected by the proposed project, and if so, how these would be affected. • Comply with DEA&DP’s Guideline for Involving Biodiversity Specialists in EIA Processes, the Fynbos Forum’s Ecosystem Guidelines for Environmental Assessment in the Western Cape (De Villiers et al. 2005) and Cape Nature’s standard requirements.

3. Study Area

3.1 Locality and general description

Farm 1183 Portion 4 and Portion 1 is situated in the Atlantis Industrial area. The study area consists of a linear strip of land contained in the western loop of Neil Hare Road. The eastern boundary is flanked by a railway line, whereas the western boundary is marked by a water- main servitude, which extends along most of the boundary length until the southern side meets Gideon Basson Road. At this point the boundary continues along the western side of a retention pond and joins Neil Hare Road. The site is surrounded by a mix of open but alien infested land, industrial buildings, railway lines and roads. Despite the fragmentary effects of the various surrounding features and possible fence barriers, the area experiences active exchange of ecological and biodiversity resources between adjacent portions of land. Of importance here is the proximity to the Atlantis dune plume situated about 1.5km to the west where the Witzands Aquifer Nature Reserve is located.

5 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 1. Location of the proposed industrial development site on Farm CA1183 Portion 4 & Portion 1 in the Atlantis Industrial Area (green dot).

3.2 Geology, topography and soils

The site consists of low to moderate vegetated dunes, which are characteristic of the surrounding area. The dunes are of aeolian origin, underlain by fine- to medium- grained sand. These contain detrital carbonate (mainly finely broken sea shells) of the Witzand Formation. The sands associated with most of the site (except a relatively small portion along the southern boundary) are alkaline due to the high calcium content. The southern portion of the site also contains aeolian deposits, however, the detrital carbonate (sea-shells) has been leached from the original dune sands and they are therefore most likely acidic.

3.3 Climate

The Mediterranean climate within the region experiences rainfall mainly between May and August: MAP 290 – 660 (mean 440 mm), with temperatures ranging from a mean summer high (February) of 27.9 ˚C to a winter low (July) of 7˚C.

4. Evaluation Method

The study area was visited on 30 May 2012, and surveyed on foot. A combination of photographic records and sampling waypoints (using a Garmin ® GPSmap 60CSx) were

6 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

used to record important features. The vegetation and study area was described in terms of general quality and degree of disturbance, sensitivity and conservation importance Plant species were identified in the field or collected for identification. Potential impacts were measured against the following criteria: • Conservation planning: GIS shapefiles of The City of Cape Town’s Biodiversity Network (CCT BioNet) (2011) was used to show were Critical Biodiversity Areas (CBA’s) fall in relation to the study area. The CCT BioNet is of high importance since it provides information on priority biodiversity areas and the associated category of importance. Ground-thruthing of CBA’s is important since the sites may reflect a different scenario to the CCT BioNet. • Ecosystem status: ecosystem status of the vegetation type was the gained using the List of Threatened Terrestrial Ecosystems (Government Gazette, 2011). The gazette listings are crucial to commenting on the level of sensitivity in relation to natural vegetation quantity and quality. • Special habitats: the presence of rare or sensitive habitats such as wetlands and dunes. • Restoration potential and biodiversity corridors: degraded areas or alien-infested areas have the potential to be restored depending on the level of disturbance or transformation. Degraded and transformed areas may also be of importance if these areas link portions or remnants of good quality or highly threatened vegetation types.

5. Limitations and assumptions

Stands of alien invasive vegetation presented a limitation since in some portions of the site these were almost impenetrable. Access through heavy infestations was extremely difficult. Consequently it is possible that small patches of remnant species were missed during the survey, since the entire site could not be surveyed due to impenetrability. Of particular concern was lack of access due to dense alien stands towards the south-western portion of the site since scattered individuals of the ENDANGERED Leucospermum parile was found within the dense stands.

Although most plant species could be detected at the time of survey (late May), a survey outside of the peak spring flowering period makes it difficult to detect the full array of potential species, in particular geophytes (bulbs) which were still dormant. The number of species recorded would therefore probably be higher during a spring survey. This limitation is more of a concern within the disturbed area since the geophytes could be more important in such areas.

7 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 2. Google Earth ™ aerial image of the proposed industrial development site (red outline) on Farm 1183 Portion 4 & Portion 1 in relation to Atlantis; the Atlantis dune system and Klein Dassenberg Road.

8 Botanical Screening: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis, CoCT

6. The Vegetation 6.1 General description and context

Vegetation According to the Vegetation Map of South Africa, Lesotho, and Swaziland (Mucina, Rutherford and Powrie, 2005) there are two vegetation units within the study area (Figure 5). These are:

1) Cape Flats Dune Strandveld (CFDS): an ENDANGERED ecosystem, covering almost the entire site; and 2) Atlantis Sand Fynbos (ASF): a CRITICALLY ENDANGERED ecosystem, covering a small section along southern boundary.

Biodiversity plans The study area does not fall within the City of Cape Town’s Biodiversity Network (2011) since the CCT BioNet’s planning methodology preferentially selects areas outside of the urban edge but it is important to note that several large portions of important natural remnant vegetation were found.

Local context The study area forms part of the Atlantis dune ecosystem also found in the Witzand Aquifer Nature Reserve. However, the site is somewhat isolated from the main dune system by roads; buildings; fences; cleared portions of land, and heavy infestations of invasive alien Port Jackson Willow (Acacia saligna) and rooikrans (Acacia cyclops).

6.2 The vegetation of Farm 1183 Portion 4 & Portion 1

Approximately two thirds of the site has been transformed by invasive aliens vegetation (mainly Port Jackson Willow, with lower cover of rooikrans), which, in some areas - particularly the southern portion - is almost impenetrable due to high densities of 3 - 4m high saplings. The remaining areas contain intact, good-quality Cape Flats Dune Strandveld and a relatively small portion of Atlantis Sand Fynbos. The two vegetation types (as a result of the interface between different soil types) merge along the southern portion of the site. This is significant since transition zones are recognized as critically important areas for driving speciation and for biodiversity importance (De Villiers et al. 2005).

The remnant portions of Cape Flats Dune Strandveld (Figure 4) are dominated by the small tree known as the dune olive (Olea exasperata). The tree has a dwarf habit, which may be a small 9

Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis form of the species. It is more likely that the tree is relatively slow-growing, and in the early stages of growth following a recent fire in the area. This is not entirely clear though, since alien stands tend to be a consistent height and are rapid colonizers, reaching maturity within a few years after fire. The high density of Port Jackson Willow saplings towards the southern side of the site reflect a recent fire. Of greater importance, however, is the large patch of Cape Flats Dune Strandveld occurring within the site, which is considered a highly important, albeit threatened, remnant due to the ecological state of the surrounding area. The area is considered to have a high restoration potential under the scenario of alien eradication and active long-term. clearing. Furthermore there are small pockets of good quality Cape Flats Dune Strandveld which would serve as important islands for the recovery potential.

The Cape Flats Dune Strandveld remnants have several dominant species which include Searsia laevigata subsp. villosa; Searsia glauca, Euclea racemosa, Osteospermum moniliferum, Thamnochortus spicigerus, Roepera morgsana, Ehrharta villosa, Limonium perigrinum, Asparagus capensis, Trachyandra sp., Cissampelos capensis, Euphorbia mauritanica, Cynanchum africanum, Ruschia macowanii and Muraltia spinosa. There are also high numbers of the ENDANGERED mesemb Ruschia indecora throughout the site, particularly the periphery and disturbed portions of the natural vegetation. Additional species include Arctotis stoechadifolia, Lachenalia rubida, Brunsvigia orientalis, Thesium sp., Carpobrotus cf. quadrifidus, Euphorbia marlothiana, Lycium ferocissimum and Othonna coronopifolia.

The remnant portion of Atlantis Sand Fynbos along the southern boundary is partially disturbed and of medium quality. The land north of the medium quality vegetation is heavily infested with Port Jackson Willow and rooikrans (Figure 4). Within the heavily infested areas several species are present, including Phylica cephalantha, Trichocephalus stipularis, Diosma sp., Thamnochortus sp. and a few individuals of Erica mammosa and the ENDANGERED Malmesbury Pincushion (Leucospermum parile) (Figure 12). The most common widespread of these is Phylica cephalantha. The most southern portion has a low cover of alien vegetation where there is a remnant population of approximately 80 individuals of the ENDANGERED Leucospermum parile (Figure 4). All individuals were mapped (Appendix 1) to show the distribution. The population is a red flag since the species is steadily declining and will most probably be listed as CRITICALLY ENDAGERED in the future. Species associated with this population included Willdenowia incurvata, Othonna coronopifolia; Arctotis stoechadifolia; Trichocephalus stipularis; Diosma sp., Aspalathus cf. spinosa; Metalasia muricata and Aspalathus ternata (VULNERABLE).

Two artificial wetlands or retention ponds were located. These included a small excavated pond (location: 33°36'3.65"S; 18°28'13.48"E) towards the middle of the site and a larger retention pond at the south-eastern corner located at waypoint 054: 33°36'14.68"S; 18°28'18.61"E). Both

10 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis ponds are covered with bulrush (Typha capensis) and are surrounded by alien vegetation. The possible presence of a wetland located at 33°36'1.72"S; 18°28'13.99"E was checked and found to be a grassy area with alien vegetation.

11 Botanical Screening: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis, CoCT

Figure 3. Google Earth ™ aerial image of the proposed industrial development site on Farm 1183 Portion 4 and Portion 1 in Atlantis Industrial in relation to the City of Cape Town’s Biodiversity Network (2011) (yellow shading). The CBA category within the site boundary is ‘Other Natural Vegetation’, which means the area is not part of the current CCT BioNet.

12

Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 4. Google Earth ™ aerial image of the proposed industrial development site on Farm 1183 Portion 4 and Portion 1 in Atlantis Industrial Area with the sample waypoints (labeled green icons). The good quality vegetation is indicated by the yellow shading (Cape Flats Dune Strandveld) and orange shading (Atlantis Sand Fynbos) whereas the remaining areas consist of heavy alien infestations of Port Jackson Willow and rooikrans. The red icons show the distribution of clumps of the ENDANGERED Malmesbury pincushion (Leucospermum parile). The blue shading indicates wetlands/retention ponds.

13 Botanical Screening: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis, CoCT

FFd4

FS6

AZd3

FS6 FFd4

AZi9

Figure 5. The proposed industrial development site (red outline) represented on a portion of the Vegetation Map of South Africa, Lesotho, and Swaziland (Mucina et al. 2005). FS6 = Cape Flats Dune Strandveld; FFd4 = Atlantis Sand Fynbos; AZi9 = Cape Inland Salt Pans; Azd3 = Cape Seashore Vegetation

14

Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 6. Portions of good quality Cape Flats Dune Strandveld, dominated by the dune olive (Olea exasperata) extends over a large portion of the site. Sample at waypoint 038 (33°35'50.93"S; 18°28'6.73"E).

Figure 7. The eastern boundary of the site showing the railway, industrial area and alien stands. Sample waypoint 047 (33°35'57.33"S; 18°28'17.06"E).

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Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 8. The area checked for the possible presence of a wetland in terms of the CoCT wetland mapping at 33°36'1.72"S; 18°28'13.99"E revealed a grassy patch covered with alien vegetation.

Figure 9. The small wetland/retention pond within stands of Port Jackson Willow, which is dominated by bulrush (Typha capensis). Located at 33°36'3.65"S; 18°28'13.48"E.

16 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 10. Dense stands of Port Jackson Willow cover most the study area. The southern half of the site contains patches alien vegetation and the common Phylica cephalantha. Located at waypoint 081 (33°36'7.61"S; 18°28'23.16"E).

Figure 11. Large wetland/retention pond dominated by bulrush (Typha capensis) located at waypoint 054 (33°36'14.68"S; 18°28'18.61"E).

17 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 12. Remnant patch of Atlantis Sand Fynbos where the population of the ENDANGERED Malmesbury pincushion (Leucospermum parile) occurs. Located at waypoint 063 (33°36'19.51"S; 18°28'22.35"E).

7. Impact Assessment

The ‘No Go’ scenario and the construction implementation scenario (i.e. industrial development of the area) were assessed, with the ‘No Go’ scenario coupled with an offset proposal. No alternatives were provided.

7.1 ‘No Go’ Alternative

In the case of the ‘No Go’ alternative, the proposed development would not go ahead. The status quo would consequently prevail with no immediate changes to the vegetation. In the medium to long term the site would be subject to increased invasion by Port Jackson Willow and rooikrans since alien clearing is unlikely to be controlled under the ‘No Go’ scenario.

7.2 Direct impacts

Direct impacts are impacts occurring directly on the vegetation of the site that would result from the proposed development. In this instance there would be loss of intact vegetation and species of importance in addition to loss of degraded, alien-infested

18 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

vegetation. The impacts on the two classes of vegetation and habitat due to the proposed construction are considered according to two identified potential impacts which are:
Loss of vegetation type – including intact vegetation, ecologically important species and species of conservation concern.
Loss of ecological processes – associated with the loss of intact vegetation, ecologically important species and species of conservation concern.

Direct impacts are assessed in Tables 1 – 4, which apply to the design, construction and operational phases of the project.

19 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Table 1. Impact and Significance – Loss of intact vegetation type, ecologically important species and species of conservation concern during the design and construction phase:

Alternative 1: Development Alternative 1: Development option option No-Go Alternative Comment Impact: Intact vegetation & species of Degraded vegetation & alien conservation concern infestations Nature of impact: Loss of natural vegetation Loss of natural vegetation Loss of natural vegetation Extent and duration of impact: National & Permanent Local & Permanent Local & Permanent Biodiversity offset mitigation Probability of occurrence: Likely Likely Unlikely measure Degree to which the impact can be reversed: Low Low High Degree to which the impact may cause irreplaceable loss of Low Low High resources: Low to Medium Low Biodiversity offset mitigation Cumulative impact prior to mitigation: High measure Significance rating of impact prior to mitigation High Low to Medium Low Degree to which the impact can be mitigated: Low Low High Proposed mitigation: Biodiversity offset Biodiversity offset None Cumulative impact post mitigation: High Low to Medium Low Significance rating of impact after mitigation High Low to Medium Low

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Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Table 2. Impact and Significance – Loss of intact vegetation type, ecologically important species and species of conservation concern during the operational phase:

Alternative 1: Development Alternative 1: Development option option No-Go Alternative Comment Impact: Intact vegetation & species of Degraded vegetation & alien conservation concern infestations Nature of impact: Loss of natural vegetation Loss of natural vegetation Loss of natural vegetation Extent and duration of impact: National & Permanent Local & Permanent Local & Permanent Biodiversity offset mitigation Probability of occurrence: Likely Likely Unlikely measure Degree to which the impact can be reversed: Low Low High Degree to which the impact may cause irreplaceable loss of Low Low High resources: Low to Medium Low Biodiversity offset mitigation Cumulative impact prior to mitigation: High measure Significance rating of impact prior to mitigation High Low to Medium Low Degree to which the impact can be mitigated: Low Low High Proposed mitigation: Biodiversity offset Biodiversity offset None Cumulative impact post mitigation: High Low to Medium Low Significance rating of impact after mitigation High Low to Medium Low

21 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Table 3 Impact and Significance – Loss of ecological processes associated with loss of vegetation type during the design and construction phase: Alternative 1: Development Alternative 1: Development option option Loss of ecological process Loss of ecological processes No-Go Alternative Comment Impact: associated with intact associated with degraded vegetation & species of vegetation & alien infestations conservation concern Nature of impact: Loss of ecological processes Loss of ecological processes Loss of ecological processes Extent and duration of impact: National & Permanent Local & Permanent Local & Permanent Biodiversity offset mitigation Probability of occurrence: Likely Likely Unlikely measure Degree to which the impact can be reversed: Low Low High Degree to which the impact may cause irreplaceable loss of Low Low High resources: Low to Medium Low Biodiversity offset mitigation Cumulative impact prior to mitigation: High measure Significance rating of impact prior to mitigation High Low to Medium Low Degree to which the impact can be mitigated: Low Low High Proposed mitigation: Biodiversity offset Biodiversity offset None Cumulative impact post mitigation: High Low to Medium Low Significance rating of impact after mitigation High Low to Medium Low

22

Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Table 4. Impact and Significance – Loss of ecological processes associated with loss of vegetation type during the operational phase:

Alternative 1: Development Alternative 1: Development option option Loss of ecological process Loss of ecological processes No-Go Alternative Comment Impact: associated with intact associated with degraded vegetation & species of vegetation & alien infestations conservation concern Nature of impact: Loss of ecological processes Loss of ecological processes Loss of ecological processes Extent and duration of impact: National & Permanent Local & Permanent Local & Permanent Biodiversity offset mitigation Probability of occurrence: Likely Likely Unlikely measure Degree to which the impact can be reversed: Low Low High Degree to which the impact may cause irreplaceable loss of Low Very low High resources: Low to Medium Very low Biodiversity offset mitigation Cumulative impact prior to mitigation: High measure Significance rating of impact prior to mitigation High Low to Medium Very low Degree to which the impact can be mitigated: Low Low High Proposed mitigation: Biodiversity offset Biodiversity offset None Cumulative impact post mitigation: High Low to Medium Very low Significance rating of impact after mitigation High Low to Medium Very low

23 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

• Loss of vegetation type and important species identified

Development of the site would most probably result in loss of all vegetation on the site. The loss of all portions of intact vegetation and important species (i.e. Figure 4 & Appendix 1) would therefore result in HIGH NEGATIVE IMPACT for the design, construction and operational phases of the project and LOW to MEDIUM NEGATIVE IMPACT for degraded, alien-infested vegetation. Furthermore the impacts would have the same rating when considering the proposed mitigation (i.e. offset option). It would be difficult to avoid the intact vegetation since the largest patch occurs near the centre of the site.

• Loss of ecological processes

Loss of ecological processes is expected to be similar to impacts associated with the loss of vegetation. Ecological processes are difficult to assess since these are mostly unseen, however, based on the makeup, quality, size and connectivity of the habitat, such processes can be assumed to correlate with occurrence of patches of natural vegetation. The associated loss of ecological processes is therefore expected to result in HIGH NEGATIVE IMPACT for intact vegetation (e.g. Cape Flats Dune Strandveld and Atlantis Sand Fynbos) and species of conservation concern (e.g. Leucospermum parile) and LOW to MEDIUM NEGATIVE IMPACT for degraded, alien-infested vegetation.

Mitigation

The position of the intact vegetation (i.e. in the center of the site, Figure 4) means that the development alternative is only likely if a biodiversity offset is offered to compensate for the loss. The proposed offset of 1:1 ha for ENDANGERED Cape Flats Dune Strandveld pertains to most of the site, whereas the ratio 2:1 ha for CRITICALLY ENDANGERED Atlantis Sand Fynbos would apply to the strip of land along the southern boundary. The offset option is thus considered the only feasible mitigation option available.

24 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

7.3 Indirect impacts

Indirect impacts are impacts that are not a direct result of the proposed activity (in this case the construction of industrial buildings and associated infrastructure), but occur away from the original source of impact. No indirect impacts in terms of the vegetation were identified in this regard.

7.4 Cumulative impacts

Cumulative impacts are spatially related impacts assessed on local, regional and national scales, as appropriate, that may be caused by several projects, strategic actions and existing trends.

The cumulative loss of vegetation within the Atlantis Industrial Area has led to extensive loss of two vegetation types, namely Atlantis Sand Fynbos (CRITICALLY ENDANGERED) and Cape Flats Dune Strandveld (ENDANGERED). The further loss of intact Cape Flats Dune Strandveld and Atlantis Sand Fynbos on the study site would result in a HIGH NEGATIVE CUMULATIVE IMPACT.

8. Recommendations and Conclusions

• The proposed industrial development would impact on two vegetation types, which includes a large portion, and several smaller portions, of ENDANGERED, good quality Cape Flats Dune Strandveld within the northern half of the site, with high numbers of the ENDANGERED mesemb Ruschia indecora present. The second portion of vegetation occurs along the southern boundary in a relatively narrow strip, comprising CRITICALLY ENDANGERED, medium quality, Atlantis Sand Fynbos. This area harbours about 80 individuals of the ENDANGERED Malmesbury Pincushion (Leucospermum parile). • The transitional area - where the soil interface gives rise to a changeover and interchange of species between the vegetation types is of high conservation importance since such ecotones usually drive speciation and are important in terms of ecological processes.

25 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

• Both vegetation types, in particular the large portion of Cape Flats Dune Strandveld and the population of Leucospermum parile are of high conservation importance. However, these occur within an area overtaken by alien vegetation and with limited connectivity to the Atlantis dune area. Restoration, although possible, is unlikely to occur in the near future, which means that the land will undergo further degradation through alien invasion. In order for the land to hold any conservation value in the future, the alien vegetation would have to be eradicated and biodiversity corridors created to link with the Atlantis dune area. Active and ongoing management of the site would be required.

• The proposed offset is supported since this would ensure the conservation of an unfragmented area greater than the existing site that will be lost and it would become a well-managed conservation area. Thus although the impacts would be HIGH NEGATIVE these would more than adequately compensate in the offset scenario - a gain for biodiversity conservation.

9. References

Brownlie, S. 2005. Guideline for involving biodiversity specialists in EIA processes: Edition 1. CSIR Report No. ENV-S-C 2005-053 C. Provincial Government of the Western Cape: Department of Environmental Affairs and Development Planning.

Brownlie, S. and Both, M. 2009. Biodiversity offsets: adding to the conservation estate, or ‘no net loss’? Impacts Assessment and Project Appraisal, 27(3), September, pp. 227-231.

DEA&DP. 2011. Information Document on Biodiversity Offsets, EIA Guideline and Information Document Series. Western Cape Department of Environmental Affairs & Development Planning (DEA&DP). October 2011.

De Villiers, C.C. Driver, A. Clark, B. Euston-Brown, D.I.W. Day, E.G. Job, N. Helme, N.A. Holmes, P. M. Brownlie, S. and Rebelo, A. G. 2005. Fynbos Forum Ecosystem Guidelines for Environmental Assessment in the Western Cape. Fynbos Forum, Cape Town, 94pp.

26 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Government Gazette No 34809, 9 December 2011. Department of Environmental Affairs, No. 1002 of 2011. Threatened Terrestrial Ecosystems in South Africa.

Holmes, P. Stipinovich, A. and Purves, A. 2011. City of Cape Town’s Biodiversity Network. Environmental Resource Management Department (ERMD), City of Cape Town.

Mucina, L., Rutherford, M.C., & Powrie, L.W. (eds.). 2005. Vegetation map of South Africa, Lesotho, and Swaziland 1:1 000 000 scale sheet maps. South African National Biodiversity Institute, Pretoria. ISBN 1-919976-22-1.

Mucina, L. & Rutherford, M.C. 2006. (eds.) The Vegetation of South Africa. Lesotho & Swaziland. Strelitzia 19. South African National Biodiversity Institute, Pretoria.

Theron, N.T (compiler). 1990. 1: 250 000 Geological Series (Republic of South Africa): 3318 Cape Town. Government Printer, Pretoria.

______Report submitted: 11June 2012; revised 3 July 2012, 3 October 2012

27 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Appendix 1: Localities of Red List species recorded within the proposed industrial site on Farm 1183.

Waypoint reference Species and number of individuals Locality

057 Leucospermum parile (EN) X 1 plant 33°36'20.46"S 18°28'20.68"E

058 Leucospermum parile (EN) X 1 plant 33°36'20.92"S 18°28'20.47"E

059 Leucospermum parile (EN) X 15 plants 33°36'21.58"S 18°28'20.60"E

060 Leucospermum parile (EN) X 4 plants 33°36'19.98"S 18°28'22.14"E

061 Leucospermum parile (EN) X 2 plants 33°36'19.85"S 18°28'22.38"E

062 Leucospermum parile (EN) X 10 plants 33°36'19.64"S 18°28'22.45"E

063 Leucospermum parile (EN) X 10 plants 33°36'19.51"S 18°28'22.35"E

065 Leucospermum parile (EN) X 5 plants 33°36'19.17"S 18°28'22.63"E

066 Leucospermum parile (EN) X 1 plant 33°36'19.33"S 18°28'22.86"E

067 Leucospermum parile (EN) X 1 plant 33°36'20.11"S 18°28'22.85"E

068 Leucospermum parile (EN) X 2 plants 33°36'17.68"S 18°28'24.31"E

069 Leucospermum parile (EN) X 5 plants 33°36'17.28"S

18°28'23.47"E

070 Leucospermum parile (EN) X 4 plants 33°36'17.07"S 18°28'23.57"E

071 Leucospermum parile (EN) X 4 plants 33°36'17.04"S 18°28'23.88"E

072 Leucospermum parile (EN) X 4 plants 33°36'17.54"S 18°28'24.45"E

074 Leucospermum parile (EN) X 1 plants 33°36'16.08"S

28 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

18°28'27.73"E

075 Leucospermum parile (EN) X 1 plant 33°36'14.94"S 18°28'29.03"E

076 Leucospermum parile (EN) X 1 plant 33°36'14.44"S 18°28'29.97"E

077 Leucospermum parile (EN) X 4 plants 33°36'13.77"S 18°28'30.30"E

082 Leucospermum parile (EN) X 1 plant 33°36'7.06"S 18°28'22.07"E

29 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT Scoping and Environmental Impact Assessment for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

APPENDIX K:

Palaeontological Assessment Email confirmation from Dr. Graham Avery re. applicability of findings to the proposed Atlantis gas-to-power project

From: Graham Avery To: Date: 07/10/2016 09:12 Subject: Palaeontological Assessment: Proposed Development Farms CA1183 (Portions 1&4) and CA 4 (Portion 93), 3318CB Melkbosstrand

Dear Kelly,

Thank you for your enquiry re the basic palaeontological implications in my report: Avery, G. 2012. Palaeontological Assessment: Proposed Development Farms CA1183 (Portions 1&4) and CA 4 (Portion 93), 3318CB Melkbosstrand.

The information and recommendations therein still stand and I do not believe that a further study at this stage would change these materially.

Regards,

Graham Avery --

*Dr Graham Avery MRSSAf*

*Cell: 0834410028*

*Landline: 0214241285*

*Email: [email protected] *

*Archaeozoologist*

*Curator in Natural History Collections Department, Cenozoic Studies (retired)*

*Honorary Associate: Natural History Collections Department, Iziko Museums of South Africa, PO Box 61, Cape Town 8000*

*Honorary Research Associate, Archaeology Department, University of Cape Town* Palaeontological Assessment: Proposed Development Farms CA1183 (Portions 1&4) and CA 4 (Portion 93), 3318CB Melkbosstrand

Prepared by Graham Avery (Sole Proprietor)

Archaeozoology, Stone Age Archaeology and Quaternary Palaeontology

July, 2012

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Contents Executive Summary ...... 3 Location of the proposed development ...... 3 Method ...... 4 Introduction ...... 4 Palaeontological potential ...... 4 Conclusion ...... 7 Recommendations ...... 7 Heritage Permits Required ...... 8 References...... 8

Executive Summary

Dr Graham Avery was commissioned by Jenna Theron on behalf of Doug Jeffrey Environmental Consultants to conduct a survey of the palaeontological potential on proposed development, Farms CA1183 (Portions 1&4) And CA 4 (Portion 93), 3318CB Melkbosstrand.

Applicant: City of Cape Town Proposed activity: Industrial Development (renewable energy) Location: Atlantis Industrial Area A review of published sources and personal observations indicates that the proposed development falls on land under which deposits of potential palaeontological significance may exist. The area is within the Duinefontyn Dune Plume where wind erosion has in other parts exposed deeper sediments that underlie the Holocene (<10 000 year old (10 ka) Witzand Formation. Vegetation comprises a mix of indigenous Strandveld and alien Acacia species. Absolute dates place some fossil material at 330 ka, but there are even older known marine fossiliferous deposits dating back to at least 5 Ma (Million years ago) at the coast. Sparse scatters of stone artefacts of probable Early Stone Age occur with some of the fossils; Middle and Later Stone Age artefacts also occur, the latter on or within the Witzand Formation and most likely the result of activities of Khoekhoe herders, who arrived in the Western Cape some 2000 years ago. Similar occurrences may have been located during the archaeological survey of the proposed area. The occurrence of fossils in underlying sediments is a strong possibility, especially if excavations for foundations cut through the Witzand Formation and penetrate into underlying older sediments in which wetland deposits and/or fossils may be encountered. Collaboration between the contractor and a suitably-qualified palaeontologist (or archaeologist with appropriate experience) will be required during excavations for foundations and infrastructure so that information and/or material can be recorded appropriately. Prior access to geotechnical information and accurate foundation depths would help to determine the likelihood of this and the best strategy. Provided that the recommendations of this assessment are complied with, there is no palaeontological reason why the erection of the proposed development should not proceed.

Location of the proposed development The proposed area falls on 1:50 000 topographical map 3318CB Melkbosstrand and see Figure 1.

3

Figure 1. The location of the proposed development on the edge of the Atlantis Industrial Area. Note the proximity of the Witsand Dune Field.

Method A desktop study was conducted, by Dr G. Avery, Archaeozoologist.

Introduction The Western Cape is yielding significant fossil remains, dating back several million years, relating to South Africa’s palaeontological, palaeoenvironmental and past animal and human heritage. Hendey (1983) provides general background. Most observations of the more ancient occurrences are within a kilometer of the coast and associated with dune plumes; large areas further inland are vegetated or under agriculture and subaerial sediments have not been exposed; so the overall extent of the fossiliferous deposits, while likely to extend well into the Duinefontyn Dune Plume (Roberts, et al. 2009), which continues inland ‘Northeast’ of the Dassenberg site, remains to be confirmed. Foundations of any depth may intersect fossil-bearing deposits and have the potential to provide opportunities for observations in sediments otherwise inaccessible.

Palaeontological potential This report is the result of a desk top study. Rogers (1982) describes the basic lithography of the area. Apart from reference to fossils, he notes that peaty deposits occur in deeper sediments. Traces of Pleistocene age terrestrial fossils have been located in sediments along the west bank of the Diep River entrance to Rietvlei and in sediments underlying Rietvlei (Avery 1995). Early Pliocene marine mammal remains (whale bone) have been recovered from the Potsdam Sewerage pumping station (GA pers. observation), on Milnerton Beach at the Diep River estuary and Ysterplaats

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(Hendey 1969; Simpson 1973; Tankard 1975). During construction of the Koeberg Nuclear Power Station, Early Pliocene sediments yielded marine mammals, mainly whales. Further North, Middle Pleistocene terrestrial fossils and Middle Stone Age stone artefacts occur at Bokbaai (Mabbutt, et al. 1955). Elandsfontein (aka Hopefield Fossil Site) (Klein, et al. 2007), a major fossil occurrence in the Dune Plume extending from the Ysterfontein area (Roberts, et al. 2009) further North and some 20 km inland of Langebaan (Klein, et al. 2007), has yielded important Middle Pleistocene animal fossils (700 ka to 400 ka) and the earliest human remains (archaic Homo sapiens) found so far in the Western Cape. Late Pleistocene animal fossil occurrences occur along the coast from Melkbosstrand to Ysterfontein (GA pers. obs.) and at Elandsfontein (Inskeep 1966; Klein 1983). It is clear, therefore that the area is palaeontologically important. Witsand Dune Field Superficial dune sands cover most of the area and are <10 000 ka. Scatters of Later Stone Age pottery, stone artefacts and marine molluscs attest to human activity; remains of a black rhinoceros provide a specimen record confirming observations by the first European settlers in the area. Wind erosion in these areas does not penetrate the calcretes, which are often exposed. Pleistocene deposits undoubtedly exist below these. Duinefontein Dune Field Later Stone Age surface occurrences similar to those in the Witsand Dune Field occur in the dunes on Duinefontein (Stoch, L. unpublished records, Archaeology Section, Iziko Museums Social History Collections Department). During the 1950s and 1960s the Duinefontein dune field, which extended from Melkbosstrand to Groot Springfontein also yielded many fossils and early and Middle Stone Age artefacts (Hendey 1968; Hendey 1969), which were exposed and sandblasted. However, erosion also exposed better-preserved in situ reddish (ferrugenized) sediments, which have been carefully excavated and/or collected and published (Avery and Klein 2011; Cruz-Uribe, et al. 2003; Klein 1976; Klein, et al. 1999). DFT 1-4 Two major excavated samples, DFT 1, a hyaena den, and DFT2, ancient land surfaces around wetlands, have yielded 330 ka fossils of a wide range of mainly terrestrial mammals and birds and Early Stone Age artefacts (Cruz-Uribe, et al. 2003).

5

Figure 2. DFT 2 excavation with Koeberg Nuclear Power Station in background. The white dunes (top left) are the overlying Witzand Formation.

Figure 3. DFT 2 excavated surface with fossilized Eland vertebrae in reddish (ferrugenized sands).

DFT n This is a similar-aged temporary exposure, probably a hyaena accumulation, in the northernmost area of the Duinefontein Dune Field, which has yielded the earliest example of the South African Fur Seal, the species that lives around our coasts today, terrestrial mammals, marine and terrestrial birds and early Stone Age artefacts (Avery and Klein 2011).

6

Klein Springfontein A temporary exposure in the ‘Duinefontein Dune Field’ near the R27 yielded many fossils of terrestrial mammals, reptiles and birds, which were collected by GA and RG Klein and lodged in the Cenozoic Section of Iziko Museum’s Natural History Collections Department.

Koeberg Nuclear Power Station Excavations for the foundations of the Koeberg Nuclear Power Station yielded 14 m of terrestrial Middle Pleistocene deposits underlain by a further 14 m of highly fossiliferous marine deposits, dated to approximately 5 Ma, that extended to Malmesbury bedrock (Rogers 1979; Rogers 2006). Unique early Pliocene avian and marine mammal species, including a probable new species of Arctocephalus (the same genus the South African Fur Seal falls into), have been described from the site, e.g. (Avery and Klein 2011; Simpson 1975).

Human Burials Later Stone Age people inhabited the area as evidenced by surface scatters (above) and San and/or Khoekhoe burials may be encountered at any time or level e.g.(Pfeiffer and Van der Merwe 2004; Pfeiffer, et al. 1999).

Comments The background above serves to indicate the extensive heritage value of the area and the potential that fossiliferous deposits underlying the Witzand Formation may be encountered. It is also possible that sub-fossil remains of palaeontological interest could be encountered within Witzand Formation sediments. Good communication with contractors and periodic on-site monitoring during excavations will be required.

Conclusion From the above, it is clear that the proposed development is in an area under which potentially important palaeontological remains may occur. Such palaeontological remains are likely to be rare and sparsely distributed but, if encountered, must be carefully exposed and recorded by an appropriately qualified person. Provided that the recommendations in this report are followed, current information indicates that the proposed development will not impact significantly on palaeontological remains. Appropriately conducted the development may in fact provide opportunities to access rare fossil material and to better understand the local geological sequence. From the palaeontological perspective the development can be allowed to proceed.

Recommendations Excavations for foundations/infrastructure should be monitored by an appropriate palaeontologist. The frequency of this to be worked out a priori with the contractor to minimize time spent on site. 7

If possible, geotechnical information, together with the proposed depths of excavations for foundations and/or infrastructure, should be provided prior to the commencement of construction. This may enable a better estimation of the time(s) when monitoring will take place and even the extent of recovery work. Protocols for dealing with palaeontological monitoring/mitigation must be included in the Environmental Management Plan (EMP). Any such material is likely to be fragile and due care must be exercised. Any material recovered will be lodged in the collections of Iziko South African Museum. Funds must be available a priori to cover costs.

Heritage Permits Required The primary heritage legislation that needs to be considered is The South African Heritage Resources Act 25 of 1999 and regulations (details at www.sahra.org.za). All heritage material, including burials, is included. Clearance in terms of the National Heritage Act of 1999 will be required before the development can proceed. Locally, a permit will be required from Heritage Western Cape; in the event of a burial being exposed, SAHRA is the organization to contact along with the South African Police Services, but no bones should be further moved until an archaeologist or palaeontologist has assessed them. Although not required by the Act, it is suggested that, to obviate possible delays should fossil material be encountered, a permit be applied for before any excavation is initiated. This would enable the monitor to readily recover material, should it be encountered during construction activities.

References Avery, G. 1995 Archaeological and Palaeontological Survey: Milnerton Lagoon Mouth (3318CD). South African Museum. Avery, G., and R.G. Klein 2011 Review of fossil phocid and otariid seals from the southern and western coasts of South Africa. Transactions of the Royal Society of South Africa 61(1):14-24. Cruz-Uribe, K., et al. 2003 Excavation of buried Late Acheulean (Mid-Quaternary) land surfaces at Duinefontein 2, Western Cape Province, South Africa. Journal of Archaeological Science 30:559-575. Hendey, Q. Brett 1968 The Melkbos site: an Upper Pleistocene fossil occurrence in the South-Western Cape Province. Annals of the South African Museum 52:89-119. Hendey, Q.B. 1969 Quaternary vertebrate fossil sites in the south-western Cape Province. South African Archaeological Bulletin 24:96-105. 1983 Palaeoenvironmental implications of the late Tertiary vertebrate fauna of the fynbos region. In Fynbos Palaeoecology: a Preliminary Synthesis. H.J. Deacon, Q.B. Hendey, and J.J.N. Lambrechts, eds. Pp. 100-115. South African National Scientific Programmes Report, Vol. 75. Pretoria: South African National Sientific Programmes. Inskeep, R. R. 1966 Interesting association of bones from the Elandsfontein fossil site. Actes du V Congres Panafricaini de prehistoire et de L' Etude du Quaternaire.

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Klein, R.G. 1976 A preliminary report on the Duinefontein 2 "Middle Stone Age" open-air site (Melkbosstrand, South-Western Cape Province, South Africa). South African Archaeological Bulletin 31:12-20. 1983 Palaeoenvironmental implications of Quaternary large mammals in the Fynbos biome. In Fynbos Palaeoecology: a Synthesis. Pp. 116-138. South African National Scientific Programmes Reports. Pretoria: CSIR. Klein, R.G., et al. 2007 The mammalian fauna associated with an archaic hominin skullcap and later Acheulean artifacts at Elandsfontein, Western Cape Province, South Africa. Journal of Human Evolution 52:164- 186. Klein, R.G.., et al. 1999 Duinefontein 2: An Acheulean Site in the Western Cape Province of South Africa. Journal of Human Evolution 37(2):153-190. Mabbutt, J.A., et al. 1955 Geomorphology, archaeology and anthropology from Bokbaai, Darling District, Cape Province. South African Archaeological Bulletin 10:85-93. Pfeiffer, S., and N.J. Van der Merwe 2004 Cranial injuries to Later Stone Age children from the Modder River Mouth, Western Cape Province, South Africa. South African Archaeological Bulletin 59(180):59-65. Pfeiffer, S., et al. 1999 Violent human death in the past: a case from the Western Cape. South African Journal of Science 95(3):137-140. Roberts, DL, et al. 2009 West coast dune plumes: climate driven contrasts in dunefield morphogenesis along the western and southern South African coasts. Palaeogeography, Palaeoclimatology, Palaeoecology 271:24-38. Rogers, J. 1979 The sedimentary succession at the Koeberg nuclear power station, Melkbosstrand [Abstracts]. 18th Congress of the Geological Society of South Africa, 1979, pp. 310-322. 2006 Sedimentology of the Late Cenozoic sediments, including the Pliocene Duynefontein Member of the Varswater Formation, Koeberg nuclear power station, Melkbosstrand, Cape Town. African Natural History 2:194-196. Rogers, J. 1982 Lithostratigraphy of Cenozoic sediments between Cape Town and Eland’s Bay. Palaeoecology of Africa 15: 121-137. Simpson, G.G. 1973 Tertiary penguins (Sphenisciformes, Spheniscidae) from Ysterplaats, Cape Town, South Africa. South African Journal of Science 69:342-344. 1975 Tertiary penguins from the Duinefontein site, Cape province, South Africa. Annals of the South African Museum 79(1):1-7. Tankard, A. J. 1975 The marine Neogene Saldanha Formation. Transactions of the Geological Society of South Africa 78(2):257-264.

Dr Graham Avery MRSSAf 13 Prince Street Oranjezicht 8001 Cell: 0834410028 Email: [email protected]

Honorary Associate: Iziko Museums, Natural History Collections Department

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