RVM 1 HYDROELECTRIC POWER (PTY) LTD

RIEMVASMAAK HYDROPOWER PROJECT, ORANGE RIVER, NORTHERN CAPE PROVINCE, SOUTH AFRICA

ENVIRONMENTAL IMPACT ASSESSMENT VOLUME 5: COMMENT AND RESPONSE REPORT

DEA Reference Number: 14/12/16/3/3/2/600

Prepared for: Prepared by:

RVM1 Hydro Electric Power EOH Coastal & Environmental Services

Loft Office No. 6 Grahamstown The Woodmill Lifestyle Centre P.O. Box 934, Vredenburg Road Grahamstown, 6140 Stellenbosch

South Africa South Africa

FINAL REPORT

SEPTEMBER 2015

PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Final Environmental Impact Assessment Report September 2015

EOH Coastal & Environmental Services

Report Title: Comment and Response Report Report Version: Final Project Number: 279

Name Responsibility Shawn Johnston (SFZA) Compiler Bill Rowlston Reviewer

Copyright This document contains intellectual property and proprietary information that is protected by copyright in favour of RVM 1 Hydro Electric Power, EOH Coastal & Environmental Services (CES) and the specialist consultants. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of these parties. The document is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of South Africa.

REPORTS PRODUCED AS PART OF THIS EIA:

Volume 1: Environmental Scoping Report Volume 2: Specialist Reports Volume 3: Environmental Impact Assessment Report Volume 3a: Appendices to Environmental Impact Assessment Report Volume 4: Environmental Management Programme Volume 5 Comment and Response Report

Notes: (i) The Environmental Scoping Report was produced by Aurecon and accepted by DEA in October 2013 (ii) Volume 2 was compiled by EOH Coastal & Environmental Services (iii) Volumes 3, 4 and 5 were prepared by EOH Coastal & Environmental Services

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COMMENTS AND RESPONSE REPORT Comments & Issues submitted on the Draft Environmental Impact Assessment Report

Notes on the Report  Comments and issues are listed in alphabetical order of the surname of the person who submitted the comment or issue.  Some comments and issues were submitted by I&APs in PDF format and had to be retyped by Sustainable Futures ZA (SFZA). Minor typing errors may have occurred.  For this report comments and issues that were submitted in Afrikaans were translated into English. The original submissions are included in Appendix E of the EIA Report.  For some comments or issues headings were added or words highlighted to make it easier for the reader to identify the focus of the comment or issue.

No. Issue Raised by Response from CES EIA team or Hydro SA African Paddling Association and Gravity Adventures – Louise Kellet 1. Dear Mr Johnson, Louise Kellet, African Dear Mrs Louis-Marie Kellet, Is the Draft EIA already completed? How is this possible since Paddling Association Thank you for your e-mail. I hereby acknowledge receiving your the previous process was stopped and new consultants and Gravity e-mail and attached comments. (yourselves) were appointed? I was under the impression that Adventures, 23 April The DEIR has been completed. I sent a CD copy to your street the process would begin anew and I have not received any 2015. address by registered mail for review and comment. The DEIR is communications from you at all? Please explain the process in also available on the CES web site. detail so that I can understand what has been happening. We The EIA process was not cancelled. The process continues on have not made any submissions to you as part of the new from the scoping process as indicated in the acceptance of process – are you using all the information and comments scoping by the DEA Pretoria. The environmental impact gathered as part of the Aurecon process? assessment practitioner was changed from Aurecon to CES. I also need to make the following points. These have been CES is continuing with the EIA process. We are now in the raised before in the previous process and so I assumed you comments period of the DEIR. I have not received the comments would have been aware of them. you submitted previously, but I will included the comments in the 1. Surely the wording of the notice should use the word final environmental impact assessment when I receive them. “would” and not “will”. “Will” implies that the project is I look forward to your comments on the DEIR. definitely going ahead and this is not the case – it is merely Sincerely, a proposal at this stage. Shawn Johnston 2. This project is of National and International importance. You cannot just make Draft EIA report available locally and you EAP’s response cannot just consult locally. This would be a travesty of your Wording (1): The use of the word “will” does not mean that the role as an independent consultant. You need to consult project is definitely going ahead. Used in the context of an EIA widely and meaningfully. “will” indicates intention, and carries with it an implicit “if the 3. Similarly, the public meetings need to be held throughout project is authorised.”

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No. Issue Raised by Response from CES EIA team or Hydro SA the country, at least in the major centres – this Advertisements (3&4): The availability of the Draft EIAR was development is happening in a national park, which advertised nationally, provincially and locally in the Sunday belongs to the people of the country and is a national Times (25th April), and Die Burger, Die Gemsbok and Die asset. Volksblad (29th April), all as required by DEA. We believe we 4. I have attached the comments we submitted as part of the have conducted a consultation process that provides an Aurecon process – have these been included? opportunity to comment on the proposed project to anyone who 5. The Draft EIA needs to made available in an electronic form wishes to do so. so that it can be widely distributed for comment Documents (4): See comments from Shawn Johnston above. Sincerely, Availability of Draft EIAR (5): The Draft EIAR was and still is, Marie-Louise Kellett, African Paddling Association & Gravity available on CES’s website – www.cesnet.co.za – follow the link Adventures to Public Documents. 2. Dear Shawn Louise Kellet, African EAP’s response: I strongly suggest that you send a mail to each and every IAP Paddling Association The commentator was informed of the continuation of the and ask them to re‐submit their earlier comments. If mine have and Gravity assessment process by e-mail on 13th March 2015, re- been “lost” in the changeover of consultants, I am sure that the Adventures, 04 May registered as an I&AP, and provided with a copy of the BID. others have also. It would be in your interest to ensure that the 2015. All I&APs who were registered for the Scoping phase of the Public Participation process has been properly conducted as assessment were similarly informed of the continuation of the this is one of the major issues highlighted earlier on in the assessment process. process. I also urge you to consult widely and meaningfully – this is a national, not a local issue. Thank you, Marie-Louise Kellett 3. Preliminary Comments on the proposed Hydropower Plants Louise Kellet, African EAP’s response: at Augrabies Falls, Northern Cape. Submitted by Marie-Louise Paddling Association We note your concerns about developing projects that might Kellett for the Environmental Working Group, African Paddling and Gravity affect your association’s activities, and your suggestion that Association. December 17 2013 Adventures, 04 May alternative, less sensitive sites should be investigated. The African Paddling Association is a voluntary body 2015. Alternative sites: Alternative sites studied by the applicant are representing the commercial paddling industry in southern discussed in Chapter 5 of the EIA Report, where it is pointed out Africa. As such, we are well informed on the various water that there are few sites on South African rivers that are suitable bodies in our country as well as on their potential to develop for the generation of electricity without the need to construct green jobs for our people through ecotourism. Tourism is large impounding reservoirs to generate the necessary head, currently the largest provider of jobs in South Africa. The APA such as, for instance, the Gariep and Van der Kloof dams, both recognises the need to develop alternative energy production of which have had, and will continue to have, a profound technologies in order to reduce our reliance on fossil fuels. We influence on the flow regime of the Orange River. In this context are, however, 100% opposed to developing any projects in we note that DEA has recently granted environmental pristine, wilderness areas and areas of ecological importance. authorisation for another large instream dam, about 30m high, on Sites of less ecological significance should be investigated as a the Orange River, to facilitate the generation of 22MW of power priority over sites of such a pristine and ecological sensitive at the Rooikat HPP. nature. Protected areas: We believe that this project can be developed

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No. Issue Raised by Response from CES EIA team or Hydro SA and operated with minimal effects on the nature of the park and its surroundings, and with minimal effect on the Augrabies Falls or the Orange River as a whole as a tourist attraction,. 4. The APA also would like to object in the strongest possible Louise Kellet, African EAP’s response: terms to the public participation process for the following Paddling Association Your objections are noted. reasons; and Gravity Advertisement (1): See details of the extent of advertisement in 1. The Augrabies Falls (Riemvasmaak) project is of national Adventures, 04 May Comment No 1 above. and international importance – Augrabies Falls is in a 2015. Cumulative effects (2): The cumulative effects of the national park and is of importance to the whole country. development of structures in and on the Orange River are Despite this, the consultants and developer have treated it considered in section 7.6 of the EIA Report. as a local project and have only notified people in the It is important to note that the RVM HPP will not “destroy” the immediate area. This project should have been advertised Augrabies Falls. The commentator is referred section 3.3.1 of the at a provincial and national level with a meaningful public EIA Report for details of the effect of the project on the flow participation process. National and provincial tourism regime of the falls. bodies as well as civil society should have been fully and The project will not affect the river downstream of a point in the meaningfully consulted. In our opinion, the public middle of the Augrabies Gorge at all. participation is fatally flawed and should be declared null and void and the process started from scratch. 2. Individualised Scoping studies and EIA’s fail to recognise the cumulative effects of the various hydro schemes, dams and ‘flood control’ weirs being constructed and planned for the Orange. This applies particularly to the site identified at the Ritchie Falls near Onseepkans as the combined effect of this and the Augrabies Falls project will be to destroy two of the last remaining wilderness areas on the entire river. The combined effects of all of this construction needs to be considered as a whole and proper consultation done. In our opinion, a Strategic Environmental Assessment is of vital importance before any projects progress any further. 5. To comment in more detail: The APA does not support the Louise Kellet, African EAP’s response: proposed hydropower plants at Augrabies Falls and Ritchie Paddling Association The Orange as an international river: We are aware of the Falls, inter alia based on the following reasons: and Gravity status of the Orange River as an internationally-shared river, and 1. Transboundary River Adventures, 04 May of the various instruments that relate to its management. The Orange River is a transboundary river, whose basin is 2015. However, given that the proposed project will affect the flow shared between Lesotho, South Africa, Botswana and Namibia. regime of the river only between the diversion weir and the point The utilisation of these water resources is governed by bi- at which the diverted flow is returned undiminished to the lateral agreements between the participation countries. The mainstem river, a distance of about 10km, mostly through the overall development and management of the Basin is carried rocky gorge downstream of the Augrabies Falls, the project will out by the Orange-Senqu Basin Commission (ORASECOM). not affect the downstream riparians (and will certainly not affect

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No. Issue Raised by Response from CES EIA team or Hydro SA All of the member States, and especially South Africa are the upstream riparian, Lesotho). The requirements of the SADC signatories to the UN Convention on the Law of the Non- Water Sharing Protocol are the basis of the management of the Navigational Uses of International Watercourses, as well as the basin, which requires each basin-sharing state to “ utilise the SADC revised Protocol on Shared Watercourses. Any resources of the River System in their territories, take all development activities impacting on the Orange river must be appropriate measures to prevent the causing of significant harm in accordance with the principles of these conventions and to any other Party. The term "significant harm" shall be protocols, as well as the bilateral agreements (especially Article interpreted in line with the Revised Protocol on Shared 4 sub-clause 2 specifically refers to environmental protection Watercourses in the Southern African Development Community and preservation). Further, on the list of I&APS published (on (SADC) Region.” (Agreement on the Establishment of the the environmental project website) ORASECOM is not listed as Orange-Senqu River Commission, 7.4). Accordingly there is no an Interested and Affected Party. significant effect on the river that requires consultation with the In relation to this, ORASECOM has commissioned several other basin states in accordance with the SADC Protocol. detailed studies on the river as part of the process of Management of the River: The South African Department of developing a Basin Specific management plan. None of these Water and Sanitation is responsible for the management of the studies has been referenced or even mentioned in the report, Orange River Basin in South Africa, and for administering water- including the environmental flow requirements report. related agreements between South Africa and Namibia. The In a similar vein, the National legislation of the participating department has not raised any objections to the project, and has countries requires water resources to be managed from a written to the applicant confirming that sufficient water is available catchment approach i.e. from source to sea. In light of these for the construction (3 years) and operational (20 years) phases proposed hydropower plants, a strategic assessment that of the project, should it be approved. The period of availability of assess the cumulative impacts of all of the proposed hydro- water for operation relates to the maximum period of a water use power plants on the Orange river should be carried rather than licence, and not to the anticipated lifetime of the project, which the current process of individual site-specific assessments. may be of the order of 80 years or more. 6. 2. Due process – Augrabies Falls (Riemvasmaak Farm) Louise Kellet, African EAP’s response: The main objections to constructing power plants at this site Paddling Association National park; public consultation: The issue of consultation is relate to the sense of place and ecological sensitivity of the and Gravity addressed in the response to Comment 1 above. site. In terms of process, as the Augrabies site affects a Adventures, 04 May We are aware that elements of the infrastructure necessary to National Reserve – a national asset and thus the impact to the 2015. operationalise this project will be constructed across land that is asset extend beyond the boundaries of the municipality within part of the AFNP, and that other infrastructural elements will be in which it is located. Therefore public participation should have land that is not within the boundaries of the park but which are been carried out at a National scale including adverts and calls immediately adjacent to the park. for comments in all the major national newspapers. We are also aware, and have taken account of, the requirements Further, the Augrabies Falls is a declared National Park, and of the NEM: PAA and its Regulations. therefore subject to the National Environmental Management: We are also aware that there are no absolute legal prohibition of Protected Areas Act, Act 57 of 2003, and its regulations for the activities such as those contemplated in respect of this project, proper administration of special nature reserves, national parks but that it is necessary to obtain permission from the and world heritage sites, published un Government Notice management authority – in this case SANParks - before the R1061 IN Government Gazette 28181 of 28 October 2005. In project may be implemented. reference to these regulations: We are of the opinion that this project can be developed and 39. Interference with soil or substrate operated without significant impacts on the nature of the park and

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No. Issue Raised by Response from CES EIA team or Hydro SA (1) No person shall, except with the prior written permission its surroundings, and with minimal impacts on the Augrabies Falls of a management authority - (a) remove from a special as a tourist attraction. nature reserve, national park or world heritage site any- (i) soil, rock, mineral or similar material; (ii) wood, mulch or other dead vegetation; (iii) fossil, archaeological remains or cultural artefacts; (iv) ritual or spiritual remains; (v) coral or shells; or (vi) a shipwreck, flotsam or jetsam. (b) dig or intentionally disturb any soil or similar material in a special nature reserve, national park or world heritage site; or (c) intentionally disturb any - (i) wood, mulch, peat or other dead vegetation or animal in a special nature reserve, national park or world heritage site; (ii) termite mounds; (iii) fossil, shell midden, archaeological remains or paleontological specimens or meteorites in a special nature reserve, national park or world heritage site; or (iv) any of the marine components contemplated in paragraph (a); or (v) any object or material that is or was used for any ritual, spiritual or other practice. Further (2) No person shall construct an impoundment or weir on any river or river bed or abstract any water from any impoundment or weir on any river or in any river bed within a special nature reserve, national park or world heritage site, nor abstract any water by means of a pump, pipes, gravitation or any other means, located outside the boundary of a special nature reserve, national park or world heritage site, from any river or river bed forming a boundary with a special nature reserve, national park or world heritage sites without the written permission of a management authority and without conducting an environmental impact assessment. (own emphasis). 7. 42. Removal and dumping in water area Louise Kellet, African The response to Comment No 6 also refers to this comment. No persons shall, without the prior written consent of a Paddling Association management authority and subject to the conditions imposed and Gravity by the management authority, in any manner - Adventures, 04 May

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No. Issue Raised by Response from CES EIA team or Hydro SA (a) remove, dredge, pump or move any sand, soil or stones 2015. from a water area; (b) deposit, dump or throw sand, soil, stones or other material of any kind in a water area; or (c) construct any retaining wall or weir in a water area. Further, section 46 refers to buildings and improvements, requiring the prior written approval of a management authority and where necessary obtaining the necessary environmental authorisations prior to applying to the management authority for approval. While an EIA is being conducted, it only refers to application for authorisation in terms of the NEMA GN 544 AND GN545 listed activities, it does not include application for the necessary authorisation in terms of the NEM:PAA GNR 1061. Further: 17 Purpose of protected areas The purposes of the declaration of areas as protected areas are- (a) to protect ecologically viable areas representative of South Africa’s biological diversity and its natural landscapes and seascapes in a system of protected areas; (b) to preserve the ecological integrity of those areas; (c) to conserve biodiversity in those areas; (d) to protect areas representative of all ecosystems, habitats and species naturally occurring in South Africa; (e) to protect South Africa’s threatened or rare species;; (f) to protect an area which is vulnerable or ecologically sensitive; (g) to assist in ensuring the sustained supply of environmental goods and services; (h) to provide for the sustainable use of natural and biological resources; (i) to create or augment destinations for nature-based tourism; (j) to manage the interrelationship between natural environmental biodiversity, human settlement and economic development; (k) generally, to contribute to human, social, cultural, spiritual and economic development; or (l) to rehabilitate and restore degraded ecosystems and promote the recovery of endangered and vulnerable species.

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No. Issue Raised by Response from CES EIA team or Hydro SA Constructing of a hydropower plant and ancillary activities and infrastructure at the Augrabies Falls are in contradiction to these principles. 8. 3. Sense of Place and the Wilderness Experience – Augrabies Louise Kellet, African EAP’s response: Falls and Ritchie Falls Along the entire length of the Lower Paddling Association Note: This response addresses only the proposal to develop a Orange River, a high percentage of the riparian habitat is and Gravity hydroelectric power project (HPP) – the Riemvasmaak HPP - transformed (63.8%). Only 11.2% can be classified as pristine. Adventures, 04 May using the natural head generated by the Augrabies Falls, as set The Augrabies Falls and Ritchie Falls sites are located within 2015. out in the EIA Report currently under consideration. The the areas deemed to be pristine wilderness. This pristine possibility of an HPP being developed that uses the head wilderness nature and associated sense of place will be generated by the Ritchie Falls has nothing whatever to do with irrevocably damaged by the construction of a hydropower the Riemvasmaak HPP, and this response does not address any plant, regardless of any and all attempts to mitigate the impact. aspect of such a project. We do not agree that the two sites are Given that so few areas of wilderness still exist along the “irrevocably linked”. These comments are not relevant to the Orange, together with the fact that a river is a continuous issues at hand. system with impacts upstream having an effect downstream, Riparian habitat: We are aware that the construction of the these two sites are irrevocably linked, since the same diversion weir and offtake structure will necessitate the removal developer is planning hydro power plants for BOTH sites and of some riparian vegetation. The botanical report assesses the comments will therefore apply to both. impact thuswise: “The construction of the intake weir will impact Much has been written about the importance and effect of Lower Gariep Alluvial Vegetation to a small localised extent and wilderness and its effect upon the visitor. In “The Role and will not make a significant contribution to the cumulative loss of Function of Wilderness Trails in the Kruger National Park” By this Endangered vegetation type.” Barry Hopgood and Jaco Badenhorst, the authors use the Impact on flow regime: The impact of the project on the flow definition of wilderness as enshrined in United States of regime of the river is set out in section 3.3.1 of the EIA Report as America Wilderness act of 1964: follows: "In contrast with those areas where man and his own work  For ±20% of the time no flow will be diverted into the tailrace: dominate the landscape, as an area where the earth and its  For ±15% of the time (55 days) the river flows at or less communities of life are untrammelled by man, where man than 30m³/s, so no flow will be diverted into the headrace himself is a visitor who does not remain". The act went on to and the HPP will not operate. require that a wilderness retains "its primeval character and  For ±5% of the time (18 days) the river flows at more than influence", and that it be protected and managed in such a way 800m³/s. At this flow rate it is anticipated that the sediment that it "appears to have been affected primarily by the forces of loads in the river will begin to increase to such an extent nature". that sediment could be drawn into the headrace, and could They go on to say that “Although wilderness means something result in damage to the turbines. No flow will be diverted different to everyone, the main aspects of wilderness are: the into the headrace; power generation will be shut down to value of the wilderness experience; the value of wilderness as prevent damage to the turbines. a scientific resource and environmental baseline; the value of  For ±45% of the time (165 days, or 5.4 months) river flows are wilderness as heritage sites and the spiritual and symbolic between 30m³/s and 90m³/s, diverted flow will progressively value of wilderness to the nation and the world.” increase from zero to 38m³/s, and the power station will The Augrabies Falls and Gorge and to a greater degree, the operate at less than its installed generating capacity. Ritchie Falls and Orange Gorge fulfil all of the above  For ±35% of the time (128 days, or 4.2 months river flows

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No. Issue Raised by Response from CES EIA team or Hydro SA requirements. In fact, the Ritchie Falls and Orange Gorge have exceed 90m³/s but are less than 800m³/s, diverted flow will be been recognised as significant from an ecological and at a maximum of 38m³/s, and the power station will operate at ecotourism point of view and recommended for formal its full design capacity environmental protection. (LORMP, 2008:73) Augrabies Falls This means that, during the time when flow will be diverted to the has a particular sense of place The Khoi people called it hydropower station, the percentage reduction in the flow rate ‘Aukoerebis’, or place of Great Noise, as this powerful flow of over the falls will range from zero at a total river flow of 30 cubic water is unleashed from rocky surroundings characterized by metres per second (m3/sec) to 42.2% at 90m3/sec, falling to 4.2% the 18km abyss of the Orange River Gorge (ORASECOM, when the river flow is at 800 m3/sec. 2007:65). Reducing this thunder takes away the sense of place The project will therefore never reduce the flow over the falls to a from the falls, a little trickle down the falls doesn’t inspire the trickle. The flow regime over the falls can only be reduced to same sense of awe, inspiration and wonder when one stands accord with the commentators; fears by improper management of on the edge of the falls. releases from the very large dams upstream of Augrabies, and Wilderness areas, or areas with pristine habitat, devoid of mismanaged and / or uncontrolled abstractions from the river for human intrusions, both visually and audibly, are becoming off-channel consumptive uses. extremely scarce, and along the LOR, areas perceived as Pristine area: We appreciate the commentator’s being wild and pristine, are isolated and rare. Only a small acknowledgement that the area that will be affected by the portion of the river still retains this character, and it is project is not, in the true sense of the word, in “pristine” condition, imperative that these areas are formally protected (LORMP, but is in a “reasonably natural condition.” 2008:73). Both Augrabies Falls and Ritchie Falls fall within the As stated previously, we believe that the project can be identified wilderness areas with pristine habitat. Both sites are implemented so as not to significantly affect the current nature of parts of the Orange River in reasonably natural condition which the area. represent ecosystem types not conserved elsewhere. Areas of We do not wish to comment on the commentator’s perception of particular conservation importance include the gorge wilderness, nor on the various recommendations as to how the downstream of Augrabies Falls and the Falls at Onseepkans area should be managed. (Ritchie falls) (ORASECOM, 2007:60). In fact, to further enhance Augrabies’ pristine characteristic, it was recommended that the boathouse and equipment store, as well as the motorised boat currently used in the gorge be removed. The transition from pristine to high and even total impacts does change the quality of the experience (LORMP, 2008:81). Further, it is recommended that ecotourism overnight campsites within the pristine sections of the river must be based on wilderness camping principles, with no permanent infrastructure allowed. In addition the LOR Management Plan recommends that the status of this pristine section (Richie Falls and gorge) should be formalised by seeking protected area status in South Africa and Namibia (LORMP, 2008:103). The potential mitigation of the visual intrusion of the power plants at these sites is severely limited and does not mitigate

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No. Issue Raised by Response from CES EIA team or Hydro SA the human influence and impact to the area. There are no measures that can be taken to completely hide or disguise the structures effectively. One can’t plant a forest to hide the 4m high structures or transformer yard, as forest is not the natural vegetation in the area. Rock cladding may hide bland concrete walls, but the square, rigid and linear form of the infrastructure will still be in contrast to the abstract and random features of the area. At Ritchie Falls it will no longer be a pristine and undisturbed area. At the Ritchie Falls site, in addition to the impact on the Falls themselves, where the water will be almost entirely diverted except during high water events, the sense of place of the Orange Gorge (referred to in the report as the Southern Channel) will similarly be permanently affected – diversion of the flow into the northern channel will turn this awe inspiring gorge filled with rapids (and a world class whitewater kayaking route) into a series of stagnant pools, except during the high water events which occur far less often than in the past. 9. 4. Ecological Sensitivity Louise Kellet, African EAP’s response: Any effects on the ecology of the river as a result of the Paddling Association Aquatic ecology: The aquatic ecology study indicated that, with Augrabies Falls development will have to also, at a minimum, and Gravity the implementation of recommended mitigation measures, the also have to consider a scenario where the Ritchie Falls project Adventures, 04 May impacts of the project on the ecology of the river downstream of also goes ahead. This is because of the reasons pointed out 2015. the diversion weir will not be significant. The specialist opined above – the fact that the river is a system and if you consider that the rocky nature of the gorge, with a distinct lack of riparian the combined effects of both projects, the result might be and instream vegetation, is such that the reduction in flow rates catastrophic for the ecology of the river as a whole. (described above in Comment 8) will not result in significant The Lower Orange River (LOR) downstream of the Augrabies impacts on the ecology of the gorge. Falls is very important with regard to fish species, with 13 of the The impacts on aquatic ecology downstream from the point 15 indigenous freshwater fish of the Orange River found in the where the diverted flow re-joins the mainstem river will be LOR (ORASECOM, 2007:188) including endemic and red data negligible. species. Five of the six endemic Orange River Fish species Impacts on the river as a whole: We have no reason to doubt occur in this lower river section. Three of the five endemic the validity of the information provided by the commentator on the species, B. hospes, B. kimberleyensis, and Austroglanis impacts that have resulted from the regulation of the Orange sclateria are Red Data listed (ORASECOM, 2007:121). River. Further, these red data species tend to favour fast-flowing However, these impacts relate to major, macro-level manipulation water, below rapids (Cambray, 1984; Skelton and Cambray, of the river’s flow regime, over the entire length of the river in 1981; Benade, 1993; in ORASECOM (2007:189)). Therefore South Africa, by major dams inside South Africa (including the altering the flow regime over the falls and adjacent rapids will diversion of significant quantities of water to the Eastern Cape by directly and seriously impact on the breeding habitat of these the Orange-Fish Tunnel), and the abstraction of increasing red data species. volumes of water from the Orange for, among others, irrigation

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No. Issue Raised by Response from CES EIA team or Hydro SA Barbus hospes, the fish found only in the Orange river and mining. More recently, since the implementation of the downstream of Augrabies Falls, is a known species which LHWP, the flow regime in the Senqu has been manipulated by should be considered of special conservation importance the dams in Lesotho, which also facilitate the transfer of water (ORASECOM, 2007:60). Note that special conservation into the Reef area of South Africa via the Trans-Caledon Tunnel. requires the protection of the species habitat, in order to The impacts of the diversion of a maximum flow rate of support the continued breeding and survival of the fish species. 38 m3/sec, when the flow rate in the river permits (see Comment Further, within the distribution range of B. hospes, 8), for a distance of 10km before returning it undiminished to the geographically isolated populations of two fish species, river, cannot reasonably be compared to the major alterations to Mesobola brevianlia and barbus trimaculatus, occur. These two the river’s flow regime described above. species are of considerable interest for they may provide evidence of an ancient link between the drainages of the Okavango system and the Orange (ORASECOM, 2007:60). The report notes that should it become necessary to develop a dam in the lower Orange River, the conservation of these species would best be served by preserving as long an uninterrupted stretch of the lower river as possible. This would apply to the construction of weirs as well. The ecological consequences of flow changes include loss of species diversity, reed encroachment, loss of water through evaporation, change in water temperature and change in water quality. Loss of species diversity The review of available information has shown that loss of species diversity has taken place in the riparian vegetation, which is highly modified in many places. This can be directly ascribed to development of water resources of the river. Its importance lies in the fact that river reaches with natural riparian vegetation are limited and considered to be of conservation importance. Due to electric power generation (between Gariep and Vanderkloof dams and below Vanderkloof for some 200kms) loss of species diversity is severe. The river immediately below Vanderkloof has been described as an ecological desert. The creation of further “ecological deserts” would not be desirable (ORASECOM, 2007:61). Reed encroachment Reed encroachment of the channel in the middle reaches of the orange river has been considerable, subsequent to the regulation of flow by the Gariep and Vanderkloof dams (ORASECOM, 2007:61). This is problematic to flow and

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No. Issue Raised by Response from CES EIA team or Hydro SA sediment regimes and ecological habitat provision. The regulating of the flow via diverting-weirs will reduce the energy of the water and result in sediment deposition which promotes reed encroachment into the river channel. Blackfly increase Flow regulation has been accompanied by the appearance of major outbreaks of Simulium chutteri (black fly), which have resulted in annual losses of livestock to farmers estimated at R33million along an 800km stretch of the river. As in the case of reed encroachment, these outbreaks are ascribed to the artificial flow regime and it is considered that other flow regimes may contribute to their amelioration (ORASECOM, 2007:61). Adult female blackflies usually need a blood meal to complete the development of eggs. All outdoor activities are seriously affected, particularly general population, stock farming, irrigation farming, river rafting and other tourist activities (WRC, 2007:1). In terms of treatment, releases from Vanderkloof Dam are usually highly variable, and this makes it difficult to determine accurate dosages (WRC, 2007:2). The impact of the directing weirs on the flow regime will also impact on the ability to determine accurate dosages, or flush the larvae. Changes in temperature A changed temperature regime has profound impacts on the life of rivers and can result in conditions totally unsuitable for certain organisms (ORASECOM, 2007:62). Lower water levels can result in the water warming up quicker, whereas dam releases tend to result in thermic shock to fish resulting in fish deaths, as the water is suddenly colder than normal. Controlling the present mechanical manipulation of the river bed, banks and floodplain is extremely important as these factors are major contributors towards the decline in the condition of the riverine ecosystem, which together with the current manipulation of the flow regime will eventually lead to its complete collapse (LORMP, 2008: 31). The mechanical manipulation referred to above includes the controlled releases of water for irrigation, and would similarly include the control of flows in hydropower generation, especially where numerous hydro projects are planned for the same river. In an analysis of the median monthly flows, with Boegoeberg Dam as a point of reference going downstream to the

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No. Issue Raised by Response from CES EIA team or Hydro SA confluence with the Fish river, using data from 1914-01-01 to 1998-04-03, calculated that the natural flow patterns in the system showed an 82% summer (October to May) versus 18% winter (May to October) distribution. Minimum flow occurred during August (Wellington, 1933; Chutter, 1973; Benade, 1993) and maximum flow during February (Tomasson & Allanson, 1983; Benade, 1993), showing erratic flow peaks coupled with high silt loads (Tomasson & Allanson, 1983) (ORASECOM, 2007:120). Riverbed degradation resulting from suspended solid precipitation caused by the combination of low flows (river regulation), high evaporation rates and high mineral content (Agricultural and other pollution) leads to aquatic degradation, which could be detrimental to the survival of certain indigenous, including endemic organisms, while promoting the unwanted establishment of other indigenous, as well as alien organisms (ORASECOM, 2007:121) e.g. reed encroachment. Increasing river regulation and catchment utilisation will result in increases in filamentous Phycophytes and blue-green alga (algal blooms), and will also promote habitat changes suitable for the encroachment and colonisation of plant species. It can be expected that further river regulation will enhance habitat possibilities for economically important invertebrates such as Blackflies, the snail intermediate hosts of Bilharzia and Fluke spp, mosquito’s, etc. (ORASECOM, 2007:121). These species are economically important because of the devastation or economic impact they can impose should there be an outbreak of these invertebrates. When considering the Present Ecological State (PES) of the Orange river, the Augrabies and Richie Falls fall within the reach PESEIS 4: Orange Catchment from the Hartbees confluence to the estuary. The main PES of this reach is category C – moderately modified. Loss and change of natural habitat and biota have occurred, but the basic ecosystem functions are still predominantly unchanged. The improvement (in relation to upstream reaches) is due to the fact that the river is inaccessible or protected in many sections and the increasing abstractions of flow upstream has lessened the impact of the flow releases for hydropower and agriculture (ORASECOM, 2010:96). In other words, maintaining these

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No. Issue Raised by Response from CES EIA team or Hydro SA pristine and protected areas as natural and pristine is helping to maintain and improved ecological state of the river, i.e. if they were lost the ecological state of the river would decline. 10. In terms of the Ecological Importance and Sensitivity (EIS), the Louise Kellet, African Note: Remarks in Comment 8 relating to responses not Augrabies Falls and Richie Falls fall into the reach of EFR 03 Paddling Association addressing the Ritchie falls / Orange Gorge apply equally to this (ORASECOM, 2010b:65). The EIS evaluation results in a and Gravity comment. HIGH importance, including: Adventures, 04 May  Rare and endangered instream biota: BKIM, Simulium 2015. PES & EIS: We do not disagree with the information provided by gariepense; the commentator in respect of the Ecological Importance and  Rare and endangered riparian biota: Clawless otter, black Sensitivity. stork, straw-coloured fruit bat. A. erioloba (IUCN listed as The aquatic specialist assessed the Ecological Status of the declining). Euclea pseudenus (SANBI protected tree). section of the river that will be affected by HPP as Category C, Vegetation type = Lower Gariep Alluvial vegetation while the EIS was assessed as HIGH. (Conservation status: endangered).  Unique aquatic biota: Some fish species are endemic to the Orange System (ASCL, BAEN, and LCAP). BTRI IN Lower Orange possible unique population, BHOS endemic to lower Orange, MBRE isolated population in the Orange.  Unique riparian biota: Orange river white-eye restricted to catchment, paradise frog (SA Endemic), 6 endemic vegetation plants;  Riparian biota – taxon richness: 70 out of 87 riverine faunal species present (80% of expected);  Riparian habitat: Diversity of types and features: cobble beaches, grazing lawns, backwaters, intact riparian zones, reed beds and some mud flats.  Riparian migration corridor: a riparian band in the area annually inundated by high floods, remains intact, despite the larger area in the floodplains being cleared and planted with agricultural crops. This intact band forms a very important migration corridor for most of the riverine faunal species present in the area.  National parks, wilderness areas, reserves, heritage sites, natural areas: Augrabies Falls (ORASECOM, 2010b:65) and Richie Falls. 11. Changes in flows impact on the food source (Abundance of Louise Kellet, African EAP’s response: fish) of piscivorous species (ORASECOM, 2010b:68), e.g. Paddling Association Important Note: Remarks in Comment 8 relating to responses otters and kingfishers. Lower flows eliminate associated deep and Gravity not addressing the Ritchie falls / Orange Gorge apply equally to pool habitat (overhanging vegetation for kingfishers; emerging Adventures, 04 May this comment.

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No. Issue Raised by Response from CES EIA team or Hydro SA vegetation for warblers, weavers and moorhen and slower 2015. Changes in flow: Remarks in Comment 9 about the comparison backwater habitats (ducks, coots, storks) (ORASECOM, of macro-scale manipulation of the river’s flow regime with that 2010b:68). The changes in flows (removal of higher flows) arising from this project apply equally here. resulted in the marginal zone being vegetated with reeds and Environmental water requirements: We note the previous hygrophilous shrubs, reducing mudflats and alluvial sandbars. estimates of the EWR at the river mouth and elsewhere quoted Thus less waders (sandpipers, plovers) and open habitat by the commentator. A new section – 3.3.2 Previous animals (plovers, geese) present. Also species that use environmental water requirements recommendations – has been sandbars and sandbanks lose digging substrate (monitors, added to Chapter 3 of the EIA Report. bee-eaters, martins) (ORASECOM, 2010b:68). Clearing the It should be noted that the report referred to by the commentator site for construction, will remove the riparian vegetation which assessed the Present Ecological Status of the Boegoeberg to provide refuge, shelter, breeding and feeding habitats, and Augrabies reach of the river as Category C, while the Desired migration routes for riparian species. Ecological Status was Category B, which resulted in considerably The Recommended Ecological Category (REC) for the reach higher environmental flow recommendations. including Augrabies and Richie Falls, is a category B As described above (see Comment 8) no flow will be diverted (ORASECOM, 2010b:73). The REC refers to the management from the river until the flow rate approaching the diversion weir objective of the river reach, i.e. the river should be managed to reaches 30 m3/sec, which is the environmental flow achieve an improved PES status of category B. recommended by DWS. Noting that, on average during the last The river mouth ecological requirements currently released 20 years of record, the flow rate in the river has been less than from Vanderkloof Dam amounts to 289 million m3/a, and is 30 m3/sec for 15% of the time (55 days a year), failure to achieve based on fairly old methodology. Recent estimation of the the environmental flow through the falls of 30 m3/sec will be as a ecological requirement indicated an average requirement in result of upstream influences beyond the control of the applicant, the order of 1 062million m3/a (ORASECOM, 2007b:57). While and will never be due to water being diverted to the HPP. the proposed plants are run of river, and the volume of water in the greater flow of the river will not be reduced by the hydro- power plants, the volume of water through the falls at the selected sites will be reduced, especially in low flow and average conditions. In terms of the combined operating flows of the Richie Falls plant (Oranje Falls Farm) and the environmental flow requirements for the REC category B (ORASECOM, 2010b:91, table 9.8), the combined flow requirements exceed the monthly average flow. Further, the design flow alone exceeds the monthly average flow for 8 months of the year. As the Augrabies plant is a higher design capacity, it is assumed the flows will exceed the monthly average to a greater extent and further reduce the ability to implement the environmental flow requirements at the Falls. 12. 5. Ecotourism: Augrabies Falls Louise Kellet, African EAP’s response: There are various ecotourism products on offer associated Paddling Association See Comment 8 for details of the impacts of flow diversion on the with the Augrabies Falls. The magnificence of the falls are and Gravity flow regime downstream of the diversion weir and through the

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No. Issue Raised by Response from CES EIA team or Hydro SA central to all of the experiences on offer and it is very hard to Adventures, 04 May Augrabies Falls. predict exactly what the effect of the loss of the wilderness 2015. Rafting: The diversion weir is 2.35km upstream from the actual character as well as the loss of water flow on the falls will have entrance to the Augrabies falls, and 1.1km upstream of the on them. The effect of visitor numbers to the National Park is furthest point that a raft or canoe could safely navigate before also hard to quantify. This requires further study and entering the narrow, rocky channel immediately upstream from consultation. the entrance to the falls. The configuration of the HPP diversion Various rafting operators will have their routes severely weir is such that it will be passable by raft or canoe under all but curtailed on the section of the Orange above the falls and the very high and very low flow rates. It is difficult to understand how compensation for the associated financial losses that they will this will “severely curtail” the routes currently travelled by the incur must be included in the project planning process. Further rafting operators. studies and consultation will be needed to investigate this “Lost” submissions: All I&APs who were registered for the properly. Scoping phase of the assessment (conducted by Aurecon) were Anecdotal reports suggest that although certain rafting requested to re-register for the EIA phase, which was conducted operators have made written submissions protesting against by EOH Coastal & Environmental Services. We are not aware the development, these have been ‘lost’ by the consultants. that any comments have been “lost”, and all comments received This is obviously of great concern to us as it means that these from all I&APs during this phase of the assessment have been submissions need to be made again, which is time consuming included in this report. and disheartening for those opposing the project – those opposing the project are forced to use their own time and money to research and write comments for the project, in contrast to the environmental consultants who are paid to do it – not exactly a level playing field! 13. 6. Construction and operation Louise Kellet, African Important Note: Remarks in Comment 8 relating to responses Again, although the Ritchie Falls and Augrabies Falls projects Paddling Association not addressing the Ritchie falls / Orange Gorge apply equally to are considered as separate, in terms of the potential impacts and Gravity this comment. on the river system as a whole, it is impossible to consider the Adventures, 04 May Consultation process: We have conducted a comprehensive one without the other. The following comments will focus on 2015. public consultation process for the EIA phase of the assessment the Augrabies Falls projects but we need to reiterate that the that satisfies the requirements of the NEMA EIA Regulations. effects of the construction and operation of the Ritchie Falls The commentator was informed of the continuation of the project HAVE to be considered as well in order to get an assessment process by e-mail on 13th March 2015, re-registered accurate picture of the cumulative effect. as an I&AP, and provided with a copy of the BID. Construction and Operation: Augrabies Falls All I&APs who were registered for the Scoping phase of the Due to the flawed public consultation process, the APA assessment were similarly informed of the continuation of the only became aware of this project in recent weeks. Time has assessment process. therefore not permitted us to make a properly considered response on this subject and we would like this to be noted as a major problem in this project – due process has not be adequately followed and the consultants have erred in setting up a wholly under representative and meaningless public consultation process.

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No. Issue Raised by Response from CES EIA team or Hydro SA 14. 7. Conclusions Louise Kellet, African EAP’s response: Ritchie Falls and Orange Gorge: Given the many negative Paddling Association We note your objections to the project. impacts identified above, we strongly recommend that further and Gravity We also note your recommendation for an SEA to be conducted planning permission for this project be denied and that this Adventures, 04 May on the Orange River. area be given protected status as soon as possible to help 2015. prevent any such projects in the future. This is part of our country’s natural heritage and should not be handed over to a private company to generate profit for their own benefit and to our detriment. Augrabies Falls: Given the national and international significance of the site, we recommend that this project be abandoned completely. Alternatively, given the fatally flawed consultation process, we recommend that this project be halted and started again from scratch. Augrabies Falls and Ritchie Falls projects and all other proposed projects along the length of the Orange River: Given the unknown cumulative effects of all of the various structures being planned for the Orange, including but not limited to hydro-electric power stations, dangerous “flood control’ weirs etc, we recommend that a Strategic Environmental Assessment as well as a Reserve Assessment be conducted for the river as a whole. 15. REFERENCES Louise Kellet, African EAP’s response: Lower Orange River Management Plan (LORMP)(2008). Paddling Association Thank you for the list of references you used in your comments. Unlocking the Ecotourism potential of the river. Compiled by and Gravity Ecotoursim Afrika, for //Ai/Ais-Richtersveld Transfrontier park, Adventures, 04 May funded by South African Department of Water and Forestry. 2015. ORASECOM (2007). Environmental Considerations Pertaining to the Orange River. Report 005/2007. Prepared by WRP (Pty) Ltd., Jeffares Green Parkman Consultants (Pty) Ltd, Sechaba Consultants, Water Surveys Botswana and Windhoek Consulting Engineers. Funded by GTZ. ORASECOM (2007b). Summary of water requirements from the orange River Basin. Report 006/2007. Prepared by WRP (Pty) Ltd., Jeffares Green Parkman Consultants (Pty) Ltd, Sechaba Consultants, Water Surveys Botswana and Windhoek Consulting Engineers. Funded by GTZ. ORASECOM (2010). Support to Phase 2 of the ORASECOM Basin-wide Integrated Water Resources Management Plan: Desktop EcoClassifcation assessment. Prepared by WRP.

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No. Issue Raised by Response from CES EIA team or Hydro SA ORASECOM Report: 016/2011. ORASECOM (2010b). Support to Phase 2 of the ORASECOM Basin-wide Integrated Water Resources Management Plan: Environmental Flow Requirements Volume 1 (Main Report). Prepared by WRP, funded by GIZ. ORASECOM Report: 016/2011. “The Role and Function of Wilderness Trails in the Kruger National Park” By Barry Hopgood and Jaco Badenhorst, http://www.sanparks.co.za/parks/kruger/tourism/activities/wilde rness/articles/RoleFuncti onWTrailsKNP.pdf Water Research Commission (WRC)( 2007). Guidelines for integrated control of pest blackflies along the orange river. Compiled by Palmer, R.W., Rivers-Moore, N., Mullins, W., McPherson, V., and Hattingh, L. WRC Report No. 1558/1/07 Andrew Hockley - Augrabies 16. Hi Shawn, Dankie Gerhard Andrew Hockley, EAP’s response: Please register me as an interested and affected party for this Augrabies, 11 March The commentator was provided with access to all available unsolicited proposal of a Hydro Electric Scheme in the 2015, comment by e- documents relating to the project. primitive and remote areas of the Augrabies Falls National mail. Park and the Riemvasmaak Community Conservancy. In order for a realistic assessment of the proposal I hereby request the documents from which this new set of consultants will be referring to in making this assessment. In particular: Any document calculating the amount of water which could be available. Preferably from DWAF. Any Geological data, in particular the Earthquake Risk assessment. A fine scale contour map of the proposed Diversion Weir and Outtake structures, covering the full island, the island and in particular the potential for the erosion of the entire island. An assessment of the noise pollution inevitability during construction covering all weather variations and wind directions. Particularly important is the winter cold periods when any sound stays low and carries. An assessment of the water quality as returned to the river just above the man-made lake from Vredesvallei. Adding dead water to dead water appears unadvisable. Any research on the Cape Clawless Otter. Thanks and regards,

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No. Issue Raised by Response from CES EIA team or Hydro SA Andrew Hockly 17. Dear All and Dr Avis, Andrew Hockley, EAP’s response: Not sure if this is a comment or a request but my Augrabies, 28 April The suggested project title is noted. understanding is that Farm 497 is the Farm Waterval 497, 2015, comment by e- property of and location of the major disturbance in this mail. proposal. Is it not disingenuous for the location to be referred to as the Farm Riemvasmaak. A location I first hear of here.. Should the title of the proposal not be: UNSOLICITED PROPOSAL FOR THE DIVERSION OF THE ORANGE RIVERS NORTH CHANNEL WITHIN THE BORDERS OF THE AUGRABIES FALLS NATIONAL PARK ON FARM 497 WATERVAL, AND EXTENDING TO THE MELKBOSRAND NATURE RESERVE, PROPERTY OF THE RIEMVASMAAK TRUST.? Andrew Hockly 18. To whom it may concern Andrew Hockley, EAP’s response: The application is a monster of misinformation, half-•‐truths Augrabies, 22 June It is not possible to respond to the general comments in and bluster. 2015, comment by e- paragraphs 1 and 3. Our internet connections out here in the remote Northern Cape mail. are slow, unreliable and expensive. With regard to the commentator’s request in paras 4, 5 and 6 for The time set aside for us to fully comment after studying the an extension of time for comment we sent the following message proposal has been insufficient to do justice to this flagrant by e-mail shortly after receiving the request: disregard to the protections our constitution allows to protected Dear Mr Hockly, areas and the protections it gives to our most protected areas I refer to your request, included at the end of your e-mail and the deliberations one should give to such an enormous message dated 22nd June 2015, for an extension of the time breach of these. period for you to review and comment on the Draft Environmental Currently I am attempting to analyse the map, “ The South Impact Report and other associated documents that relate to the African Renewable Energy EIA Application Database” which EIA for the above project. contains spatial data for renewable energy applications for I note that your request comes seven weeks after the project environmental authorisation. On a brief study of this it is documents were made available to all I&APs for comment, and lacking this proposal which I see as disingenuous and does one week after the end of the two-week extension of the required not allow for a considered response. 30-day comment period. I therefore must request an extension to the comment period I also note that you have requested a “3 to 6 month extension which will allow the map to be updated and the full import of once these updates are available”, where “these updates” are the this unsolicited development proposal to be fully considered 2nd and 3rd quarter updates of the map associated with The and further comments as to its undesirable nature be South African Renewable Energy EIA Application Database. formulated, described and put forward. We estimate, working with the parameters you have set out, that We would probably require that the second and 3rd quarter we might expect to receive your comments and observations on updates appear on the map and then some time to allow us to the project documents sometime between January and April download, ponder and revert. I therefore request a 3 to 6 2016.

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No. Issue Raised by Response from CES EIA team or Hydro SA month extension once these updates are available. I am of the opinion that you have had sufficient time to review the Yours sincerely available documents, ponder, and prepare your comments. Andrew Hockly, Augrabies Accordingly I am not willing to entertain your request. If we receive your comments by the end of June (2015) we will ensure that they are submitted to the Department of Environmental Affairs as part of the Comment and Response Report. If you are unable to let us have your comments by the end of June please send them direct to the Department, with a copy to us. Yours sincerely, Shawn Johnston 19. Hi Shawn, Andrew Hockley, Dear Mr. Andrew Hockley, On the other hand, an incredible opportunity does present Augrabies, 07 July The commentator’s change of attitude towards the project is itself for Hydro and tourism working together. 2015, comment by e- noted. With a limited number of "Instream Flow Diversions", drop mail. Thank you for your comments. I acknowledge receiving it and will pools and other leading edge flow technology, a seriously include it in the issues and response trail. world-class opportunity presents. The outlet alone promises Sincerely, almost 4 km of what could be a world class attraction... Shawn Johnston I hereby claim copyright of attached and included materials etc etc. These outlines may be dated, included as is. Trusting this could open some interesting discussions. Andrew Hockly, Augrabies BirdLife South Africa – Simon Gear & Daniel Marnewick 20. Dear Kobus, Daniel Marnewick, The message was sent to Mr Kobus van Coppenhagen, who I am copying Simon Gear, our Policy and Advocacy Manager, Manager: Important drew Mr Marnewick’s attention to the project. who will register us as an I&AP as soon as possible. Thank Bird and Biodiversity Shawn Johnston you for bringing this matter to our attention. Areas and Regional Kind regards, Conservation Daniel Marnewick Programme, Manager: Important Bird and Biodiversity Areas and Regional BirdLife South Africa, Conservation Programme comment by e-mail, 29 BirdLife South Africa April 2015.

21. Hi Shawn, Simon Gear, Dear Simon, Policy & Advocacy Thank you of your e-mail. I hereby acknowledge that BirdLife SA Please register BirdLife South Africa as an I&AP on this Manager, BirdLife has been registered and an interested and affected party on the project, using my details below. South Africa, comment proposed HydroSA Riemvasmaak run-of-river hydro by e-mail, 14 May environmental impact assessment. With thanks, 2015. Sincerely, Shawn Johnston

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No. Issue Raised by Response from CES EIA team or Hydro SA Simon Gear Policy & Advocacy Manager Cliff Rossenrode 22. I would like to be listed as an interested and concerned party Cliff Rossenrode, Dear Mr. Rossenrode, Thank you for your sms. You have been to try and stop the proposed building of a dam on the Gariep comment by sms, 19 registered as a interested and affected party on the stakeholder river that would definitely be detrimental to the environment August 2015 database and will be informed of all project developments. and Augrabies park. Sincerely, Shawn Johnston Thank you, Cliff Rossenrode Kalahari Outventures – Craig Eksteen

Important Note: Comments Nos 23 to 34 were submitted by Mr Eksteen on 5th May 2015.09.10 Subsequently Mr Eksteen has reconsidered his view of the project, and has submitted the following documents in support of his reveised opinion

Hi Bill, Shawn Thank you for your email and the opportunity to update my comments regarding the Augrabies Hydro Project. I have attached an official letter reflecting our updated views on the project. We wish you the best of luck with the finalisation of your project. If you have any questions or need anything further, please do not hesitate to contact me. Please also let me know if you would like a signed version of the attached letter. Kind Regards Craig

+27 (0)54 453 0001 (o) +27 (0) 82 476 8213(c) +27 (0) 86 613 5692(f) [email protected] www.kalahari-adventures.co.za www.facebook.com/KalahariOutventures www.outventures.iblog.co.za

Dear Mr Johnston, I refer to my earlier submissions regarding the proposed RVM Hydro Power facility. Further study of the information provided by EOHCES in the Draft Environmental Impact Assessment has given me new insight regarding the project. The technology to be used and the construction method proposed, does not appear to be as invasive or destructive as I initially was led to believe. Furthermore, since it is now clear to me that the facility doesn’t use or pollute water, I cannot see it having any negative

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No. Issue Raised by Response from CES EIA team or Hydro SA impacts on my business on the Orange River. South Africa needs electricity generation and why not from a renewable source. I therefore retract my negative comments and wish to advise that although a portion of the construction will be in a sensitive area, if managed carefully, the overall impact will beneficial to the region and the country. I hope and trust that you will find this in order. If you have any questions or queries, please do not hesitate to contact me. Yours Sincerely Craig B. Eksteen (Owner/Director) +27 (0)82 476 8213 +27 (0)54 453 0001 [email protected]

EAP’s response: Thank you for your revised comments.

Accordingly the original comments can be ignored, but they have been left in place to conserve this report as a record of all comment suibmitted.as a record of all

23. Hi Shawn, Craig Eksteen, Dear Craig, Hope you are well? Kalahari Outventures, Thank you for your e-mail. You can send all of your comments to It seems as though there have been a few lost comments in comment by e-mail 05 me directly and I will include them into the Final EIR. the handover period from Aurecon to yourselves. May 2015. Craig, it would be important for your organization to review the We would like to resubmit our comments as we will be highly draft environmental impact assessment report and comment on affected and our input needs to be included in the final EIA the report in addition to your original comments you will be process submitting to me. Please suggest the way forward and who we should be The draft environmental impact assessment report is available on submitting more comments to and making sure that we are the CES web site: http://www.cesnet.co.za/public- properly represented. documents.html. Kind Regards, My team look forward to receiving your comments. Craig Sincerely, Shawn Johnston 24. COMMENTS AND OBJECTIONS Craig Eksteen, EAP’s response: BY KALAHARI ADVENTURES PTY LTD WITH REGARDS TO Kalahari Outventures, Your use of the river for your commercial activities is noted, THE PROPOSED AUGRABIES HYDRO SCHEME comment by e-mail 05 together with your objections to the project. Kalahari Adventures is a professional Adventure Safari May 2015. Alternative sites: The criteria used for selecting this site for the company specialising in personalised wilderness trips on the development of a hydroelectric project, and the alternative sites Orange River and into the Green Kalahari Desert. are set out in Chapter 5 of the EIA Report. KA is currently the largest provider of adventure activities on the river at Augrabies, operating within a 180km radius both

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No. Issue Raised by Response from CES EIA team or Hydro SA upstream and downstream of the Waterfall. KA also has contractual concessions within the Augrabies Falls National Park specifically relating to the proposed project. In 1997 a proposal was put forward to SANPARKS for access to the 9km of river upstream of the Augrabies waterfall in order to provide adventure and river activities. This concession was approved and has been in operation ever since. Currently the only adventure activity on offer within the Augrabies Waterfall national Park. The proposed site for the scheme and weir development is exactly in the middle of the wilderness paddling trip and pristine area. Audited figures reflect that approximately 20 000 people have enjoyed this experience since the concession has been active and that it is one of the highlights of a visitors stay in AFNP. Kalahari Adventures is 100% opposed to developing any projects in pristine, wilderness areas and areas of ecological importance. Sites of less ecological significance should be investigated as a priority over sites of such a pristine and ecological sensitive nature. 25. Ecotourism: Augrabies Falls Craig Eksteen, EAP’s response: There are various ecotourism products on offer associated Kalahari Outventures, Impacts of Neusberg HPP: We cannot comment on the issues with the Augrabies Falls. The magnificence of the falls are comment by e-mail 05 raised concerning the alleged impacts of the Neusberg HPP on central to all of the experiences on offer and it is very hard to May 2015. the Orange River or associated activities, and these concerns predict exactly what the effect of the loss of the wilderness should be addressed to DWS and the owner / operator of the character as well as the loss of water flow on the falls will have facility. on them. ALTHOUGH; WE HAVE ALREADY NOTICED A Curtailment of river route: Refer to the response to Comment MASSIVE INFLUENCE TO WATER CLARITY, RIVER 12 above. FLOWS AND ENVIRONMENTAL IMPACT FROM THE NEUS Fly fishing: the location of the fly fishing enterprise is not HYDRO PROJECT. The evidence is real and very visible. It is specified, and we are therefore not able to comment in an now public knowledge that the weir built was lower than informed manner on the potential impacts of the project on this planned/proposed and less water goes over what is left of the activity. scenically beautiful Neus waterfall. The readings from water Tourism: The specialist report on socio-economic and tourism affairs are far from what was suggested. Also a loss to one of impacts did not identify any impacts with significance greater than the well - known travel routes called the Rocky Route and a Medium, most of which can be mitigated to Low. It is huge impact to related tourism roleplayers. acknowledged that these are estimates of what is expected to The effect of visitor numbers to the National Park is also hard happen, and the actual impacts cannot be determined unless the to quantify. This requires further study and consultation as project is implemented. Accordingly we are not able to comment over 80 000 day visitors enjoy the park, waterfall and all on the question of entitlement to compensation, except to say its splendour..... annually. that they will need to relate to actual losses incurred as a direct The effect is much farther reaching with regards to tourism, as result of the project, should it proceed.

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No. Issue Raised by Response from CES EIA team or Hydro SA not only operators would be affected, agents, booking offices, “Lost” submissions: The commentator’s remarks about “lost” equipment manufacturers, fuel stations and all related parties submissions is a repeat of the remark in Comment 12. All I&APs would feel the consequences if these highly rated wilderness who were registered for the Scoping phase of the assessment assets are impacted. Kalahari Adventures will have its route (conducted by Aurecon) were requested to re-register for the EIA severely curtailed on the section of the Orange above the falls phase, which was conducted by EOH Coastal & Environmental and the compensation for the associated financial losses that Services. We are not aware that any comments have been “lost”, we will incur must be included in the project planning process. and all comments received from all I&APs during this phase of Further studies and consultation will be needed to investigate the assessment have been included in this report. this properly. With Flyfishing being one of the country’s biggest role-players in tourism worldwide and also KA’s biggest breadwinner, the effect of river flows, water clarities, and temperatures will have a huge negative impact to the recently recognised World Class Wilderness Flyfishing Venue. Having been operational for 20 years on the Orange River, we have very recently noticed the huge impact as mentioned above relating to the now operational Neus Hydro Scheme. In turn forcing us to move our activities further downstream to find the conditions that were once very suitable, but no longer. This has had a huge impact on our business, the environment, the flyfishing industry, the community and the area in general. Operators have made written submissions protesting against the development, these have been ‘lost’ by the consultants. This is obviously of great concern to us as it means that these submissions need to be made again, which is time consuming and disheartening for those opposing the project – those opposing the project are forced to use their own time and money to research and write comments for the project, in contrast to the environmental consultants who are paid to do it – not exactly a level playing field! 26. Construction and operation Craig Eksteen, EAP’s response: Construction and Operation: Augrabies Falls Due to the flawed Kalahari Outventures, Consultation: We do not agree that the public consultation public consultation process, Kalahari Adventures Pty Ltd only comment by e-mail 05 process for the EIA phase of the assessment was flawed. All became aware of this project late last year. Time has therefore May 2015. I&APs who were registered for the Scoping phase of the not permitted us to make a properly considered response on assessment (conducted by Aurecon) were requested to re- this subject and we would like this to be noted as a major register for the EIA phase, which was conducted by EOH Coastal problem in this project – due process has not be adequately & Environmental Services. Even if previously-registered I&APs followed and the consultants have failed in setting up a did not re-register they were provided with all available transparent and meaningful public consultation process. information. 27. Conclusions Craig Eksteen, EAP’s response:

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No. Issue Raised by Response from CES EIA team or Hydro SA Kalahari Adventures Pty Ltd: Given that IAP’s have not been Kalahari Outventures, Consultation: Response as for Comment 25 above. properly consulted and due process not followed, our company comment by e-mail 05 Impacts on tourism, loss of income, etc: The specialist report along with other stakeholders are already suffering the May 2015. on socio-economic and tourism impacts did not identify any consequences from recently completed projects. We are left impacts with significance greater than Medium, most of which can with no choice but to highly object on all fronts to the proposed be mitigated to Low. It is acknowledged that these are estimates site, claim loss of income and get suitably compensated for the of what is expected to happen, and the actual impacts cannot be huge impact on our business already and in the future if this determined unless the project is implemented. Accordingly we project goes ahead. are not able to comment on the question of entitlement to Tourism: We request a full economic impact study to be done compensation, except to say that they will need to relate to actual on the impact to tourism, as it is not only our company that will losses incurred as a direct result of the project, should it proceed. lose money, but our agents, retailers, service stations, Sanparks, staff, catering companies, equipment suppliers, TV productions and locally employed people. The impact is far wider reaching than being considered. Augrabies Falls: Given the national and international significance of the site, we recommend that this project be abandoned completely. Alternatively, given the fatally flawed consultation process, we recommend that this project be halted and started again from scratch. Augrabies Falls and all other proposed projects along the length of the Orange River: Given the unknown cumulative effects of all of the various structures being planned for the Orange, including but not limited to hydro-electric power stations, dangerous “flood control’ weirs etc, we recommend that a Strategic Environmental Assessment as well as a Reserve Assessment be conducted for the river as a whole. 28. Kalahari Adventures would also like to object in the strongest Craig Eksteen, Comment 28 is a repeat of Comment 4 above. possible terms to the public participation process for the Kalahari Outventures, The response is the same. following reasons; (ADDITIONAL INFORMATION COMPILED comment by e-mail 05 BY MRS M-L KELLET ON BEHALF OF THE AFRICAN May 2015. PADDLING ASSOCIATION) 1. The Augrabies Falls (Riemvasmaak) project is of national and international importance – Augrabies Falls is in a national park and is of importance to the whole country. Despite this, the consultants and developer have treated it as a local project and have only notified people in the immediate area. This project should have been advertised at a provincial and national level with a meaningful public participation process. National and provincial tourism bodies as well as civil society should have been fully and meaningfully consulted. In our

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No. Issue Raised by Response from CES EIA team or Hydro SA opinion, the public participation is fatally flawed and should be declared null and void and the process started from scratch.

2. Individualised Scoping studies and EIA’s fail to recognise the cumulative effects of the various hydro schemes, dams and ‘flood control’ weirs being constructed and planned for the Orange. This applies particularly to the site identified at the Ritchie Falls near Onseepkans as the combined effect of this and the Augrabies Falls project will be to destroy tow of the last remaining wilderness areas on the entire river. The combined effects of all this construction needs to be considered as a whole and proper consultation done. In our opinion, a Strategic Environmental Assessment is of vital importance before any projects progress any further. 29. To comment in more detail: Kalahari Adventures Pty Ltd does Craig Eksteen, Comment 29 is a repeat of Comment 5 above. not support the proposed hydropower plant at Augrabies Falls Kalahari Outventures, The response is the same. or other identified sites along the Orange River, inter alia comment by e-mail 05 based on the following reasons: May 2015. Transboundary River

The Orange River is a transboundary river, whose basin is shared between Lesotho, South Africa, Botswana and Namibia. The utilisation of this water resources is governed by bi-lateral agreements between the participation countries. The overall development and management of the Basin is carried out by the Orange-Senqu Basin Commission (ORASECOM). All of the member States, and especially South Africa are signatories to the UN Convention on the Law of the Non- Navigational Uses of International Watercourses, as well as the SADC revised Protocol on Shared Watercourses. Any development activities impacting on the Orange river must be in accordance with the principles of these conventions and protocols, as well as the bilateral agreements (especially Article 4 sub- clause 2 specifically refers to environmental protection and preservation).

Further, on the list of I&APS published (on the environmental project website) ORASECOM is not listed as an Interested and Affected Party.

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No. Issue Raised by Response from CES EIA team or Hydro SA In relation to this, ORASECOM has commissioned several detailed studies on the river as part of the process of developing a Basin Specific management plan. None of these studies has been referenced or even mentioned in the report, including the environmental flow requirements report.

In a similar vein, the National legislation of the participating countries requires water resources to be managed from a catchment approach i.e. from source to sea. In light of these proposed hydropower plants, a strategic assessment that assess the cumulative impacts of all of the proposed hydro- power plants on the Orange river should be carried rather than the current process of individual site- specific assessments. 30. Due process – Augrabies Falls (Riemvasmaak Farm) Craig Eksteen, Comments 30 & 31 are repeats of Comment 6 & 7 above. The main objections to constructing power plants at this site Kalahari Outventures, The responses are the same. relate to the sense of place and ecological sensitivity of the comment by e-mail 05 site. In terms of process, as the Augrabies site affects a May 2015. National Reserve – a national asset and thus the impact to the asset extend beyond the boundaries of the municipality within which it is located. Therefore public participation should have been carried out at a National scale including adverts and calls for comments in all the major national newspapers. 31. Further Craig Eksteen, The Augrabies Falls is a declared National Park, and therefore Kalahari Outventures, subject to the National Environmental Management: Protected comment by e-mail 05 Areas Act, Act 57 of 2003, and its regulations for the proper May 2015. administration of special nature reserves, national parks and world heritage sites, published un Government Notice R1061 IN Government Gazette 28181 of 28 October 2005. In reference to these regulations: 39. Interference with soil or substrate (1) No person shall, except with the prior written permission of a management authority a) remove from a special nature reserve, national park or world heritage site any- (i) soil, rock, mineral or similar material; (ii) wood, mulch or other dead vegetation; (iii) fossil, archaeological remains or cultural artefacts; (iv) ritual or spiritual remains; (v) coral or shells; or (vi) a shipwreck, flotsam or jetsam.

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No. Issue Raised by Response from CES EIA team or Hydro SA (b) dig or intentionally disturb any soil or similar material in a special nature reserve, national park or world heritage site; or (c) intentionally disturb any - (i) wood, mulch, peat or other dead vegetation or animal in a special nature reserve, national park or world heritage site; (ii) termite mounds; (iii) fossil, shell midden, archaeological remains or paleontological specimens or meteorites in a special nature reserve, national park or world heritage site; or (iv) any of the marine components contemplated in paragraph (a); or (v) any object or material that is or was used for any ritual, spiritual or other practice. Further (2) No person shall construct an impoundment or weir on any river or river bed or abstract any water from any impoundment or weir on any river or in any river bed within a special nature reserve, national park or world heritage site, nor abstract any water by means of a pump, pipes, gravitation or any other means, located outside the boundary of a special nature reserve, national park or world heritage site, from any river or river bed forming a boundary with a special nature reserve, national park or world heritage sites without the written permission of a management authority and without conducting an environmental impact assessment. (own emphasis). 42. Removal and dumping in water area No persons shall, without the prior written consent of a management authority and subject to the conditions imposed by the management authority, in any manner - (a) remove, dredge, pump or move any sand, soil or stones from a water area; (b) deposit, dump or throw sand, soil, stones or other material of any kind in a water area; or (c) construct any retaining wall or weir in a water area. Further, section 46 refers to buildings and improvements, requiring the prior written approval of a management authority and where necessary obtaining the necessary environmental authorisations prior to applying to the management authority for approval. While an EIA is being conducted, it only refers to application for authorisation in terms of the NEMA GN 544

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No. Issue Raised by Response from CES EIA team or Hydro SA AND GN545 listed activities, it does not include application for the necessary authorisation in terms of the NEM:PAA GNR 1061. Further: 17 Purpose of protected areas The purposes of the declaration of areas as protected areas are- (a) to protect ecologically viable areas representative of South Africa’s biological diversity and its natural landscapes and seascapes in a system of protected areas; (b) to preserve the ecological integrity of those areas; (c) to conserve biodiversity in those areas; (d) to protect areas representative of all ecosystems, habitats, species naturally occurring in SA (e) to protect South Africa’s threatened or rare species; (f) to protect an area which is vulnerable or ecologically sensitive; (g) to assist in ensuring the sustained supply of environmental goods and services; (h) to provide for the sustainable use of natural and biological resources; (i) to create or augment destinations for nature-based tourism; (j) to manage the interrelationship between natural environmental biodiversity, human settlement and economic development; (k) generally, to contribute to human, social, cultural, spiritual and economic development; or (l) to rehabilitate and restore degraded ecosystems and promote the recovery of endangered and vulnerable species. Constructing of a hydropower plant and ancillary activities and infrastructure at the Augrabies Falls are in contradiction to these principles. 32. Sense of Place and the Wilderness Experience – Augrabies Craig Eksteen, Comment 32 is a repeat of Comment 8 above. Falls Kalahari Outventures, The response is the same. Along the entire length of the Lower Orange River, a high comment by e-mail 05 percentage of the riparian habitat is transformed (63.8%). Only May 2015. 11.2% can be classified as pristine. The Augrabies Falls site is located within the area deemed to be pristine wilderness. This pristine wilderness nature and associated sense of place will be irrevocably damaged by the construction of a hydropower

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No. Issue Raised by Response from CES EIA team or Hydro SA plant, regardless of any and all attempts to mitigate the impact. Given that so few areas of wilderness still exist along the Orange, together with the fact that a river is a continuous system with impacts upstream having an effect downstream, these two sites are irrevocably linked, since the same developer is planning hydro power plants for BOTH sites and comments will therefore apply to both.

Augrabies Falls has a particular sense of place The Khoi people called it ‘Aukoerebis’, or place of Great Noise, as this powerful flow of water is unleashed from rocky surroundings characterized by the 18km abyss of the Orange River Gorge (ORASECOM, 2007:65). Reducing this thunder takes away the sense of place from the falls, a little trickle down the falls doesn’t inspire the same sense of awe, inspiration and wonder when one stands on the edge of the falls.

Wilderness areas, or areas with pristine habitat, devoid of human intrusions, both visually and audibly, are becoming extremely scarce, and along the LOR, areas perceived as being wild and pristine, are isolated and rare. Only a small portion of the river still retains this character, and it is imperative that these areas are formally protected (LORMP, 2008:73). Both Augrabies Falls and Ritchie Falls fall within the identified wilderness areas with pristine habitat. Both sites are parts of the Orange River in reasonably natural condition which represent ecosystem types not conserved elsewhere. Areas of particular conservation importance include the gorge downstream of Augrabies Falls and the Falls at Onseepkans (Ritchie falls) (ORASECOM, 2007:60).

In fact, to further enhance Augrabies’ pristine characteristic, it was recommended that the boathouse and equipment store, as well as the motorised boat currently used in the gorge be removed. The transition from pristine to high and even total impacts does change the quality of the experience (LORMP, 2008:81).Further, it is recommended that ecotourism overnight campsites within the pristine sections of the river must be based on wilderness camping principles, with

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No. Issue Raised by Response from CES EIA team or Hydro SA no permanent infrastructure allowed. The potential mitigation of the visual intrusion of the power plants at these sites is severely limited and does not mitigate the human influence and impact to the area. There are no measures that can be taken to completely hide or disguise the structures effectively. One can’t plant a forest to hide the 4m high structures or transformer yard, as forest is not the natural vegetation in the area. Rock cladding may hide bland concrete walls, but the square, rigid and linear form of the infrastructure will still be in contrast to the abstract and random features of the area. The Augrabies Falls area will no longer be a pristine and undisturbed area.

At the Augrabies Falls site, in addition to the impact on the Falls themselves, where the water will be tapped, the sense of place of the river and area will similarly be permanently affected – diversion of the flow into the northern channel will turn this wilderness area filled with rapids (and top class rafting, flyfishing and wilderness adventure) into a series of slow and stagnant pools, except during the high water events which occur far less often than in the past. 33. Ecological Sensitivity Craig Eksteen, Comment 33 is a repeat of Comments 9, 10 & 11 above. Any effects on the ecology of the river as a result of the Kalahari Outventures, The responses are the same. Augrabies Falls development will have to also, at a minimum, comment by e-mail 05 also have to consider a scenario where the Ritchie Falls May 2015. project also goes ahead. This is because of the reasons pointed out above – the fact that the river is a system and if you consider the combined effects of both projects, the result might be catastrophic for the ecology of the river as a whole. The Lower Orange River (LOR) downstream of the Augrabies Falls is very important with regard to fish species, with 13 of the 15 indigenous freshwater fish of the Orange River found in the LOR (ORASECOM, 2007:188) including endemic and red data species. Five of the six endemic Orange River Fish species occur in this lower river section. Three of the five endemic species, B. hospes, B. kimberleyensis, and Austroglanis sclateria are Red Data listed (ORASECOM, 2007:121). Further, these red data species tend to favour fast-flowing water, below rapids (Cambray, 1984; Skelton and Cambray,

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No. Issue Raised by Response from CES EIA team or Hydro SA 1981; Benade, 1993; in ORASECOM (2007:189)). Therefore altering the flow regime over the falls and adjacent rapids will directly and seriously impact on the breeding habitat of these red data species. Barbus hospes, the fish found only in the Orange river downstream of Augrabies Falls, is a known species which should be considered of special conservation importance (ORASECOM, 2007:60). Note that special conservation requires the protection of the species habitat, in order to support the continued breeding and survival of the fish species. Further, within the distribution range of B. hospes, geographically isolated populations of two fish species, Mesobola brevianlia and barbus trimaculatus, occur. These two species are of considerable interest for they may provide evidence of an ancient link between the drainages of the Okavango system and the Orange (ORASECOM, 2007:60). The report notes that should it become necessary to develop a dam in the lower Orange River, the conservation of these species would best be served by preserving as long an uninterrupted stretch of the lower river as possible. This would apply to the construction of weirs as well. The ecological consequences of flow changes include loss of species diversity, reed encroachment, loss of water through evaporation, change in water temperature and change in water quality. Loss of species diversity The review of available information has shown that loss of species diversity has taken place in the riparian vegetation, which is highly modified in many places. This can be directly ascribed to development of water resources of the river. Its importance lies in the fact that river reaches with natural riparian vegetation are limited and considered to be of conservation importance. Due to electric power generation (between Gariep and Vanderkloof dams and below Vanderkloof for some 200kms) loss of species diversity is severe. The river immediately below Vanderkloof has been described as an ecological desert. The creation of further “ecological deserts” would not be desirable (ORASECOM, 2007:61). Reed encroachment

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No. Issue Raised by Response from CES EIA team or Hydro SA Reed encroachment of the channel in the middle reaches of the orange river has been considerable, subsequent to the regulation of flow by the Gariep and Vanderkloof dams (ORASECOM, 2007:61). This is problematic to flow and sediment regimes and ecological habitat provision. The regulating of the flow via diverting-weirs will reduce the energy of the water and result in sediment deposition which promotes reed encroachment into the river channel. Blackfly increase Flow regulation has been accompanied by the appearance of major outbreaks of Simulium chutteri (black fly), which have resulted in annual losses of livestock to farmers estimated at R33million along an 800km stretch of the river. As in the case of reed encroachment, these outbreaks are ascribed to the artificial flow regime and it is considered that other flow regimes may contribute to their amelioration (ORASECOM, 2007:61). Adult female blackflies usually need a blood meal to complete the development of eggs. All outdoor activities are seriously affected, particularly general population, stock farming, irrigation farming, river rafting and other tourist activities (WRC, 2007:1). In terms of treatment, releases from Vanderkloof Dam are usually highly variable, and this makes it difficult to determine accurate dosages (WRC, 2007:2). The impact of the directing weirs on the flow regime will also impact on the ability to determine accurate dosages, or flush the larvae. Changes in temperature A changed temperature regime has profound impacts on the life of rivers and can result in conditions totally unsuitable for certain organisms (ORASECOM, 2007:62). Lower water levels can result in the water warming up quicker, whereas dam releases tend to result in thermic shock to fish resulting in fish deaths, as the water is suddenly colder than normal. Controlling the present mechanical manipulation of the river bed, banks and floodplain is extremely important as these factors are major contributors towards the decline in the condition of the riverine ecosystem, which together with the current manipulation of the flow regime will eventually lead to its complete collapse (LORMP, 2008: 31). The mechanical

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No. Issue Raised by Response from CES EIA team or Hydro SA manipulation referred to above includes the controlled releases of water for irrigation, and would similarly include the control of flows in hydropower generation, especially where numerous hydro projects are planned for the same river. In an analysis of the median monthly flows, with Boegoeberg Dam as a point of reference going downstream to the confluence with the Fish river, using data from 1914-01-01 to 1998-04-03, calculated that the natural flow patterns in the system showed an 82% summer (October to May) versus 18% winter (May to October) distribution. Minimum flow occurred during August (Wellington, 1933; Chutter, 1973; Benade, 1993) and maximum flow during February (Tomasson & Allanson, 1983; Benade, 1993), showing erratic flow peaks coupled with high silt loads (Tomasson & Allanson, 1983) (ORASECOM, 2007:120). Riverbed degradation resulting from suspended solid precipitation caused by the combination of low flows (river regulation), high evaporation rates and high mineral content (Agricultural and other pollution) leads to aquatic degradation, which could be detrimental to the survival of certain indigenous, including endemic organisms, while promoting the unwanted establishment of other indigenous, as well as alien organisms (ORASECOM, 2007:121) e.g. reed encroachment. Increasing river regulation and catchment utilisation will result in increases in filamentous Phycophytes and blue-green alga (algal blooms), and will also promote habitat changes suitable for the encroachment and colonisation of plant species. It can be expected that further river regulation will enhance habitat possibilities for economically important invertebrates such as Blackflies, the snail intermediate hosts of Bilharzia and Fluke spp, mosquito’s, etc. (ORASECOM, 2007:121). These species are economically important because of the devastation or economic impact they can impose should there be an outbreak of these invertebrates. When considering the Present Ecological State (PES) of the Orange river, the Augrabies and Richie Falls fall within the reach PESEIS 4: Orange Catchment from the Hartbees confluence to the estuary. The main PES of this reach is category C – moderately modified. Loss and change of natural habitat and biota have occurred, but the basic ecosystem

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No. Issue Raised by Response from CES EIA team or Hydro SA functions are still predominantly unchanged. The improvement (in relation to upstream reaches) is due to the fact that the river is inaccessible or protected in many sections and the increasing abstractions of flow upstream has lessened the impact of the flow releases for hydropower and agriculture (ORASECOM, 2010:96). In other words, maintaining these pristine and protected areas as natural and pristine is helping to maintain and improved ecological state of the river, i.e. if they were lost the ecological state of the river would decline. In terms of the Ecological Importance and Sensitivity (EIS), the Augrabies Falls and Richie Falls fall into the reach of EFR 03 (ORASECOM, 2010b:65). The EIS evaluation results in a HIGH importance, including:  Rare and endangered instream biota: BKIM, Simulium gariepense;  Rare and endangered riparian biota: Clawless otter, black stork, straw-coloured fruit bat. A.erioloba (IUCN listed as declining). Euclea pseudenus (SANBI protected tree). Vegetation type = Lower Gariep Alluvial vegetation (Conservation status: endangered).  Unique aquatic biota: Some fish species are endemic to the Orange System (ASCL, BAEN, and LCAP). BTRI IN Lower Orange possible unique population, BHOS endemic to lower Orange, MBRE isolated population in the Orange.  Unique riparian biota: Orange river white-eye restricted to catchment, paradise frog (SA Endemic), 6 endemic vegetation plants;  Riparian biota – taxon richness: 70 out of 87 riverine faunal species present (80% of expected);  Riparian habitat: Diversity of types and features: cobble beaches, grazing lawns, backwaters, intact riparian zones, reed beds and some mud flats.  Riparian migration corridor: a riparian band in the area annually inundated by high floods, remains intact, despite the larger area in the floodplains being cleared and planted with agricultural crops. This intact band forms a very important migration corridor for most of the riverine faunal species present in the area.  National parks, wilderness areas, reserves, heritage sites,

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No. Issue Raised by Response from CES EIA team or Hydro SA natural areas: Augrabies Falls (ORASECOM, 2010b:65) and Richie Falls. Changes in flows impact on the food source (Abundance of fish) of piscivorous species (ORASECOM, 2010b:68), e.g. otters and kingfishers. Lower flows eliminate associated deep pool habitat (overhanging vegetation for kingfishers; emerging vegetation for warblers, weavers and moorhen and slower backwater habitats (ducks, coots, storks) (ORASECOM, 2010b:68). The changes in flows (removal of higher flows) resulted in the marginal zone being vegetated with reeds and hygrophilous shrubs, reducing mudflats and alluvial sandbars. Thus less waders (sandpipers, plovers) and open habitat animals (plovers, geese) present. Also species that use sandbars and sandbanks lose digging substrate (monitors, bee-eaters, martins) (ORASECOM, 2010b:68). Clearing the site for construction, will remove the riparian vegetation which provide refuge, shelter, breeding and feeding habitats, and migration routes for riparian species. The Recommended Ecological Category (REC) for the reach including Augrabies and Richie Falls, is a category B (ORASECOM, 2010b:73). The REC refers to the management objective of the river reach, i.e. the river should be managed to achieve an improved PES status of category B. The river mouth ecological requirements currently released from Vanderkloof Dam amounts to 289 million m3/a, and is based on fairly old methodology. Recent estimation of the ecological requirement indicated an average requirement in the order of 1 062million m3/a (ORASECOM, 2007b:57). While the proposed plants are run of river, and the volume of water in the greater flow of the river will not be reduced by the hydro-power plants, the volume of water through the falls at the selected sites will be reduced, especially in low flow and average conditions. In terms of the combined operating flows of the Richie Falls plant (Oranje Falls Farm) and the environmental flow requirements for the REC category B (ORASECOM, 2010b:91, table 9.8), the combined flow requirements exceed the monthly average flow. Further, the design flow alone exceeds the monthly average flow for 8 months of the year. As the Augrabies plant is a higher design capacity, it is assumed the flows will exceed the monthly average to a greater extent

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No. Issue Raised by Response from CES EIA team or Hydro SA and further reduce the ability to implement the environmental flow requirements at the Falls. 34. REFERENCES Craig Eksteen, Comment 34 is a repeat of Comment 15 above. Lower Orange River Management Plan (LORMP)(2008). Kalahari Outventures, The response is the same. Unlocking the Ecotourism potential of the river. Compiled by comment by e-mail 05 Ecotoursim Afrika, for //Ai/Ais-Richtersveld Transfrontier park, May 2015. funded by South African Department of Water and Forestry. ORASECOM (2007). Environmental Considerations Pertaining to the Orange River. Report 005/2007. Prepared by WRP (Pty) Ltd., Jeffares Green Parkman Consultants (Pty) Ltd, Sechaba Consultants, Water Surveys Botswana and Windhoek Consulting Engineers. Funded by GTZ. ORASECOM (2007b). Summary of water requirements from the orange River Basin. Report 006/2007. Prepared by WRP (Pty) Ltd., Jeffares Green Parkman Consultants (Pty) Ltd, Sechaba Consultants, Water Surveys Botswana and Windhoek Consulting Engineers. Funded by GTZ. ORASECOM (2010). Support to Phase 2 of the ORASECOM Basin-wide Integrated Water Resources Management Plan: Desktop EcoClassifcation assessment. Prepared by WRP. ORASECOM Report: 016/2011. ORASECOM (2010b). Support to Phase 2 of the ORASECOM Basin-wide Integrated Water Resources Management Plan: Environmental Flow Requirements Volume 1 (Main Report). Prepared by WRP, funded by GIZ. ORASECOM Report: 016/2011. Water Research Commission (WRC)( 2007). Guidelines for integrated control of pest blackflies along the orange river. Compiled by Palmer, R.W., Rivers-Moore, N., Mullins, W., McPherson, V., and Hattingh, L. WRC Report No. 1558/1/07 Department of Environmental Affairs Pretoria – Danie Smit 35. From: "Danie Smit" Danie Smit Dear Mr. Danie Smit, Subject: RE: Proposed HydroSA Riemvasmaak Hydro Project Control Environmental Thank you for your note on receipt of the Draft EIR. / Voorgestelde HydroSA Riemvasmaak Hidro Project Officer Grade B Sincerely, Date: 28 April 2015 2:51:25 PM SAST (Deputy Director) Shawn Johnston To: "Howard Hendricks" , Integrated ShawnJohnston Environmental EAP’s response: Cc: "[email protected]" , Authorisations We note that the message was sent / copied to staff members of "FransVan Rooyen" , "Hugo (Protected Areas) SANParks and DWA, and copied to Shawn Johnston, PPP Bezuidenhout" , "Lucius Department of Coordinator.

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No. Issue Raised by Response from CES EIA team or Hydro SA Moolman" , "Nomvuselelo C. Environmental Affairs, We note that Mr Smit did not request copies of comments from Songelwa" , comment by e-mail, 28 other commenting parties. "Paul Daphne" April 2015.

Dear All, Thanks for the info forwarded to DEA. I have just today received the Draft EIR that is in the public at the moment. Please be so kind as to forward your comments on the documents to me also so that I can have a record of your comments and concerns. Kind Regards, Danie Smit Control Environmental Officer Grade B (Deputy Director) Integrated Environmental Authorisations (Protected Areas) Department of Environmental Affairs 36. Dear Danie, Bill Rowlston – EOH EAP’s response: We refer to your letter dated 30th October 2013 in which you CES & Comment noted. accepted the Scoping Report for the above project. In that Shawn Johnston – letter, under the heading Public Participation you required us Sustainable Futures, to include in the Draft EIA Report a copy of the minutes of a 05 May 2015. meeting held on 28th August 2013 between Hydro SA, Aurecon and staff of your department. Initially we believed that you had misquoted the date of this meeting, because on that date our principals at Hydro SA, Mr Theron and Ms Grimbeek, were in Namibia, but it has recently been brought to our attention that the meeting was in fact held on that date, but the attached e-mail trail indicates that the then Case Officer, Ms Poll-Jonker, was responsible for preparing the minutes of the meeting and distributing them to the participants. Neither Mr Theron nor Ms Grimbeek has any record of receiving the minutes, and as a consequence the Draft EIA Report we have recently submitted to you does not include a copy of the minutes. We will be pleased if you will follow the matter up with Ms Poll- Jonker, and provide us with a copy of the minutes. Alternatively, if it turns out that no minutes were prepared, we will be pleased if you will let us know. We look forward to hearing from you in the near future. Sincerely,

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No. Issue Raised by Response from CES EIA team or Hydro SA Bill Rowlston – EOH CES Shawn Johnston – Sustainable Futures 37. Dear Danie, Bill Rowlston – EOH Response from Mr Smit Please refer to Shawn Johnston’s e-mail– below – dated 5th CES, comment by e- Dear Bill, May 2015 on the above subject. We have not yet received a mail, 04 June 2015. Apologies for the delay but it took me some time to look for old reply to the message. documents. We are being pressed by one of the registered I&APs to Unfortunately I could only retrieve an agenda and an attendance provide him with a copy of the Minutes of the meeting, and we register. will be very pleased if you will, as a matter of urgency, either: My opinion is that we never received minutes on this meeting. I (i) Provide us with a copy of the Minutes that were prepared by see from the attendance list that the previous consultant were Ms Poll-Jonker; or also present at the said meeting. It would have been their task to (ii) Confirm, in writing, that no Minutes were written for the provide minutes. meeting. From the attendance list it is clear that whatever the discussions I need to hear from you in the very near future please. were, it would be in line with the comments received from the Sincerely, relevant parties on the list to date. I was at that meeting and can Bill Rowlston confirm that the viewpoints were similar to all later meetings later. I have no other documents related to this date. Regards, Danie

38. Dear Danie, Bill Rowlston – EOH EAP’s response: The e-mail trail – attached – clearly shows that the CES, comment by e- We have not received a response to this message, and responsibility for writing kites / minutes for the meeting lay mail, 05 June 2015. accordingly we are not able to provide a copy of the Minutes, as with, and was accepted by, Ms Poll-Jonker of your staff. requested by DEA. Accordingly we are not able to include a copy of these Minutes in the Final EIAR, as instructed in your letter 30th October This is noted in the Foreword of the EIA Report. 2013, in which the department accepted the Scoping Report for the above project, nor are we able to provide a copy of the Minutes to the I&AP who has requested the Minutes. Will you let me have your observations please, as a matter of urgency? Sincerely, Bill Department of Environment and Nature Conservation Northern Cape – Ordian Riba and L. Tools-Bernado 39. Dear Sir/Madam, Ordian Riba, Northern Dear Odain Riba, Please find attached comments from the Department of Cape Department of Thank you for the comments received from the Department of Environment and Nature Conservation: Impact Management Environment and Environment and Nature Conservation Northern Cape on the regarding the proposed project with the ref: Nature Conservation, proposed Riemvasmaak Run-of-River Hydro draft environmental NC/NAT/ZFM/KAI!/RIE1/2015. 26 May 2015. impact assessment study.

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No. Issue Raised by Response from CES EIA team or Hydro SA Kind Regards, Sincerely, Ordain Riba Shawn Johnston 40. The Department confirms having received the EIA Report for L. Tools-Bernado, EAP’s response: environmental authorisation of the above mentioned project on Northern Cape Comment noted. 06th May 2015. As required in term of the Environmental Department of Impact Assessment Regulations, 2010. Environment and Nature Conservation, The application has been assigned the reference number. 26 May 2015. Kindly quote this reference NC/NAT/ZFM/KAI!/RIE1/2015 number in any future correspondence in respect of the application. Please note the responsible officer is going to be Mr. O. Riba and can be contacted at (053) 807 7468. Department of Rural Development and Land Reform – Khathu Muruba 41. Dear Shawn Johnston, Khathu Muruba, EAP’s response: ENVIRONMENTAL IMPACT ASSESSMENT PROCESS FOR Pr. Planner (SA) Comment noted. THE PROPOSED HYDRO SA RUN-OF-RIVER HYDRO A/2059/2015 The department will be kept updated on progress with the project. POWER PROJECT, RIEMVASMAAK, NORTHERN CAPE: Professional Town and DEA REF NO: 14/12/16/3/3/2/600 Regional Planner I hereby acknowledge receipt of your letter(s). Spatial Planning & Land Use Management The Department of Rural Development and Land Reform Branch (DRDLR) would like to convey its gratitude for being notified NATIONAL about the availability of the Environmental Impact Assessment DEPARTMENT OF Report for the proposed Hydro SA Run-of-River Hydro Power RURAL Project. The Department has perused the documentation(s) DEVELOPMENT & sent. LAND REFORM, Based on the above, thus far the Department does not have comment by e-mail, 23 any objections to the proposed. However, the Department June 2015. would like to be notified of anything related to the project in future. Yours sincerely, Khathu 42. Dear Shawn Johnston, Khathu Muruba, Dear Khathu, PROPOSED RIEMVASMAAK RUN-OF-RIVER HYDRO Pr. Planner (SA) Thank you for your e-mail and comments on the DEIR for the POWER STATION A/2059/2015 proposed RVM Hydro Project. I hereby acknowledge receipt of your correspondence. Professional Town and Sincerely, The Department of Rural Development and Land Reform Regional Planner Shawn Johnston (DRDLR) would like to convey its gratitude for being notified Spatial Planning & about the proposed Run-of-River Hydro Power Station. Land Use Management The department will be kept updated on progress with the project. The Department does not have any objections to the project at Branch

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No. Issue Raised by Response from CES EIA team or Hydro SA this stage. However, the Department would like to be notified NATIONAL of anything related to the project in future. DEPARTMENT OF Yours sincerely, RURAL Khathu DEVELOPMENT & Pr. Planner (SA) A/2059/2015 LAND REFORM, Professional Town and Regional Planner comment by e-mail, 17 Spatial Planning & Land Use Management Branch July 2015. NATIONAL DEPARTMENT OF RURAL DEVELOPMENT & LAND REFORM Dr. Rian Wolhuter - Interested and Affected Party 43. HydroSA Riemvasmaak / Augrabies Falls National Park Hydro Dr Riaan Wolhuter EAP’s response: Project Environmental Impact Assessment Process Senior Researcher, Available head and flow requirements: Detailed calculations Comments Stellenbosch undertaken by the applicant show that the net head (that is, after With reference to the proposed Augrabies Hydropower University, comment by deducting head losses through delivery conduits), is 123.6m, and scheme, I would like to comment as follows: e-mail, 01 June 2015. that a flow rate of a little less than 38m3/sec is sufficient to According to published information and the project website generate 40MW of power at an 88% efficiency (that is, allowing itself, the scheme is planned to generate up to 40 MW. The for turbine, generator, transformer and transmission losses). project's proposed location and associated topography shows Availability of water: The availability of water was derived from that the hydrostatic pressure height for the scheme cannot be analysis of 20 years of recorded data (daily average flow between more than 120m and will probably be closer to 100m in 1994 and 2014) from DWS’s hydrological gauging weir at practice. Neusberg Weir (D7H014), some 47km upstream from the Simple power calculations and assuming an 85% utilization proposed diversion weir. On DWS’s advice a constant 3m3/sec rate, show that a volume flow of just under 50 cumec (m3/s) was deducted from the flow rates recorded at the gauging station will be required. During a visit to the Park in April 2013, the to allow for abstraction for irrigation between Neusberg and the flow was 35 cumec, only 70% of the required value. The fall diversion weir site. was still nice, but not spectacular. During my last recent visit in Energy calculations: The energy model used in the analysis April it was even below this at 27 cumec, according to considers that the project does not operate until river flow is equal information provided by the Department of Water Affairs. to 30m3/sec, and is shut down when flows exceed 800m³/s, when Perusing flow figures over the last 10 years for that part of the high sediment loads are anticipated. Orange, as available from Department of Water Affairs, is Diversion of water: More detail on the diversion schedule and its instructive. The period includes about 6 times of flood during impacts on the flow regime at the Augrabies falls are provided in which the flow factor increases by 10-•‐20 times momentarily. the response to Comment 8. If we want to preserve something of the visual attraction of the Generating capacity: Comparisons between the generating falls and generate 40 MW, then app. 30 + 50 = 80 cumec is capacity at this project and in Mpumalanga are meaningless. The required, which has only been achieved 50% of the total time. transmission practitioner on the project design team remarks as If the 6 short peak periods are omitted, this required flow follows: incidence reduces to 18% over the period. It should also be “A 40 MW hydro plant connecting at Blouputs will have a positive noted that hydro power generation through turbines would not impact on the stability of the South African Electricity Grid. While be an option during flood periods, due to the silt content of the the small relative size of the units will have negligible impact on river at those times. A very typical annual average flow for that the overall system frequency stability, the units will provide

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No. Issue Raised by Response from CES EIA team or Hydro SA river section in non-•‐flood years, lies between 35 and 60 significant local voltage support. This voltage support is cumec. In e.g. 2012, the overall annual average was only 57 mandated in the RPP Grid code for this sort of generating unit. cumec. Sobering, in view of the 50 cumec required. The voltage support improves the efficiency of the local In the Mail & Guardian of 13th March 2013, Mr. Theron of transmission and distribution network, makes solar PV less prone Hydro SA is quoted as follows: to interruption due to voltage dips and enhances fault detection "... The Amount of water [Extracted] is very little in terms of the and clearing through higher local fault levels. All these effects flow regime" This statement clearly does not correspond with provide a more secure, reliable and higher quality electricity the facts and is grossly misleading. supply for customers in the region. The presence of synchronous Moreover, according to Die Burger of 10th April 2013, Hydro generation in a region can also facilitate faster system restart SA stated that a minimum flow of 30-•‐35 cumec will be after blackouts and assist the supply authorities in system outage maintained for the falls. Further, again according that report: management.” "We will not take away the waterfall ....". The above paragraph has been added to section 4.2.6 of the EIA This is completely erroneous. The facts are clear. It is Report impossible to avoid serious or fatal damage to the falls during the vast majority of the time for the declared energy generation capacity, or even a significant part of it. ANY diversion of the flow, especially in the drier months, will have a disastrous impact on the visitor experience and thus on the Park. The seasonal variation in the appearance of the fall and side falls is also part of the Park's attraction. There are other misrepresentations regarding the project. The information website of the project engineers (who have apparently withdrawn in the interim) contains the following statement: “Furthermore, the station will aid in balancing South Africa’s energy grid as most of the country’s current electricity generation is located in the Northern provinces such as Gauteng, Mpumalanga, etc.” According to Eskom, the installed capacity in Mpumalanga alone, is about 30 GW. In relation to that capacity, the 40 MW of the proposed Augrabies scheme represents 0.13%. To suggest that this will assist to stabilize the national grid, is ludicrous. The 2.5 m dia. pipeline to the generating station will run through part of the park. Pipelines necessarily follow a geometric / hydrological design and large ones particularly cannot be laid to follow existing jeep tracks, as proposed. The nature of the pipeline and other construction work will require extensive earthworks and apart from the disturbance of wildlife and vegetation during construction, permanent damage will be

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No. Issue Raised by Response from CES EIA team or Hydro SA inevitable. The pipeline must be serviceable and will require infrastructure like a good access road with sufficient load bearing capacity. There is also the issue of excavated material and other construction artefacts. What happens to that in a National Park? Renewable energy generation is often, like in this instance, presented as being clean and environmentally friendly. It is not always the case at all. One of the many unfortunate examples is the Ruacana Falls project in Namibia, where the spectacular falls are destroyed, except during random flooding. It's a fact that that the overall average generation from the scheme is far below the maximum capacity. A visit to the area reveals a disturbing and visible ecological disaster. Apart from the rock wall without water, construction damage is seen everywhere. One can only wonder what the long‐term eco‐tourism asset for Namibia would have been if nature has been left alone. According to witnesses the falls were once spectacular. There is much evidence that in general the long-term job creation and income potential from sustainable eco-•‐tourism could very often be much higher than high impact short-•‐term development. The Victoria Falls tourism complex and huge sustainable revenue source, come to mind immediately. Interestingly, after many objections on environmental, social and economic grounds, similar to the those voiced here, the possible Epupa hydro scheme further downstream in the Kunene River in Namibia has not been approved. The usual motivations, such as community involvement and job creation, are valid and certainly sound good to political decision‐makers who must approve the project. If this, as well as the government's energy buy-•‐back program (REIPPP) is the purpose, there are a number of other renewable generation alternatives without any impact on a National Park, that could be pursued. There are large current Northern Cape developments of that type, particularly solar based, which certainly appear attractive to other developers. The Park as a whole is a very unique and beautiful area with the fall as one of his best assets. The actual generation capacity of the proposed scheme is highly volatile and insignificant in the larger South African context. This is convincingly evident from the flow statistics of the Orange.

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No. Issue Raised by Response from CES EIA team or Hydro SA Faced with these facts, it is very easy to be highly sceptical about the bona fides of those who are driving this project. What on earth is the real motivation to target our biggest waterfall and surrounding National Park for such a misguided development with such minimal return? We will solve absolutely no problem with this proposed scheme and only cause serious damage to one of South Africa's increasingly popular and unique natural areas. The claim that the falls and Park will not be affected, is misleading and blatantly untrue. Are we really prepared to go ahead with such foolishness? We owe it to future generations due to it not to do so. Dr Riaan Wolhuter Dr. Gerhard Smit - Interested and Affected Party 44. Augrabies Hydro – Electric Power Station. Dr Gerhard Smit, EAP’s response: Thanks for your invite to write a column. Interested and Affected Points 1-7:: No response is necessary. 1. I live in Vereeniging and am one of many citizens Party, comment by e- Points 8-12: The Orange River is a highly altered and highly concerned about the misuse and exploitation of our habitat mail to Shawn manipulated system, in which the flow regime is not rain fed, but and National and natural resources. Johnston and Daniella depends almost entirely on the operation of the major 2. Much is being made of job creation and the need for Di Gaspero, Journalist impoundments upstream of the Augrabies Falls, particularly the electricity in our country, I realise this however not at the Intern at Daily Gariep and Van Der Kloof dams. Only the very largest floods, the cost of destruction while other alternatives are readily Southern African 2010 and 2011 events being the most recent, are not significantly available. Tourism Update, 17 attenuated by these reservoirs. The extent to which the flow 3. My wife and I have been visiting our National Parks July 2015. regime at the falls is set out in the response to Comment 8 regularly since 1967, Augrabies is one of our wonders above. Monitoring adherence to this flow regime will be a matter which has been carefully conserved and preserved by our between the operator, DEA and SANParks in terms of Conditions National Parks authorities for many decades. attached to the EMPr, as well as conditions imposed by DoE. 4. Now a Hydro- Electric power generating facility is planned Points 13-15: Comments about the benefits of solar and wind for construction in the Orange (Gariep) River a few energy are noted, but such projects are not the subject of this kilometres upstream from the Augrabies National Park. assessment. Run-of-river hydroelectric power has the benefit 5. Few sights are as awesome or a sound as deafening as over solar and wind that continuous baseload power can be water thundering down the 56m Augrabies Waterfall when generated as long as water is available to turn the turbines. the Orange River is in full flood. Point 16: The project will not mean the end of the AFNP. 6. The Khoi people called it ‘Aukoerebis’, or place of Great Noise, as this powerful flow of water is unleashed from rocky surroundings characterised by the 18km abyss of the Orange River Gorge. 7. Picturesque names such as Moon Rock, Ararat and Echo Corner are descriptive of this rocky region. Klipspringer and kokerboom (quiver trees) stand in stark silhouette against the African sky, silent sentinels in a strangely

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No. Issue Raised by Response from CES EIA team or Hydro SA unique environment where only those that are able to adapt ultimately survive. The 55 383 hectares on both the northern and southern sides of the Orange River provide sanctuary to a diversity of species, from the very smallest succulents, birds and reptiles to Hartmann's mountain zebra, springbok, gemsbok and giraffe. 8. The >60 000 visitors to Augrabies (12.2% of visitors to our National Parks) per annum do not visit the park because it is there, they visit to experience and enjoy this wonders of a waterfall in an arid area. Augrabies is the sixth most visited National Park in the RSA. 9. The Orange River does not have a consistent high volume flow of water, it is dependent on rainfall upstream. 10. In high rainfall seasons the falls are spectacular, during poorer periods flow is often reduced to not much more of a trickle over the falls. 11. Much is said in the EA documentation about the flow not being less than the required minimum for the flow through the Augrabies National Park. We all are well aware that our environment does not mean much when money is at stake. 12. Wonderful EMP’s can be drawn up, but when the river flow diminishes sufficient mitigation will be improvised to use whatever is left in the river to keep the power station operational, why: because the people have gotten used to the electricity and now it cannot be cut. We are experiencing power outages now especially in winter also the drier months, the Northern Cape and the Orange River will not be spared. 13. There are much less harmful alternatives available, the Northern Cape is well known for having the most cloudless days with good sunshine per annum, and therefor solar energy could offer a guaranteed supply of non-destructive green energy for the inhabitants of the surrounding areas. 14. Wind energy is another source of non-destructive energy. 15. Both 14 and 15 above will also offer the mentioned job opportunities. 16. A Hydro Electric power station above the Augrabies National Park in the Orange River, will spell the end to one of our esteemed National Parks and also to the

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No. Issue Raised by Response from CES EIA team or Hydro SA surrounding tourist industry. 17. Persons who also care for the environment and especially the arid Northern Cape are requested to register as Interested and Affected Parties (I&AP’s) with Shawn Johnston at email address: [email protected] and lodge their objections which will form part of the public participation process. Unfortunately time is running out. 18. Our Department of Environmental Affairs and our Government will now have the grand opportunity to prove to the RSA citizens and the world that they really care by not approving this project. Yours sincerely and with kind regards Gerhard Smit. Dr. Howard Hendricks and Dr. Hugo Bezuidenhout - South African National Parks Pretoria and Kimberley 45. Dear Mr Johnson, Dr. Howard Hendricks, Dear Dr. Howard Hendricks, -In respect of South African National Parks official position as South African National Thank you for the comments submitted by yourself on behalf of communicated to the previous environmental consultants; Parks Pretoria, the South African National Park (SANPArks). I hereby SANParks supports renewable energy generation traditionally comment by e-mail, 28 acknowledge receiving your comments and look forward to the provided by technologies such as hydro, wind, solar and April 2015. comments of on the Draft Environmental Impact Assessment biogas; Report (DEIR). Copies of the DEIR has been submitted to: Insofar this project, SANParks does not support the  Frans van Rooyen at Augrabies Falls National Park ( hard construction of the weir, canal and a portion of the power line copies and CDs); within the Augrabies Falls NP;  Lucius Moolman - Regional Manager Arid Park; and, In its effort of participation during the public meetings as well  Your office in Pretoria. as direct correspondence, SANParks have communicated the I have also sent the DEIR to Willem Louw at Park Planning and following concerns to the previous environmental consultants; Development Conservation services. Sincerely, a) Elements of the proposal will have a visual impact on the Shawn Johnston park, specifically the weir and power lines as well as the powerhouses of options A and C which would have to be EAP’s response: mitigated if such proposal will continue;  Dr Hendricks’ lack of support for the project is noted. b) All options fall within the park’s buffer zone, being both in  It is noted that the comments relate to the Basic Assessment the priority natural areas buffer as well as the viewshed Reports, which addressed two 10Mw stations served by a protection areas in accordance to the National Strategy on common headrace, and subsequently the Draft Scoping report Buffer Zones around National Parks; for the EIA for the single 40MW project. 1.4 Comments on the BARs To this effect, SANParks seeks an alignment between the  We are aware of the existence of the National Strategy on proposed hydropower station development and the National Buffer Zones around National Parks and the requirements of Environmental Management: Protected Areas Act, 2003 (Act the NEM: PAA. We are also aware that South Africa is No. 57 of 2003), (NEM:PAA) being the primary Act for experiencing ongoing difficulties in providing sufficient managing protected areas in the country for the following

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No. Issue Raised by Response from CES EIA team or Hydro SA reasons; electrical power to support growth and development for all of The proposal to divert a sizable portion of the river’s flow from its people. We are of the opinion that the project can be the falls would have a negative impact on the visitor constructed and operated for the benefit of the nation, without experience to the falls. A statement in the proposal that significantly disrupting the integrity of the ecological systems of extraction may be limited to the night during periods of low the national park. flow is unrealistic as the falls are lighted at night so that visitors  The extent to which the flow regime at the Augrabies Falls is can experience them outside daylight hours; set out in the response to Comment 8 above. We are of the We anticipate that the planned volume of water to be diverted opinion that the diversion of a maximum flow rate of 38 m3/sec would also have a negative impact outside low flow periods as to the HPP will not significantly affect the visitors’ enjoyment of SANParks requires the minimum reserve flow to maintain the spectacle of water flowing over the falls. The project will ecosystem integrity especially since the choice of the never cause the falls to run dry. Only improper management of availability of electricity to consumers is likely to supersedes the large dams upstream of the falls and abstractions for off- the volume of water flowing towards the falls because the channel use can prejudice the falls to that extent. There is no provision of electricity will be regarded as a priority;SANParks proposal in the Draft EIA Report, which has been provided to requires the justification of the figure mentioned of 30 kumec; Dr Hendricks for comment, to divert water during the night and While not explicitly forbidden in the National Environmental during low flow periods. Management: Protected Areas Act (Act 57 of 2003), the  A new section – 3.3.2 Previous environmental water provision of land for infrastructure linked to the commercial requirements recommendations – has been added to Chapter generation of power is not listed as one of the functions of 3 of the EIA Report, in which the issue of environmental flow SANParks and it is therefore questioned if SANParks is in a regimes in the river is explored. position to lease or otherwise provide rights for power  We are aware of the provisions in the NEM: PAA relating to generation infrastructure such as those contained in the commercial activities in national parks, and also that the list of proposal; activities in the Regulations to the Act does not include the The area of the park through which the pipe or canal is commercial generation of electrical power. planned is currently zoned remote and falls in the special  We are aware of the nature of the land across which the management area category. The remote zone according to the headrace is proposed to run. We have been informed of its zonation plan of the Augrabies Falls NPark is the zone past uses as the home of the RVM community, and as a providing the highest form of protection. This is an area practice range for the military. As far as present uses are retaining an intrinsically wild appearance and character, or concerned we believe that access by the public is not allowed, capable of being restored to such and which is undeveloped. and as far as we know only park staff may gain access to this There are no permanent improvements or any form of human portion of land. We are aware of the need for a revision of the habitation. It provides outstanding opportunities for solitude park‘s Management Plan if such a development were to be with awe inspiring natural characteristics. If present at all, sight approved. and sound of human habitation and activities are barely  Only a small section of the riparian vegetation will need to be discernable and at a far distance. The zone also serves to removed to accommodate the offtake structure, and the protect sensitive environments from development impacts and botanical specialist assessed this impact as being of low tourism pressure. The conservation objective is to maintain the significance. zone in as near to a natural state as possible with no impact  The construction of the headrace will be done in sections, so on biodiversity pattern or processes. Existing impacts on that as much access across the route as possible is biodiversity either from historical usage or originating from maintained during excavation. Backfilling and surface

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No. Issue Raised by Response from CES EIA team or Hydro SA outside the zone should be minimized. It must be noted that rehabilitation will be done as soon as possible after amendments to the management plan and zoning have to be construction of the headrace, including reinstating episodic approved by the Minister of the Department of Environment watercourses crossing the route. On completion there will be Affairs for which the Minister may recommend a public no hindrance to crossing the route. participation process; Comments on the DSR The already diminishing riparian vegetation along the river due  We are of the opinion that SANParks mandate in the AFNP in to increased farming practices (removal of vegetation right up terms of relevant legislation can continue to be successfully to the edge of the river), is a major concern. The water level implemented, mutatis mutandis, if the project is allowed to be upstream of the weir will cause vegetation to be exposed to constructed and operated.. more water and downstream to less water (the distance  The change of project from two BAs to one Scoping+EIA was between where water is extracted up to being released back permitted and facilitated by DEA, to whom any queries about into the river) which inevitably will be detrimental to the riparian procedural irregularities should be addressed. vegetation;  The only evidence provided to us by SANParks for the Animals are dependent on water from the river and nearby existence of a contractual agreement between SANParks and affected drainage lines with low water flow will present a the RVM community over the management of the RVM land is difficulty for animals with access to water, particularly along a document entitled Konsep vir Bespreeking deur the stretch of land where game readily make use of feeding Onderhandelsing Komittee, being the minutes of a meeting routes; held on 7th Match 1998. This is to all intents and purposes an Subsequently, SANParks made the following comments on the agreement to establish an agreement, but we have no Draft Scoping Report for the Proposed Hydropower Station; indication from SANParks or the community that such an Discrepancies between the proposed development and agreement has ever been concluded. Despite a request to SANParks mandate must be regarded within all the applicable SANParks to provide us with a copy of the Cabinet decision environmental legislation both nationally and internationally, mentioned by the commentator nothing has been forthcoming. not just NEM:BA as the draft scoping report alludes; A Legal Review addressing land ownership and management There seems to be no procedural explanation for the valid issues has been commissioned by the applicant, and this will application upgrade from approximately two 10 x 10 MW be available in the Final EIA Report. substations to one 40 MW substation, including the regulatory  The disagreement between DEA and the previous EAP framework that provided for three applications which were regarding the relevance of Listed Activity 10 in GN R.545 lodged by RVM1Hydro Electric (Pty) Ltd, RVM 2 Hydro Electric (transfer of water) is irrelevant, since at least one other Listed (Pty) Ltd and RVM 3 Hydro Electric (Pty) Ltd, respectively in Activity required Scoping+EIA, and the impacts of the transfer comparision with Department of Energy lifting the cap of ≤10 infrastructure have in any case been assessed as a matter of MW; course. Whilst providing the fundamental arguments for  The impacts of diverting a portion of the flow of the river to the “Riemvasmaak land, owned by the Riemvasmaak Community HPP, and the way in which the diversion will be implemented, Trust, located within the borders of the Augrabies Falls are discussed at some length in the EIA Report. The main National Park” followed their forced removal in 1973/1974 features of the diversion are that no diversion will take place at during Apartheid, the report uses such notion of land flow rates in the river less than or equal to 30 m3/sec, and that ownership interchangeable to avoid referencing the cabinet about 10% of the total average annual flow will be diverted. decision of parliament that such land must be used for the We do not understand the difference between the visual purpose of conservation, hence the current contractual impact and the tourism experience. The question of increasing

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No. Issue Raised by Response from CES EIA team or Hydro SA agreement between SANParks and the Riemvasmaak Trust the overall flow regime at the falls for a “heightened tourism including the acceptance of an annual ex gratia payment – this experience” is for DWS to address, as that department highlights the need for clarity on land ownership and the manages releases from impoundments and abstractions from appropriate landuse thereof; the river upstream of the falls. While not explicitly forbidden in the NEM:PAA, the provision of  We are aware that the parks’ Management Plan will need to land for infrastructure linked to the commercial generation of be amended to accommodate the project, and that the power is not listed as one of the functions of SANParks and it Minister’s approval will be required for such amendments. is therefore questioned if SANParks is in a position to lease or  We are aware of the intentions of the National Strategy on otherwise provide rights for power generation infrastructure Buffer Zones around National Parks. However, we are of the such as those contained in the proposed development; opinion that the issue of ensuring that South Africa has The difference of opinion between DEA and the Aurecon sufficient energy resources to provide an acceptable standard regarding Listing Notice 2 (GN No. R545) of the NEMA EIA of living for all of her people is of such critical importance, Regulations must be resolved with immediate effect, rather particularly by means of a project that we believe will have than just prior to the submission of the final EIA Report limited impacts on the nature of this area of the park, that it Regulations must be resolved with immediate effect, rather can be accommodated within the spirit of the policy. than just prior to the submission of the final EIA Report for  The criteria used for selecting this site for the development of decision-•‐making; a hydroelectric project, and the alternative sites are set out in SANParks concern about diverting a sizable portion of the Chapter 5 of the EIA Report. It is pointed out that there are river’s flow from the falls that would have a negative impact on very few sites suitable for the provision of hydroelectricity that the visitor experience to the falls, is ignored – instead, the do not require the construction of large impounding reservoirs. report confuses this concern with the visual impact group A run-of-river project has already been developed and is rather than a tourism experience which highlight the operating at Neusberg, and a project has been developed for shortcoming of the draft scoping report in defining a tourism Boegoeberg, both of which depend on large existing experience as merely a visual impact; constructed barriers across the river to generate the driving The developer is silent on the planned volume of water to be head. diverted during the low flow period; the minimum reserve flow  The status of the national park is not “downplayed “ in the EIA is required to maintain ecosystem integrity whilst an additional Report, but it is suggested that the hydroelectric scheme and amount of volume of water will be required to provide a the national park can coexist satisfactorily with minimal heightened tourism experience at the falls; disruption to the park, including minimal impacts on the The revision of an approved Park Management Plan is the conservation of species and significant benefits to the local prerogative of the Minister in accordance to NEM:PAA Section population and the nation as a whole. 40 (2), whereas the change of a particular zone within a  Note that a specialist study was undertaken on the potential National Park is subject to Section 41 (g) of the same Act impacts of the project on tourism in the area as part of the EIA compelling SANParks to change such zones with phase of the assessment. predetermined conservation objectives and activities for all the national parks in the country to allow for the proposed project – the conservation objective is to maintain remote and primitive zones in as near to a natural state as possible with no impact on biodiversity pattern or processes, essentially these areas retaining an intrinsically wild appearance and character,

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No. Issue Raised by Response from CES EIA team or Hydro SA or capable of being restored to such and which is undeveloped, there are no permanent improvements or any form of human habitation, and provides outstanding opportunities for solitude with awe inspiring natural characteristics; SANParks notes that the proposed development is not in accordance with the spirit of the National Strategy on Buffer Zones around National Parks; The developer uses location alternatives interchangeable between alternatives sites along the Orange River versus alternative sites in the country which limits a proper understanding of what feasibility studies were done towards alternatives sites for the waterfall, no indication is given as to where the 12 sites along the Orange River were located (Ps. both Neusberg and Boegoeberg are ideal alternative sites to the Augrabies Falls National Park site which together is likely to deliver at least 30% of the 75MW allocation for small hydro stations); It is a grave concern that the developer down plays the status of a National Park with the high positive social impact that the project will have (especially for the landowners, i.e. Riemvasmaak Community), as well as the contribution it will make to the energy grid in South Africa as the best practicable environmental option for the proposed site of development thereby disregarding regrettably the importance of a National Park and the legal status thereof; From a species management point of view, the developer’s proposal falls short on the importance the park provides towards the conservation of many species to this environment, including large breeding colony of birds nesting in trees along the river and on a small islands whilst the disturbance of normal riverine habitat and the interference with the flow and stratum of the river bed and bank are likely to permanently flood many large rocks in the vicinity of the weir thereby disturbing a watercourse that would otherwise have been used as perching sites for birds such as cormorants which constitutes a prohibition in NEM:PAA Regulations; SANParks submits grave concern about the fact that the developer incorporates the impact on tourism synonymous with the visual impact of the proposed development and

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No. Issue Raised by Response from CES EIA team or Hydro SA loosely as part of the impact on the socio-•‐economic environment – the impact on tourism has merit to be investigated on its own, hence a separate and additional specialist study will be required. Regards, Howard 46. Dear Mr Johnston, Dr. Howard Hendricks, Dear Howard & Hugo, Herewith, please find SANParks comments to the Draft South African National Thank you for the SANParks review of the proposed Environmental Impact Assessment Report for consideration. Parks Pretoria, Riemvasmaak Run-of-River Hydro Draft Environmental Impact These comments should also be read together with: comment by e-mail, 31 Assessment Report. Bezuidenhout, H. September 2013. May 2015. I hereby acknowledge receiving the SANPArks submission Field visit and meeting with DEA officials and other interested prepared by Dr Hugo Bezuidenhout dated 31 May 2015. and affected parties – on the proposed hydropower station in Sincerely, Augrabies Falls National Park. Internal SANParks report, Shawn Johnston Scientific Services, Kimberley. Bezuidenhout, H. October 2014. Proposed Riemvasmaak Dear Mr Johnston – these reports are internal SANParks Hydro electric power stakeholder site visit. Internal SANParks documents and not to be confused with the official submission report, Scientific Services, Kimberley. which Dr Howard Hendricks submit on Sunday 30/05/2015. I and Regards, Howard other SANParks colleagues have given our comments to Dr Hendricks and he then gave you our official submission. Best wishes, Regards, Hugo Fred de Groot – Africa Wild 47. Dear Mr. Johnston, Fred de Groot, Africa Dear Mr. Fred de Groot, Having read the article, regarding the hydro electrical power Wild, comment by e- Thank you for your e-mail and request. You have been registered station, mail, 24 August 2015. as an interested and affected party. We will keep you Planned to be constructed near Augrabies national park, posted on the environmental impact assessment process. please can I Sincerely, be listed as a IAP in this matter. Shawn Johnston Myself being a member /representative of a wild life forum, Africa Wild, Matters such as these developments are always of concern to us and We would like to be kept updated as developments proceed. Thanking you in advance,.. Fred de Groot Africa Wild International Rafting Federation – Sue Liell-Cock 48. Dear Shawn, Sue Liell-Cock (Ms) Dear Sue, Please register me on the Project database for the International Rafting Thank you for your e-mail. I herby confirm that the International International Rafting Federation. Federation - Secretary Rafting Federation has been registered and an interested and

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No. Issue Raised by Response from CES EIA team or Hydro SA Thanks Sue General, comment by affected party on the proposed HydroSa Riemvasmaak Run-of- e-mail, 23 April 2015. River Hydro Project environmental impact assessment process. Sincerely, Shawn Johnston Jean Senogles – Interested and Affected Party 49. Sir, Jean Senogles, Dear Jean Senogles, Please register me as an Interested and Affected Party. I too Interested and Affected Thank you for your e-mail. I hereby confirm receiving your have taken tourist to the Falls during trickle time and while in Party, comment by e- comments on the proposed Riemvasmaak Hydro Project. full flood. They are truly inspiring. (See attachment) mail, 22 July 2015. Sincerely, I am so against this outrage on the landscape of this wonderful Shawn Johnston arid place. It will spoil it for ever seeing it from the air. Knowing Attachment, refer to article written by Dr. Gerhard Smit. the flow is being controlled by Homo saps too will distract something from the place for me. We seldom do anything that EAP’s response: doesn’t harm. Control of the flow regime: The flow regime in the Orange River Solar power is getting more and more efficient and will be is highly altered, and has been artificially regulated since the cheaper than this hydroelectric installation. completion of the Gariep and Van der Kloof dams in the 1970s. Who will be benefitting personally? Follow the money trail. I The exceptions have been the few very large floods that cannot don’t believe someone will not be pocketing a lump sum. That be attenuated by the impoundments. These dams have facilitated is the way of our country. large-scale abstractions of water from the river for irrigation, as Jean Senogles well as transfers of water to the Eastern Cape. More recently the dams of the Lesotho Highlands Water Project have facilitated the transfer of large volumes of water into Gauteng. The extent of alteration to the flow regime over the falls by the hydropower project cannot reasonably be compared to the macro-level manipulations of the river described above. See the response to Comment 8 for an explanation of how the project will impact the river flow. Kai!Gariep Municipality – G. Lategan, Acting Municipal Manager 50. Mr. Johnston, Leandri D. Schwartz Dear Leandri, Attached, find the letter of support for the Riemvasmaak Hydro Admin Officer – PMU Thank you for your e-mail and letter of support for the proposed Electric Power Project. Kai !Garib Municipality, Riemvasmaak Run-of-River Hydro Project and for the review of Kind regards, comment by e-mail, 08 the draft environmental impact assessment report. Leandri D. Schwartz June 2015. I hereby acknowledge the submission received from the Kai! Garib Municipality. Sincerely, Shawn Johnston 51. Dear Sir, G. Lategan, Acting Kai !Garib Municipality’s support for the Riemvasmaak Run-of- Based on EIA documents received on 29 April 2015 for the Municipal Manager, River Hydro Project is noted for the record. Riemvasmaak Hydro Electrical Power Project, Northern Cape, comment by e-mail

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No. Issue Raised by Response from CES EIA team or Hydro SA South Africa outlined a plan for the proposed development of letter, 08 June 2015. the hydro energy plant to the Kai !Garib Local Municipality, the municipality confirm her support to the project. The above mentioned was preceded by a presentation on the potential environmental impacts of the project by yourself as well as the Environmental Consultancy in the Office of the Mayor in Keimoes, Kai !Garib Municipality. Beside the fact that you conducted a public participation process for the EIA in the Kai !Garib Municipal area, the Council’s Standing Committee dealing with socio-economic issues on Tuesday, 26 May 2015 express support for the project. Furthermore, the Kai !Garib Municipal Council at a Council Meeting held on 2 June 2015 compliments the decision of the Committee. However the following is noted as development contributions of the project:  The Environmental Impact Study addresses all the potential issues relating to the project;  The project will have a significant economic impact in terms of job creation and revenue generation both within the municipality and outside of the municipality;  It was noted that these positive impacts are expected to multiply should other renewable solar energy projects be established on adjacent sites;  The project has the potential to assist the municipality in achieving its immediate and long-term development goals inter alia, infrastructure services, LED and social cohesion;  Avoidance of greenhouse emissions and particulate pollution associated with thermal energy options;  Skills development to science students, visits by schools and interested parties in renewable energy;  Through social policy dialogue with local communities the project can contribute immensely to local investment by unlocking economic activity as a catalyst for social change.

Kai !Garib Council herby extends its support for the project. G. Lategan Acting Municipal Manager Kalahari River and Safari Company – Philippa van Zyl

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No. Issue Raised by Response from CES EIA team or Hydro SA 52. Hello Shawn, Philippa van Zyl, Dear Phillippa, I’ve just received the mail from the APA council regarding this Kalahari River and proposed Scheme. Safari Company, Thank you for your e-mail. I have registered you as a interested We would be directly influenced as we operate and have our comment by e-mail, 08 and affected party. camp just above the falls! Please advise what you require from June 2015. Please send me your comments on how this project will impact us so we can have our say. and affect your camp, operations and livelihood. Warm Regards Sincerely, Philippa Van Zyl Shawn Johnston Ten 3 Safaris 53. 8 June 2015 Philippa van Zyl, EAP’s response: To whom it may concern. Kalahari River and Your objections to the project are noted. We are tourism operators who have newly taken over a camp Safari Company, We believe that the commentator’s concerns about the impacts of on the Orange River roughly 10km above the Augrabies Falls. comment by e-mail, 08 the project on tourism in the area in general, and on her business The Camp was previously known as Khamkirri, a very well June 2015. in general, are exaggerated and unfounded. known sort after destination along the Orange River. Now As described previously in this report it is our opinion that the under new owner/management we are opening Kalahari River impacts of the alteration of the flow regime over the Augrabies & Safari company on the 1st of July 2015. Falls will be minimal, and will be unnoticed by the very large This proposed scheme is unacceptable, our location from a majority of visitors. We repeat that the project will never be geographical point would be directly affected as we not only responsible for “drying the falls up” or for ”reducing the flow to a utilize the river for recreational adventure activities but the trickle”. We also believe that, although there will be disruption surrounding area where we take tourists too. The Augrabies during construction, the site can be rehabilitated so that most of falls and Riemvasmaak are 2 direct tourism attractions that the infrastructure will not be visible. The commentator’s fears would be severely affected. Our camp as well as surrounding appear to be based on the belief that visitors to the area will not B&B’s, Lodges and tour operators would then no longer be tolerate any form of development in the area, even if it is for the able to offer the diverse products that we do for our Clients. purposes of providing renewable energy for the benefit of the Private tourism Operators and investors as well as Northern nation as a whole. Cape Tourism has spent huge amounts on promoting the province as a tourism destination for local and international tourism alike, working towards long term sustainability not only for eco tourism but job creation for local communities. Apart from the unsightly invasion the Hydro scheme will pose, noise pollution, water pollution, such environmental abomination is unacceptable. The Ripple effects of such a scheme is greater than the instant financial gratification and energy source for the companies and communities supporting this. I simply cannot support such a proposed scheme in our beautiful area that has so much else to offer. Regards, Philippa van Zyl

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No. Issue Raised by Response from CES EIA team or Hydro SA Kobus van Coppenhagen - Daberas (Draft Environmental Imapct Assessment Comments) 54. Dr. Avis Kobus van EAP’s response: We are a registered affected party for the above mentioned Coppenhagen, We note and do not doubt the commentator’s status as a application, which was launched by three separate SPE's in Daberas, comment by registered I&AP for the Scoping phase of the EIA. Dec 2012 and which was subsequently "upgraded" to double e-mail, 09 March 2015 Public consultation: We do not wish to comment on the the capacity of the proposed installation. commentator’s views on the adequacy of the public consultation For the sake of brevity we will not elaborate any further, process conducted before we – EOH CES – were appointed to assuming that your company is in possession of the details of complete the EIA process. all the registered IAP's together with all the correspondence The commentator was provided with a copy of the Application as which was exchanged between IAP's and AURECON. As a he requested: see Comment 56 below. matter of interest; we have suggested 2 years ago that AURECON should be replaced as the consultants because they were conducting a procedurally flawed and administratively unfair process. This happened a few months ago and your company has the unenviable task of concluding the process in a transparent and fair manner. As a matter of record it must be noted that a precedent was set several years ago when another applicant was directed by the Competent Authority, to allow the IAP's to participate in the appointment of the consultants due to the impacts of the proposal, which was also our notion in this case, from the outset. Details of this directive can be provided on request and which would then serve as proof of precedent. We do respectfully request that your facilitator contact us (and perhaps others) to confirm our status as affected parties, especially due to our many valid concerns and the incompetent manner in which it was being dealt with. We also need to verify with the facilitator that your company is in possession of a full record our correspondence, for consideration. In the meantime we do need a copy of the valid upgraded application (requested by DEA 18 June 2013) together with the subsequent instructions and directives issued by this competent authority, which would have validated the application and which would lead the consultants in the design of the Scoping and EIA Reports. We also need a copy of the water license application, together with the instructions and directives issued by DWA. Regards Kobus & Hannecke van Coppenhagen Augrabies.

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No. Issue Raised by Response from CES EIA team or Hydro SA 55. Dr Avis, Kobus van Dear Mr van Coppenhagen, We have requested more than 4 weeks ago, that you should Coppenhagen, Thanks you for your email. My apologies for the late response, furnish us with the copy of the valid application form date Daberas, comment by but we are in the final stages of completing all documents for the stamped by the DEA and according to which the ToR for your e-mail, 15 April 2015 HydroSA project and somewhat busy. EIA has been determined. You have failed to provide us with Our engagement process, and indeed that of the EIA process, is this document, without which the application is invalid and the to gather all correspondence from IAPs and integrate this into a procedurally flawed. Do you refuse to provide this document? comments and response trail, in preference to individual and Your response is urgently required. piece-meal responses. Regards The latter is an inefficient and somewhat exclusive way of Kobus van Coppenhagen engaging, whereas including concerns and responses in the comments trail of the EIAR is a more transparent and inclusive manner of engaging with IAPs. This way everyone is privy to the debate, rather than a select few. With regard to the application form, it will be included in the Draft EIAR as an appendix for all to see. Regards, Ted Avis 56. Dear Dr. Avis, Kobus van Dear Mr van Coppenhagen, It is quite clear that we are not "on the same page", so to Coppenhagen, Kindly find the revised application form attached. speak. The applicant/s are obliged to provide the information Daberas, comment by Regards, on request of an IAP, not whenever they feel like doing it. The e-mail, 22 April 2015 Ted failure to provide a copy of the valid application form at the time when we requested it, about 18 months ago, is a serious failure on the part of the applicant and our objections to the continuation of this application must be recognized, when a review is conducted. Unfortunately it seems as if the basic concept of fair procedure and administration as laid out on the relevant document, is beyond comprehension. To refresh your memory and for the sake of brevity, we will only quote note (8) from the front page of the original "RVM1....." application;"Unless protected by law, all information filled in on this application shall become public information on receipt by the competent authority (CA). Any interested and affected party should be provided with the information contained in this application on request, during any stage of the application process." The bold type and underlining is used to reinforce our point. The record will show that we have been requesting this very relevant information for a long time and that the indulgence/failure of the CA does not absolve the applicant

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No. Issue Raised by Response from CES EIA team or Hydro SA from this duty. We are stating again, also for the record at the CA, that you are not conducting a valid application, for the various reasons we have furnished and which you admitted to have received copies of, from the previous EAP. Do you understand that we were only asking you for a copy of the valid application form, which was used to determine the ToR for the Scoping Report? This was a request for information, not comments !!! Best regards, Kobus van Coppenhagen 57. Dear Dr. Avis, Kobus van Dear Mr van Coppenhagen, Thank you for the document which you have forwarded to us. Coppenhagen, Kindly find attached the DEA acceptance of the amended Unfortunately it seems as if some panelbeating has been done Daberas, comment by application. as far as the original project title is concerned. This is a very e-mail, 28 April 2015 We acknowledge receipt of your other comments and we will important detail, when appeals/objections are lodged. To address these issues through the independent facilitator and the refresh your memory we do attach a copy of page one of the Issues Response Trail, as well as during the focus Groups and "RVM1" application, which shows the original title and which public meetings, all of which will be minuted. covers ONE hydro electric power station WITHOUT the water Regards, and electricity conveyance infrastructure, which was applied Ted for in "RVM3". Since you acknowledged receipt of our documents from AURECON, you would have noted our concern about the incorrect statement in a letter by AURECON dated 3 June 2013 (see below), which states that RVM1 has launched 3 applications, which is patently false. The closure of "RVM3" has led to the lapsing of that application. We also need a copy of the letter of acceptance by the DEA which "authorised" the transfer/inheritance/consolidation of the activities applied for in the lapsed "RVM3" application into your new? (no reference to RVM1) application. The reason for this is so that we can engage with the official to determine whether he/she/they were misled by the false statement referred to above, or whether it was a conscious decision. You do realise that these are administrative questions and not comments, thus we would expect a copy of the letter of acceptance from DEA to be forthcoming within a reasonable time frame. In the mean time our contention that you are conducting an invalid and flawed procedure, which could lead to destruction inside a National Park, remains firm. It is literally incomprehensible, how businesses with highly educated and skilled people can make such errors unwittingly.

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No. Issue Raised by Response from CES EIA team or Hydro SA Regards, Kobus van Coppenhagen 58. Hallo Shawn, Kobus van Dear Mr van Coppenhagen, We are actually requesting a copy of the minutes of the Coppenhagen, We refer to our e-mail to you yesterday, 4th May 2015, in which meeting held with the DEA on 28 August 2013. I believe that Daberas, comment by we sent you a copy of the minutes of a meeting held between Mr Smit and others from DEA were present. e-mail, 04 May 2015 Hydro SA and SANParks on 25th July 2013, and to your Regards subsequent reply received this morning, 5th May 2015. Kobus van Coppenhagen You are correct in saying that this is not the meeting referred to in On 04 May 2015, at 1:41 PM, Kobus van Coppenhagen wrote: DEA’s letter dated 30th October 2013, in which the department Hallo Shawn accepted the Scoping Report for the above project. Our telecon of this morning refers; At the time of writing to you we believed that DEA had misquoted We have not yet received a copy of the minutes of the DEA the date of this meeting, because on the date in question date our meeting of 28/8/2013, as requested. principals at Hydro SA, Mr Theron and Ms Grimbeek, were in Regards, Namibia. However, it has recently been brought to our attention Kobus van Coppenhagen that such a meeting was in fact held, and that the then Case Officer, Ms Poll-Jonker, was responsible for preparing the minutes of the meeting and distributing them to the participants. Neither Mr Theron nor Ms Grimbeek has any record of receiving the minutes. As a consequence the Draft EIA Report we have recently submitted to DEA does not include a copy of the minutes, and we are currently unable to provide a copy to you and the other I&APs. We have contacted Mr Danie Smit at the department and requested him to follow the mater up with Ms Poll-Jonker, and either provide us with a copy of the minutes, or let us know if no minutes were prepared. As soon as we hear from Mr Smit we will be in touch with you, but in the meantime please accept our apologies for the confusion over this issue. Sincerely, Bill Rowlston – EOH CES Shawn Johnston – Sustainable Futures Re submission of Mr Kobus van Coppenhagen’s Comments (Listed 1-16) Row 58-72 of this table 59. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, disappeared and we want to put it back on record. We will Daberas, comment by Thank you for our submission (1) relating to the proposed be sending many e-mails in the next few days. (1) e-mail, 30 May 2015 Riemvasmaak Run-Of-River Hydro Power EIA. Kobus van Coppenhagen I hereby acknowledge receiving your comments for the record Begin forwarded message: and inclusion in the environmental impact assessment study. From: Kobus van Coppenhagen Sincerely,

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No. Issue Raised by Response from CES EIA team or Hydro SA Date: 07 April 2013 4:57:31 nm. SAST Shawn Johnston To: David Jury McDonald Cc: Louise Corbett , Mike EAP’s response: Knight Subject: Botanical These comments were submitted to Aurecon during the BAR and Assessment for Riemvaasmaak Hydro-power Project Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Sir Response Report 1 and 2 of Aurecon’s September 2013 Scoping We live in the Lower Orange river valley and share a common Report. The comments have been included in this report for boundary of approximately 18 km with the Augrabies Falls record purposes, as requested by the commentator. National Park and are in the process of contracting the land into the National Park on a long term agreement, since 2008. This is a long process which was initiated by the desire to establish a transfrontier park (LORI Project) along the Lower Orange river, of which the Augrabies Node would stretch to Onseepkans and cover an area of 120 000ha. The river in this area is managed by a Joint Managent Board which is comprised of government departments of Namibia and South Africa. Unfortunately the finacial crisis put the process on ice, but SANParks declared their intent of continuing the process, during the review of the Park Management Plan towards the end of 2012. It was confirmed by a specialist at the time (2008) that this area falls within a biodiversity hotspot and is worthy of protection. We are studying your assessment and have a few specific questions to ask; 1) Were you aware of the existence of GN 106 of 8 February 2012, published in GG no. 35020 ? Title: Biodiversity Policy & Strategy for South Africa : Strategy on Buffer Zones for National Parks. We would appreciate your assessment of the desirabilty of this planned industrial complex in the light of the recommendations made in this policy document. Several questions arise from this document and specifically that all ranks/levels of government " should respect the views of SANParks" as far as the desirability of developments around declared National Parks are concerned. We believe that this document would make it "unwise" to apply for large scale projects in and around national parks. 2) Have you done any new work on black flies, which cause universal problems in the Bushmanland. We believe that an

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No. Issue Raised by Response from CES EIA team or Hydro SA impoundment of the river and also the outlet site could aggravate/exacerbate the problem. The Departments of Agriculture and Water Affairs are responsible for the control measures. The cost of a single spraying event alone is estimated to be about R 1 million and that covers only specific areas, not the whole river. 3) Were you involved in any public participation process? We would appreciate some kind of declaration from you on this regard, because there seems to be inconsistency between the specialist declarations. 4) Aurecon, by way of ms L Corbett, seems to think that our concerns only need to be recorded for the decision makers to adjudicate. However, due to the lack of notification, virtually nobody in the area received notice of this project and we have many issues which must to be considered. The number of private land owners notified were only 4 and they own the land on which the power lines need to be built. We are in no position to make any meaningful contribution at this stage, except to raise the alarm that there was no public participation process. Please be so kind to respond to this e-mail, since it is a matter of great importance to us. Regards

Kobus van Coppenhagen 0836564498 PS : Ms Corbett, today is Sunday and you will notice that we are busy with this matter every day and do not intend to waste your time, but we need you to urgently contact the applicant to re-open the lacking public participation process, since our approach is to contact a higher level of authority every 48 hours or so ! 60. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, Thank you for our submission (2) relating to the proposed disappeared and we want to put it back on record. We will Daberas, comment by Riemvasmaak Run-Of-River Hydro Power EIA. be sending many e-mails in the next few days. (2) e-mail, 30 May 2015 I hereby acknowledge receiving your comments for the record Kobus van Coppenhagen 0836564498 and inclusion in the environmental impact assessment study. Begin forwarded message: Sincerely, From: Kobus van Coppenhagen Shawn Johnston Date: 10 April 2013 12:31:29 nm. SAST To: Louise Corbett EAP’s response:

Coastal & Environmental Services 59 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA Cc: A B Abrahams , Howard These comments were submitted to Aurecon during the BAR and Hendricks , Mike Knight Scoping phases of the assessment and they are included, , Lea Visser together with responses, in Annexure C – Comments and Subject: Hydrology of the Orange river Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for Ms Corbett record purposes, as requested by the commentator. Although an aquatic study was done, it seems as if the . hydrological aspect was neglected from a water balance perspective and it seems as if no new work has been commissioned to adress the potential future reductions in water transfers between CMA's, which might influence this project's viability. Some background information/data needs to be gathered i.r.o future projects and approved projects, currently in the "pipe line" which could reduce the quantity of water reaching Augrabies Falls. The reason for this question is that there are other, external factors which will permanently reduce the quantity of water flowing through the Augrabies Falls in future. It is prudent to note that the majority of water use from the Orange river occurs before Augrabies Falls and most future requirements will originate upstream. This could be projects for which the water use has already been allocated, for example; 1) The 12 000 ha irrigation quota set aside for historically disadvantaged individuals. As far as we know, this is an allocation which would be used, mostly in the Lower Vaal CMA, which is more or less between Gariep dam and Augrabies Falls. We are currently noticing a lot of development and expansion in the sense of land preparations, where irrigation has not yet started. 2) Transfers to other Catchment Management Areas, which might reduce the quantity reaching Augrabies Falls. Perhaps increased transfers from the the Lesotho Highlands Scheme to the Wilge river, due to increased demand in the Upper Vaal Catchment Management Area, eg. for new power stations like Kusile PS, near Ogies. This activity would reduce the quantity of water released to Gariep dam. Kusile is a power station which would have a capacity in excess of 4 200 MW, with at least 98% availability for the next 20 years. This is about 600 times of the annual capacity compared to your to your estimated/projections of about 30% output of the proposed

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No. Issue Raised by Response from CES EIA team or Hydro SA RVM hydroscheme. Although these transfers would take place before the Gariep dam wall, it is still a reduction in total volume of water available for discharge, which will eventually reduce the quantity of water, which can be released during dry seasons. 3) If your proposed scheme was a regular, run of the river scheme, like the proposed Neusberg scheme, the above scenario's wouldn't matter as much, as at Augrabies Falls, because you are applying to conduct a streamflow reduction activity, which would ultimately lead to the demise of either the Augrabies Falls (and the National Park) or the power station. Thus, together with the convenient vertical drop in height, comes a direct competition with the actual existence of the Augrabies Falls. No-one in this part of the Northern Cape would be willing to sacrifice the spectacle of Augrabies Falls in exchange for a few MW of unprofitable power station. A power station was built in the old Bophutatswana, about 30 years ago, but they did not make provision for water, so it was never started up. 4) Section 21(a) of the 1998 Water Act : We intend to lodge a request with DWA Lower Vaal in Kimberley to declare this activity, as a stream flow reduction activity, if they do not already deem it to be and we will request SANParks to do the same. Should DWA decline the request, it would be an administrative error, for which we would have to approach the Water Tribunal for relief and to set it aside. It is a well known fact that a substantial amount of water returns to the river from irrigation farms close to it, but that quantity is not added to the irrigation quota, which underpins the principle, that the quantity returned to the river cannot be subtracted from the quantity abstracted/diverted. Should DWA agree with your ASSUMPTION that section 21(a) is not applicable, it would create a precedent for other water users to deduct the quantity returned to the river as a portion of water use which does not require licensing. Thus your water license application is flawed and should not be granted because the activity will reduce the quantity of water, at least in a section of the river, which makes it a stream flow reduction activity in the true sense of the word. Thus your assumption that the water license should not be applied for in terms of section 21 (a), is fatally flawed.

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No. Issue Raised by Response from CES EIA team or Hydro SA 5) To what extent does DWA/the applicant expect potential climate changes for example, to affect the reliable quantity of water, which can be transferred into the Lower Vaal CMA, in future? This would also reduce the quantity, which could be allocated. 6) The applicant is making a great effort to confirm that the area has been excluded from the National Park, which still manages it, but in terms of the recently published Strategy on Buffer Zones around National Parks, it is quite possible that the area will be listed as such during revision of spatial development plans and that the project would be declared undesirable at that stage because it is a large industrial complex. Regards Kobus van Coppenhagen 083 6564498

PS : Mike, we suggest that you consider applying for this activity, to be declared as a streamflow reduction activity by DWA, if you have not already done so. 61. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, disappeared and we want to put it back on record. We will Daberas, comment by Thank you for our submission (3) relating to the proposed be sending many e-mails in the next few days. (3) e-mail, 30 May 2015 Riemvasmaak Run-Of-River Hydro Power EIA. I hereby acknowledge receiving your comments for the record Kobus van Coppenhagen 0836564498 and inclusion in the environmental impact assessment study. Begin forwarded message: From: Kobus van Coppenhagen Sincerely, Date: 11 April 2013 12:45:46 nm. SAST Shawn Johnston To: Louise Corbett Cc: A B Abrahams , Howard EAP’s response: Hendricks , Mike Knight These comments were submitted to Aurecon during the BAR and , Lea Visser Scoping phases of the assessment and they are included, Subject: Additional time for comments together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Ms Corbett Report. The comments have been included in this report for Thank you for the allowance of additional time for comments, record purposes, as requested by the commentator. we would like to draw your attention to an offer made by SANParks to make their boardroom available for the additional meeting, subject to it being available for that date. Please take notice of their mail, which we are forwarding separately. To

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No. Issue Raised by Response from CES EIA team or Hydro SA ensure that most IAP's are informed, we would suggest that you place an advert in Die Gemsbok, which would satisfy our first "demand", i.r.o. public notification. We also want to draw your attention to the fact, that even though we have concerns about the proposed project, we are not trying to delay the process, but rather to have an opportunity to participate in a process which is procedurally and administratively fair. We want our concerns to enjoy proper consideration by the specialists and also to get feedback from them. We are busy with a process of integrating privately owned land into the Augrabies Falls National Park, for a very long period (99 years) and conclusion will be dependant on the long term viability of this National Park. However every application for a listed activity on either our land or the Park delays this urgent process, which was initiated in 2008. The National Park is under constant threat of development, not in line with its mission and Management Plan, however the Strategy on Buffer Zones around National Parks should give them the tool to remove/manage threats of large scale developments like the one you are proposing. You should note that there is for example applications pending with DMR, for prospecting rights in this very same Park and associated buffer zones. We can submit information for your perusal if required. We hope that this explanation makes our frustration and predicament clear to you. We will be in Cape Town between 30 April to 5 May, due to unforseen circumstances, for consultation with a medical specialist and will not be available at that time. Regards Kobus van Coppenhagen 0836564498 62. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, Thank you for our submission (4) relating to the proposed disappeared and we want to put it back on record. We will Daberas, comment by Riemvasmaak Run-Of-River Hydro Power EIA. be sending many e-mails in the next few days. (4) e-mail, 31 May 2015 I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. Kobus van Coppenhagen 0836564498 Sincerely, Begin forwarded message: Shawn Johnston From: Kobus van Coppenhagen Date: 10 April 2013 9:00:38 vm. SAST EAP’s response: To: A B Abrahams , A B Abrahams These comments were submitted to Aurecon during the BAR and

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No. Issue Raised by Response from CES EIA team or Hydro SA Scoping phases of the assessment and they are included, Cc: Louise Corbett , together with responses, in Annexure C – Comments and Howard Hendricks , Mike Response Report 1 and 2 of Aurecon’s September 2013 Scoping Knight , Lea Visser Report. The comments have been included in this report for Subject: Riemvasmaak hydropower record purposes, as requested by the commentator. generation

Sir We became aware of the planning of hydro-generation schemes in the Lower Vaal CMA, specifically the Neusberg- weir run-of-river scheme outside of Kakamas and also the Riemvasmaak hydro- generation scheme, which would divert water from JUST before the Augrabies Falls, to a site in the Riemvasmaak area and then to utilise the drop in elevation into the Lower Orange river valley for a power generation complex. This mail is dealing specifically with the latter proposal, for the Riemvasmaak area. Ms. L. Corbett has confirmed during a telecon, last week Thursday 4 April, that Aurecon has been appointed to conduct the Environmental Impact Assesment for the applicant and that they have placed an advert in a local newspaper, Die Gemsbok, late in December of 2012 to publically invite comments for the proposed hydrogeneration schemes on farm 497 and portion 1 of Farm 498, with the following DEA reference no's; RVM1( DEA ref. no. : 14/12/16/3/3/1/681) application date 17 August 2012; RVM 2 (DEA ref. no. : 14/12/16/3/3/1/685) application date 17 August 2012 & RVM 3 ( DEA ref. no. : 14/12/16/3/3/1/767) application date 14 November 2012. During the telecon we reminded her that nobody in this area seems to know about the project and asked that they consider, restarting this public participation process to ensure that it would be procedurally fair. She confirmed that they would only insert our comments into the final report, because it is already months after the closing date for meetings, etc. At this stage we requested that the applicant should then rather contact us with a view to appoint a consulting company which would at least have some form of public participation programme, which

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No. Issue Raised by Response from CES EIA team or Hydro SA was ignored even after an e- mail to that effect. She did forward a link which, enabled us to access documents and because we did not want to waste any time, worked the whole weekend of 6&7 April. However on checking the declarations all of the specialists except one, it became apparent that they have signed declarations on dates prior to the supposed advert, which confirms that they have participated in a public process. On Monday 8 April when we contacted Die Gemsbok and they confirmed that no advert was placed in December 2012 for Aurecon, or the applicant. This information was relayed to ms.Corbett on Monday 8 April 2012 and she promised to to send a copy of the advert as proof. At this stage attention must be drawn to the Draft BAR document on the Aurecon website, which does not display a copy of the advert in the position allocated for it. We phoned ms. Corbett late on Tuesday 9 April to expedite delivery of this proof, when she confirmed that the actual advert was placed in the Volksblad newspaper which is published in Bloemfontein about 800 km away from Augrabies. WE BEG YOU TO REJECT AND RETURN ALL THE WATER LICENSE APPLICATIONS FOR THE PROPOSED HYDROPOWER PROJECTS AND TO ISSUE A DIRECTIVE THAT THE PUBLIC PARTICIPATION PROCESS BE STARTED FROM SCRATCH. WE BELIEVE THAT THE UNWILLINGNESS OF AURECON TO YIELD TO OUR REASONABLE REQUEST SHOULD DISQUALIFY THEM FROM HAVING ANY FURTHER PART IN THIS PROCESS. We have already raise valid questions and concerns which are not in the specialist reports and which needs to be adressed, however for the sake of brevity we will send those questions, amongst many other potential impacts, by separate mail. Regards Hannecke van Coppenhagen 083 6564498 63. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, disappeared and we want to put it back on record. We will Daberas, comment by Thank you for our submission (5) relating to the proposed be sending many e-mails in the next few days. (5) e-mail, 31 May 2015 Riemvasmaak Run-Of-River Hydro Power EIA. Kobus van Coppenhagen 0836564498 I hereby acknowledge receiving your comments for the record Begin forwarded message: and inclusion in the environmental impact assessment study.

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No. Issue Raised by Response from CES EIA team or Hydro SA From: Kobus van Coppenhagen Date: 09 Mei 2013 10:52:08 vm. SAST Sincerely, To: Louise Corbett , A B Shawn Johnston Abrahams , M Gordon Cc: Howard Hendricks EAP’s response: , Mike Knight These comments were submitted to Aurecon during the BAR and Scoping phases of the assessment and they are included, Subject: Re: RVM Hydrogeneration scheme together with responses, in Annexure C – Comments and Response Report 1 and 2 of Aurecon’s September 2013 Scoping Ms Corbett Report. The comments have been included in this report for For information of other recipients of this message the record purposes, as requested by the commentator. reference no's of the applications are recorded; RVM 1: DOS verw. 14/12/16/3/3/1/681, NEAS verw. DEA/EIA/0001403/2012 RVM 2: DOS verw. 14/12/16/3/3/1/685, NEAS verw. DEA/EIA/0001410/2012 RVM 3: DOS verw. 14/12/16/3/3/1/767, NEAS verw. DEA/EIA/0001571/2012 Firstly we need to submit the following information as full clarification of our reason for attempting to participate in the process you are conducting; We have been involved in negotiations for several years to voluntarily incorporate our land into the Augrabies Falls National Park on a long term contract of 99 years, to expand the range for endangered species. This project has been approved by the EXCO of SANParks. Initially, applications for prospecting rights on our land and also the National Park were made which delayed the process, because the land cannot be incorporated into the National Park if a prospecting right is awarded to a third party. Now, have a situation where the status of the National Park (or part of it) might be revoked, similar to the Lake Pedder National Park debacle in Australia, where the HEC(HydroTasmania), was involved. This arm of the Tasman Government is also involved in this application by way of their shareholding in the company applying for the environmental authorisation. However it seems that the branch of SA government (SANParks) which manages land set aside for the preservation of areas with special natural attributes, must look on while a barrage of applications are made, which could

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No. Issue Raised by Response from CES EIA team or Hydro SA irreversibly change the nature and status of the National Park. We are at the moment reluctant to proceed with this process of incorporation, because of the perceived lack of SANParks authority or ability to perform its functions as guardians of the National Parks of South Africa. We do believe that the person from DEA (Sandile Vilakazi) mentioned in your draft executive summary document (page 7), should have informed the applicant of the status of the land on which it wants to construct this plant or parts of it. Your e-mail below refers; We appreciate the fact that you have drawn attention to the regulations set out in GN 543, published in GG 33306 of 18 June 2010; Section 57 makes provision for direct communication with the competent authorities, whom in this case would be Mr M Gordon of DEA and Mr AB Abrahams of DWA and by way of this message we are stating our dissatisfaction with the manner in which this process is being conducted. We want to draw their attention to 5 specialist declarations which are displayed on your website, in which they have ALREADY considered comments/inputs from a public participation process almost three weeks PRIOR to the anouncement of the public participation process, in a Free State newspaper, Volksblad, published in the first week of Jan 2013. We have drawn your attention to this fact, but you chose not to contradict our allegation. In addition to this you have mentioned on page 5 of your draft executive summary, confirmation of publishing the required notification in the Gemsbok, which is a local newspaper, but on request you have failed to provide proof of the publication. You have subsequently confirmed by telecon that the advert has indeed not been placed. We have also drawn your attention to the exaggeration of information between documents and newspaper articles, some of which can only be described as hyperbole. For the sake of brevity we do not include details again, but we would forward these messages to the competent authority if needed. It is a specific requirement of public particpation processes that the information in applications and press releases should correspond and be accurate, not to mislead the public.

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No. Issue Raised by Response from CES EIA team or Hydro SA Furthermore we want to indicate to you that the attempt by Nelis Bezuidenhout of your office (to organise) to gain access to the National Park to do project work, as indicated on an e- mail request should be construed as commencement of the activity, which is a serious offence, or at least an indication of bias towards the applicant. This should also disqualify the parties involved from the applicant's side from further participation in this process, especially since you did so eloquently draw our attention to your knowledge of this GN 543. Now then, we believe that you have neglected to adress our concerns in an objective or satisfactory manner, considering the timeframes allowed and we can only record our total objection to the public participation process which has been conducted and that procedural and administrative fairness could not be achieved, by intervention, but rather that the process should start afresh and be subject to S&EIR at least. This is obviously a matter for the departments to decide, but we insist that they should consider that the process is completely flawed and one-sided and we are expecting urgent relief in this regard. As far as the processing of applications for environmental authorisation for activities inside National Parks are concerned, we have also indicated to you that the Strategy on Buffer Zones around National Parks should dictate that it is unwise to apply for environmental authorisation, for activities which are not specifically envisaged in the relevant acts and regulations. This issue needs to be considered and clarified by all government departments, especially the competent authorities receiving applications. Regards Kobus van Coppenhagen 64. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, disappeared and we want to put it back on record. We will Daberas, comment by Thank you for our submission (6) relating to the proposed be sending many e-mails in the next few days. (6) This e-mail, 30 May 2015 Riemvasmaak Run-Of-River Hydro Power EIA. message was also forwarded to DEA once we found the I hereby acknowledge receiving your comments for the record correct address and inclusion in the environmental impact assessment study. Kobus van Coppenhagen 0836564498 Begin forwarded message: Sincerely,

Coastal & Environmental Services 68 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA From: Kobus van Coppenhagen Shawn Johnston Date: 16 April 2013 11:21:11 vm. SAST To: Louise Corbett EAP’s response: Cc: Lea Visser , Howard Hendricks These comments were submitted to Aurecon during the BAR and , Mike Knight Scoping phases of the assessment and they are included, , Frans Van Rooyen together with responses, in Annexure C – Comments and , Marius Burger Response Report 1 and 2 of Aurecon’s September 2013 Scoping , A B Abrahams Report. The comments have been included in this report for record purposes, as requested by the commentator. Subject: Proposed Riemvasmaak power generation scheme.

1) We are of the opinion that this application should be subjected to a full scoping and EIA process, due to the the following reasons; a) It is an extremely sensitive and brittle environment, ie. you cannot mitigate the impact of the construction activities, due to the hard rock environment. b) The area subject to the placement of the individual elements of the plant will be substantially larger than one hectare and even if you divide the footprint of the various applications between 3 companies as individual applications, the cumulative impact would still be large enough to justify a full scoping and EIA process. c) The specialist studies does not make reference to the hidden fauna of this area; lizards, snakes and scorpions, etc. Some of these species can only be observed by specialists and it is possible that the route for the pipeline could even harbour red data species. We want to draw your attention to SARCA expedition 11, during which a very rich diversity of reptile species was recorded. We attach a list, of species recorded, from the Herpetological Society of SA website, at the end of the e-mail. The Project Herpetologist was Marius Burger, but we are unable to locate him for more information at this stage. Our contention is that regardless of the destruction caused by the construction activity, the lasting impact of these structures would be that it will present a formidable barrier to several of the reptile species and other Fauna. d)The placement of the weir elements in the river channels could cause outbreaks of malaria due to the pooling effect of the structure. Perhaps you are not aware, but Kakamas is a

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No. Issue Raised by Response from CES EIA team or Hydro SA low risk malaria area and sporadic outbreaks have occurred in the past, with thousands of reported cases during one previous event. e) The applicant did not demonstrate that they have permission from the owners or management authority of the sites and the potential for disagreement between the various parties and even between the historically disdvantaged owners of the "power station site", requires sensitivity, facilitation and a broad public participation process, with sufficient time for the owners to decide whether they want to participate in this risky project, or not. The document which you submit as proof of excision from the National Park for the power station site, states that the SANParks remain responsible for the management of that area. The applicant also did not use the opportunity to introduce the project to interested parties at the meeting for the revision of the Park Management Plan late in 2012. f) Shortly after our engagement, a press release was made in "Die Burger" newspaper, by the applicant, with information which could be regarded as misleading. The information should not be conflicting with those in the documents, presented to the Competent Authority. One should elaborate, because the variation in data/information is significant and it is important that the public should not be misled/pacified with false information. Specifically the value of the project is stated as R 700 million in the article, which is 233% up on the figure of R 300 million, in your BAR document. The additional effect of this exaggeration is that the historically disdvantaged community would now have to pay R 84 million for their 12% share instead of R 36 million. The height of the weir is also stated to be 2,5m maximum and your document indicates less than 5 m,which is more or less double the height. Incorrect statements are an indication that the applicant is conducting a flawed process. This tendency would also suggest that information submitted by the applicant should be subjected to stringent verification. The job creation figures are another scenario, etc. g) We have highlighted several other shortcomings in recent communication and will not repeat it, for the sake of brevity. However the declarations of the specialists remain a matter of

Coastal & Environmental Services 70 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA huge concern; especially since it seems to be a standard (identical) form which was completed by all but one specialist. Did Aurecon provide this document, or where did it originate from, because you did not make use of the same document for your declaration. h) The tourism value is completely overestimated and the examples are inappropriate for this project, because it seems as if none of your examples are for run of river projects. 2) This application is indicative of an absolute lack of sensitivity and respect for the sense of place of the National Parks of South Africa and makes one wonder whether the Tasman Government, as owner of Hydro-Tasmania and partner in Hydro-SA, is aware that they might be party to potential destruction inside a South African National Park. Perhaps we should contact the Tasman/Australian government, to confirm their appetite for this activity inside a high priority conservation area in one of our National Parks, if you would be kind enough to provide the contact details. 3) Anyway, there are several renewable energy plants proposed or under construction in the Northern Cape, some of which were assessed by you, Ms Corbett. Many of the renewable energy plants, either proposed or under construction, would dwarf this proposed installation as far as output is concerned, and it is situated outside of a National Park boundary. The latest "Gemsbok" newspaper of 12 April, for example, published the following notices; Environmental Authorisation for Karoshoek Solar installation 700 MW in total Environmental Authorisation for Tutwa Solar installation on Farm Narries 7, output not specified, quite close to the National Park (20km). Environmental Authorisation for Solar Installation of 100MW on Farm 188 Zwartbast, near Kenhardt. Environmental Notification for PV Solar Installation (output not specified) on Farm 91 Konkoonsies, near Pofadder In addition to this we are aware of the following plants which are currently under construction; KaXu One 100 MW Solar Installation between Augrabies and Pofadder Khi One 50 MW Solar Installation near Upington. From this information, you should deduct that the Northern

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No. Issue Raised by Response from CES EIA team or Hydro SA Cape has massive potential for renewable energy generation, especially solar power generation, which does not have to impact directly on Conservation Areas; which makes sense. Thus the alternative to the proposed development which would have a significant impact, but insignificant output due to the expected 30% availability, would be the erection of a solar generation installation on Riemvasmaak land, which by the way, is approximately 75 000 ha in extent, but which would not spoil the sense of place of the relatively pristine conservation area, which is also bio-diversity hotspot. This type of installation can be erected quite rapidly and the cost is probably lower per installed Watt. A solar trough installation doesn't require a power tower, but it could have heat storage of between 2 and 3hours, and it can have a PV installation adjacent to it. The contribution to the national electricity grid could thus be more than 10 times the output of this proposed hydroscheme and it could be expanded in future. The focus should thus be on preserving the small area of the Lower Orange River Valley which does have a high intrinsic conservation value and use another portion of the communal land to generate an income. The other issue about a hydroscheme is that during a verification process it will become apparent that there are water allocations which are not yet fully utilised and also increases in consumption/transfers which can be forecast for the near future, which would lead to a reduction in the quantity of water ultimately reaching Augrabies Falls. Please forward the contact details of the designated officials at DEA, in order that we can forward this mail for their attention. Regards Kobus van Coppenhagen 65. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, Thank you for our submission (7) relating to the proposed disappeared and we want to put it back on record. We will Daberas, comment by Riemvasmaak Run-Of-River Hydro Power EIA. be sending many e-mails in the next few days. (7) e-mail, 30 May 2015 I hereby acknowledge receiving your comments for the record Kobus van Coppenhagen 0836564498 and inclusion in the environmental impact assessment study. Begin forwarded message: Sincerely, From: Kobus van Coppenhagen Shawn Johnston Date: 17 Mei 2013 3:11:21 nm. SAST To: Danie Smit EAP’s response:

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No. Issue Raised by Response from CES EIA team or Hydro SA Cc: Louise Corbett , These comments were submitted to Aurecon during the BAR and Pieter van der Walt , Howard Scoping phases of the assessment and they are included, Hendricks , Frans Van together with responses, in Annexure C – Comments and Rooyen Response Report 1 and 2 of Aurecon’s September 2013 Scoping Subject: Riemvasmaak hidroskema Report. The comments have been included in this report for record purposes, as requested by the commentator. Meneer Smit, Baie dankie vir u oproep. Die besluitneming ivm die voorgestelde hidroskema moet gesien word teen die agtergrond dat die Augrabiesvalle Nasionale Park 'n GEOPark is, dws dat die landskap (litosfeer) bewaar word en ons glo dat julle ook 'n spesialismening in hierdie verband sal aanvra en oorweeg. Daar is 'n publikasie " Geological Journeys" waarin die skrywers verwys na Augrabies as 'n "Geologiese Paradys". Daar is ook 'n dokument getitel "The Geomorphology and Geoconservation Significance of Lake Pedder (Kiernan K, 2001) (pdf kan afgelaai word) wat gepubliseer is na aanleiding van die oorstroming van Lake Pedder in Tasmani , wat die meriete van die bewaring van GEOdiversiteit bepleit. Die redenasie is dan ook baie toepaslik, dat unieke landskappe nie gepreserveer kan word met biopreserveringstegnieke soos bv. plante of diere wat hervestig kan word, of saad wat versamel en geberg kan word, ens. 'n Interessante aspek wat in hierdie dokument aangespreek word, is die gebrek aan kennis van geodiversiteit by amptenare wat besluite geneem het. Dit is toepaslik in hierdie geval dat die meer oorstroom is vir 'n hidroskema van Hydro Tasmania (HEC)(een van die aansoekers) en ons stel voor dat u self verdere inligting ivm die geleentheid inwin (bg. dokument is jare daarna geskryf). Prof. P. vd Walt, skrywer van die gids "Augrabies Splendour" het ook bevestig, dat hy met sy navorsing in die argiewe opgemerk het dat 'n hidroskema by Augrabies oorweeg was in die sestigerjare, maar dat daarvan afgesien is en dat die gebied daarna as Nasionale Park verklaar is.

Dit sou ook meer relevant wees indien die sosio-ekonomiese studie sou fokus op Hydro Tasmania(een van die aansoekersby wyse van hulle aandeelhouding) se operasies aangesien daar heelwat inligting beskikbaar is. Daar is op

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No. Issue Raised by Response from CES EIA team or Hydro SA stadium beweer dat hulle skemas baie skuld gehad het en dat dit nie winsgewend bedryf is nie.

Die aftakeling van so 'n installasie is natuurlik ook onmoontlik in 'n harde rots omgewing en die skade is dus permanent. Die konsultant se BAR dokument bespreek dan ook nie die moontlikheid daarvan, omdat dit onmoontlik is. Die moontlikheid van aardbewings soos wat onlangs in Augrabies voorgekom het, kan natuurlik skade aan so 'n projek aanrig, wat dit permanent uit bedryf kan stel. As gevolg van hierdie feit word hidroskemas ook nie as 'n vorm van omgewingsvriendelike energieopwekking beskou nie.

Hidroskemas soos hierdie kan natuurlik ook glad nie tot die basislading bydra nie aangesien dit nie 'n reserwe van water het nie, dus het dit geen voordeel bo 'n sonkraginstallasie wat in hibriedevorm ontwerp kan word om energie te stoor vir etlike ure per dag. 'n Soortgelyke 100MW sonkrag aanleg, KaXu One, word huidiglik deur Abengoa opgerig in ons omgewing.

Groete Kobus 66. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, Thank you for our submission (8) relating to the proposed disappeared and we want to put it back on record. We will Daberas, comment by Riemvasmaak Run-Of-River Hydro Power EIA. be sending many e-mails in the next few days. (8) The e-mail, 30 May 2015 I hereby acknowledge receiving your comments for the record consultants did initially deny that HT was involved. I and inclusion in the environmental impact assessment study. assume that after the SARAWAK debacle they wanted to Sincerely, remain below the radar. Shawn Johnston Kobus van Coppenhagen 0836564498 Begin forwarded message: EAP’s response: From: Kobus van Coppenhagen These comments were submitted to Aurecon during the BAR and Date: 30 Julie 2013 9:35:00 vm. SAST Scoping phases of the assessment and they are included, To: Louise Corbett , Nelis together with responses, in Annexure C – Comments and Bezuidenhout Response Report 1 and 2 of Aurecon’s September 2013 Scoping Cc: M Gordon , A B Report. The comments have been included in this report for Abrahams , Howard Hendricks record purposes, as requested by the commentator. , Frans Van Rooyen

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No. Issue Raised by Response from CES EIA team or Hydro SA Subject: PowerPoint Presentation

Ms Corbett Your response to our comment in the CRR regarding the shareholding of Hydro Tasmania, through their SA subsidiary, refers; Attached is a presentation which was given to the various stakeholders and which was forwarded to us as part of the suite of documents. On pages 32 and 33 the company ownership is laid out and the Hydro Tasmania SA shareholding is discussed. On page 28 the remote control of this activity from Hydro Tasmania's control room is discussed in relative detail. Hopefully this places some of our concerns in context, bearing in mind that Hydro Tasmania was responsible for the Lake Pedder National Park debacle/disaster. Regards Kobus van Coppenhagen 67. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, disappeared and we want to put it back on record. We will Daberas, comment by Thank you for our submission (9) relating to the proposed be sending many e-mails in the next few days. (9) e-mail, 30 May 2015 Riemvasmaak Run-Of-River Hydro Power EIA. These are our comments on the DSR I hereby acknowledge receiving your comments for the record Kobus van Coppenhagen 0836564498 and inclusion in the environmental impact assessment study. Begin forwarded message: Sincerely, From: Kobus van Coppenhagen Shawn Johnston Date: 27 Augustus 2013 4:40:26 nm. SAST To: M Gordon , A B EAP’s response: Abrahams , Louise Corbett These comments were submitted to Aurecon during the BAR and , Nelis Bezuidenhout Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and Cc: Howard Hendricks , Response Report 1 and 2 of Aurecon’s September 2013 Scoping Gene Visser , Giel de Kock Report. The comments have been included in this report for , Frans Van Rooyen record purposes, as requested by the commentator. , Mike Knight , Fritz Oosthuizen , Gawie Niewoudt , Nardus du Plessis Subject: Proposed Augrabies Hydro Power Plant, Northern

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No. Issue Raised by Response from CES EIA team or Hydro SA Cape

To whom it may concern The above project with incomplete reference no 14/12/16/3/3/1/681 (see DEA letter dated 18/06/2013) refers; We have become frustrated with the inability of AURECON to provide the correct documentation for the proposed project timeously and realise that they might not be able to present a properly structured application for comment by the public and consideration by the relevant authorities. We have requested a copy of the current "valid" application on more than one occasion, but have received none so far. We believe that currently, there is no valid application, lodged with DEA, except for informal discussions which were followed up by a letter from DEA, dated 18/6/2013, which suggest that the applicant resubmit a revised application. The AURECON letter of 3/6/2013 and DSR page 13 refers to three applications which were lodged by RVM 1, which is incorrect, since the applications were lodged by RVM1Hydro Electric (Pty) Ltd, RVM 2 Hydro Electric (Pty) Ltd and RVM 3 Hydro Electric (Pty) Ltd, respectively. We do not doubt the technical ability of AURECON, but the document trail is very becoming difficult to follow, especially if you lodge an objection and want refer to the correct entity. We are challenging the perception that the process is beyond the application phase as proposed in page 16, because the other 2 applications were made in the names of other legal entities. We are thus objecting to the continuation of this process on the grounds that currently there isn't a valid application with either DEA or DWA. Site visit: We have requested months ago that a meeting be held inside the National Park and that was also requested by the SANParks representative during the public meeting of 5/8/2013. Unfortunately it could not be accomodated and no date has been put forward yet, but a meeting with another party in the area was scheduled by AURECON for 22/8/2013. We did request SANParks to allow us to visit the proposed site. This was arranged for 20/8/2013 and on arrival at the entrance to the land and also at the "Rhino" gate, only the original RVM1, 2 & 3 applications were found to be on display.

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No. Issue Raised by Response from CES EIA team or Hydro SA The following paragraphs are dedicated to our observations during the SHORT site visit. In the immediate area of the proposed weir, we could clearly observe a large and "noisy" breeding colony of birds, nesting in the trees on a small island. Three nesting/breeding species were observed and it was clear from droppings marking the branches of other trees in the area, that it was not yet fully colonised for this breeding season and that this site was repeatedly used over a long period of time. The species observed were African Darter, White-breasted Cormorant and Reed Cormorant, none of which are mentioned in your avifauna discussion on p 61 of the DSR. A number of other birds were observed and heard(hadeda) but we did not have time to spare. Many large rocks in the area were also exposed, which would be permanently flooded by a water level increase of 2,5 meters. We also noticed otter droppings with crustacean residue on the river bank. We do not exactly know how the environment would be affected by the clearing of virgin riverine habitat and the interference with the flow and stratum of the river bed and bank. NEMPAA regulation 1061; article 41, specifically prohibits disturbance of a watercourse inside a National Park. A SANBI report of 1995 mentions 192 species of birds for this area. Due to the topography, exibiting many drainage courses crossed at right angles by the vehicle track and variations in elevation it became apparent that it would be virtually impossible to integrate the water conduit structure into the existing terrain, without modifying it substantially. It is worthwhile to mention that there is no existing "road", which just needs to be "widened" and that the construction of a road alone would alter the terrain substantially. The track also displays a lot of hoofprints of animals, but we did not attempt to establish their movements. The northern section of the National Park would practically be cut into two fragments by this development and considering the long continuous length of the underground conduits, the linear disturbance would be up to 10 times the length of eg. the proposed Boegoeberg Hydroscheme. This disturbance would also become a new seedbed for the propagation of invasive plants eg. Prosopis spp., all of which have recently been cleared in this section of

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No. Issue Raised by Response from CES EIA team or Hydro SA the National Park. Revegetation as proposed in p 29 of DSR is not possible without irrigation since the average rainfall in this area is only 124,4mm per annum (std. dev=73,47mm)(SANBI report), not 251 mm as in DSR p 54 and summer temperature can exceed 40deg C, so daily irrigation is required (annual evaporation is >3000mm). A SANBI report also refers to the fact that recruitment of plants is episodic rather than a regular occurence, which really makes every existing plant specimen valuable. We urge the applicant to arrange a site meeting and to indicate exactly where the various elements would be sited for both options and it would be quite in order if DEA and DWA inspect this terrain at the same time. It would be pertinent to note that there is still a resident group of the rare Mountain Zebra in THIS SECTION of the National Park, amongst many animals. Although black rhino were re- introduced 20 years ago the area was never fenced with electric wiring and to prevent animals such as girrafe from taking flight, during construction it would be prudent to make electric fencing of the whole northern section of the Park a priority. A SANBI report mentions 51 species of mammals and a total of 68 amphibians and reptiles. We have previously referred to the fact that only specialists know where and how to observe many of the creatures in this area, eg scorpions, reptiles, etc. In a 17 m wide linear construction corridor as envisaged in the DSR p 29, a large percentage of this biota would be destroyed unwittingly. During the short visit one does become aware of an aire of solitude and the large scale disturbance envisioned would would harm it irreversibly. The number of cultural sites along both routes are a "red flag" and the possibility of objections by individual families at any stage before or after commencement would cause serious problems. Waste, dust and noise: The activity would generate at least 160 000 cubic meters of solid waste, which cannot be stored on site and surely the stockpiling of this waste must get due consideration, since there is no recognised dumping site currently available. Where would the aggregate batching plants be located and how will air quality and spillages be managed in that area. According to Mr N Theron (5/8/2014) only 3 truckloads of waste would leave

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No. Issue Raised by Response from CES EIA team or Hydro SA the site per day, which would leave more than 100 000 cubic meters still on site after 3 years. The notion of bringing a crusher onto the site (p31) is an indication of a very short memory. Ownership and water. Restoration of the site would be impossible by any means and how would disputes regarding ownership be resolved in the case of default by the developer, ie if the price of renewable energy falls drastically and less power is generated due to a lack of water, which we have predicted already, because no water balance determination was done for this application, which requires 3,2 million cubic meters of water/day. Our contention is still that the project would not be sustainable in the long term because the quantity of water constantly available is the paramount requirement for this project to succeed. The EAP has noted in the CRR regarding our concern about water availability; that any new use in future other than the current would have to take the "requirements" of the hydro power station into consideration, but the applicant does not want to apply for a certain quantity. What other rights are assumed to be conferred to the applicant which could supercede owners rights or which could transfer responsibility to land owners in the case of neglect by the applicant or the remote operator Hydro Tasmania? Alternative site: The applicant did also apply for the Neusberg and Boegoeberg shemes, which are the logical alternatives for the Augrabies area. These 2 schemes would give the applicant approximately 30% of the initially allocated quota of 75MW for small hydro, without proven capability or previous track record in this business. Is Hydro Tasmania aware that it will be held responsible for any damage caused by remote plant operation and safety aspects and that RVM 1 cannot/shouldn't be able to indemnify them? We do not object to the other projects in Neusberg or Boegoeberg in principle, because they are outside a National Park. Alternative technology: Mr F. Oosthuizen did mention in the meeting of 5 August 2013, that there is a large "brown field site" available, in the form of

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No. Issue Raised by Response from CES EIA team or Hydro SA roofs of existing structures in Augrabies, (or for that matter Riemvasmaak), onto which PV panels could be installed. Alternatively the the use of solar trough technology, PV panels or Stirling engines in a dedicated area of Riemvasmaak would be a better solution in most aspects, but as Mr. N Theron has stated in a meeting: he is only interested in developing hydro generation facilities; thus, those alternatives are not even an option to be considered. Any of the above would also be more enabling to the Riemvasmaak community and will give them a sense of ownership. Declaration of interest: Is AURECON responsible for the engineering design of the proposed scheme and what is the value of that service in the event that the project don't proceed.? DSR page 21 refers to the assumption that all information from the client is correct and unbiased. The EAP must assess this information and comment as they do on all other comments. The client is not an expert in hydro technology and is using the technology base of Hydro Tasmania, which is probably the Project Sponsor as envisaged in the Equator Principles documents. We want to recommend that the following documentation also inform the applicant over and above those mentioned in page 6 of the DSR. National Environmental Management: Protected Areas Act no 57 of 2003 and Regulation 1061as published in the Regulation Gazette no. 28181 of 28 October 2005; With specific reference to; Interference with soil or substrate as defined in article 39, Removal and dumping in water area as defined in article 41, Restriction or prohibition of the use of biological resources as defined in article 45, Restriction or prohibition in land use as defined in article 46, As well as any other applicable regulation in this publication or the Park Rules and Management Plan It is a matter of convenience to ignore this legislation and management rules and regulations which are specifically applicable and binding for the management and continued existence of our National Parks. SANParks also have a large number of specialists in their employment and their inputs

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No. Issue Raised by Response from CES EIA team or Hydro SA should be decisive in the final outcome. SANParks publications: A Framework For Developing And Implementing Management Plans For South African National Parks (April 2008). Stakeholder Participation In Support Of Developing And Implementing Management Plans For South African National Parks (December 2009). South African National Parks Week (information booklet) states on page 6; Augrabies Falls National Park "The park was initially proclaimed to conserve a small area of GEOLOGICAL INTEREST around the Augrabies Falls" Our note: The Augrabies Falls should be considered as a singular geological entity, worthy of protection for posterity. Very little of the riverine habitat which is unmodified and functions naturally, does remain. IUCN publication: Guidelines For Applying Protected Area Management Categories, edited by Nigel Dudley; discuss on p66 the preservation of Geodiversity as a separate category for National Parks but also states on p67 that geodiversity can be protected under all categories. S A Council for Geoscience publication : GEOclips vol 20 June 2007: back page; "We are currently witnessing a worlwide awareness of the importance of conserving and promoting sites and regions of geological and mining interest for the tourism business," Department of Environmental Affairs website: Environmental Indicators: "Grassland, Thicket and NAMA-KAROO biomes have the highest proportion of under-protected ecosystems." Department: Government Communications and Information System Pocket Guide to South Africa 2010/2011 Page 208: Environment, Conservation Areas : reporting on governments strategy to expand conservation areas from 6% to 10 % and that management categories for protected areas in SA conform to accepted categories of IUCN. Page 229; Tourism, Northern Cape: (the introduction to this section is recited) "The Augrabies Falls National Park, with its magnificent falls

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No. Issue Raised by Response from CES EIA team or Hydro SA pressing through a narrow rock ravine, REMAINS THE MAIN ATTRACTION OF THE NORTHERN CAPE." The following concepts of the Equator Principles and IFC Performance Standards refer; This is definitely a category A project. Project Sponsor ... Hydro Tasmania? Is "Effective Control", which is required for "unlisted countries" demonstrated by remote operation of the facility, which in this case would be an operational control room of the Tasmanian government agency, Hydro Tasmania. Indigenous people : project info and approval. It is quite interesting that the equity providers put great emphasis on this aspect, but the applicant only introduced the project to the trust decision makers and only started to inform the community at a very late stage. Finally, the method of integrating Carbon Pricing/Credits in the financial model of the business should be published. It is a matter of public knowledge that businesses like Hydro Tasmania depends heavily on Carbon Price subsidies to make it profitable. 70% of the Hydro Tasmania profit of approximately AU$ 100 million/pa in the last 2 years (CRR comment 10.3) were contributed by carbon pricing on the National Energy Market in Australia. The carbon footprint of large hydro dams can be very substantial due to methane release and it does not merit carbon crediting. The Carbon Price/Credit system should also be viewed as a short term initiative to promote "renewable energy" but that funding will ultimately be spent on carbon capture and storage or conversion projects. The consultant deliberately ignored our objection regarding public notices which does not indicate the location of the project within a National Park and that is unacceptable and our objection in that regard remain. Kobus & Hannecke van Coppenhagen 68. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, Thank you for our submission (10) relating to the proposed disappeared and we want to put it back on record. We will Daberas, comment by Riemvasmaak Run-Of-River Hydro Power EIA. be sending many e-mails in the next few days. (10) e-mail, 30 May 2015 I hereby acknowledge receiving your comments for the record We were not able to access the FSR FOR THE WHOLE and inclusion in the environmental impact assessment study. COMMENT PERIOD AND ASKED FOR EXTENSION WITH Sincerely,

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No. Issue Raised by Response from CES EIA team or Hydro SA NO RESPONSE, WHICH IS RED FLAG. Shawn Johnston Kobus van Coppenhagen 0836564498 Begin forwarded message: EAP’s response: From: Louise Corbett These comments were submitted to Aurecon during the BAR and Date: 09 Oktober 2013 7:43:14 nm. SAST Scoping phases of the assessment and they are included, To: Nelis Bezuidenhout together with responses, in Annexure C – Comments and , "Kobus van Response Report 1 and 2 of Aurecon’s September 2013 Scoping Coppenhagen" Report. The comments have been included in this report for Cc: Simon Clark record purposes, as requested by the commentator. Subject: RE: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW Dear Kobus As noted on site today there will still be further opportunities to comment on the EIA Process. However, should you still wish to comment on the FSR you are welcome to do so. We will then forward your comment to DEA for their information and we will include and respond to it in our next report (the Draft Environmental Impact Assessment Report, unless DEA require us to revise the FSR). Kind regards Louise Louise Corbett

From: Nelis Bezuidenhout Sent: Wednesday, October 09, 2013 8:03 AM To: Kobus van Coppenhagen Cc: Simon Clark; Louise Corbett Subject: RE: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW Dear Mr Van Coppenhagen Please find attached the email correspondence with regards to the matter in your email below. The first email was sent on 23 September 2013 (11h32) followed shortly by a follow-up email (15h23). Kind Regards Nelis

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No. Issue Raised by Response from CES EIA team or Hydro SA

From: Nelis Bezuidenhout Sent: Wednesday, October 09, 2013 8:03 AM To: Kobus van Coppenhagen Cc: Simon Clark; Louise Corbett Subject: RE: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW

Dear Mr Van Coppenhagen Please find attached the email correspondence with regards to the matter in your email below. The first email was sent on 23 September 2013 (11h32) followed shortly by a follow-up email (15h23). Kind Regards Nelis

From: Kobus van Coppenhagen [mailto:[email protected]] Sent: Wednesday, September 18, 2013 12:23 PM To: Simon Clark Subject: Re: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW Good day Simon Thank you for the e-mail, but the FSR & several other documents are not yet posted to the website. Would you be so kind to inform us when this has been posted? Regards Kobus van Coppenhagen 0836564498

On 17 Sep 2013, at 16:44, Simon Clark wrote: Dear Sir/ Madam PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK (REMAINDER OF FARM NO. 497 AND PORTION OF FARM NO. 498), ON THE ORANGE RIVER IN THE VICINITY OF AUGRABIES FALLS NATIONAL PARK, NORTHERN CAPE RVM 1: DEA Ref: 14/12/16/3/3/1/681;

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No. Issue Raised by Response from CES EIA team or Hydro SA NEAS Ref: DEA/EIA/0001403/2012; AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW

The abovementioned project refers. This email serves to notify I&APs of the availability of the Final Scoping Report (FSR) for the above mentioned project for comment. 1. Introduction Following the comment period on the DSR, the Final Scoping Report (FSR) was compiled. The FSR includes comments and concerns that were raised by Interested and Affected Parties (I&APs) during the comment period of 40 days which stretched from 19 July 2013 until 28 August 2013. 2. Changes made to FSR This FSR is an update of the DSR, including additional information on the current status of the public participation process and amendments made in light of some of the comments made. Substantive changes to the Draft Scoping Report are reflected as underlined text, while deletions are reflected with strikethrough text. For your convenience we have attached the non-technical summaries (English & Afrikaans) to this email. The following annexures have been updated: Annexure B (includes updated database and proof of I&AP correspondence); and Annexure C (includes Comments and Response Report 2 and comments received). 3. Way forward 69. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, Thank you for our submission (11) relating to the proposed disappeared and we want to put it back on record. We will Daberas, comment by Riemvasmaak Run-Of-River Hydro Power EIA. be sending many e-mails in the next few days. (11) e-mail, 30 May 2015 I hereby acknowledge receiving your comments for the record Comments on FSR and inclusion in the environmental impact assessment study. Kobus van Coppenhagen 0836564498 Sincerely, Begin forwarded message: Shawn Johnston From: Kobus van Coppenhagen Date: 10 Oktober 2013 2:01:30 nm. SAST EAP’s response: To: Louise Corbett , These comments were submitted to Aurecon during the BAR and Danie Smit , A B Abrahams Scoping phases of the assessment and they are included, together with responses, in Annexure C – Comments and

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No. Issue Raised by Response from CES EIA team or Hydro SA Cc: Howard Hendricks howard.hendricks sanparks.org , Response Report 1 and 2 of Aurecon’s September 2013 Scoping Gene isser ondpoort gmail.com , M Gordon Report. The comments have been included in this report for mgordon environment.gov.za , Kallie Naud record purposes, as requested by the commentator. , "Dr. Hanneline Smit- Robinson" , Charles Norman Subject: Comments on the Final Scoping Report for the proposed Hydropower scheme inside the Augrabies Falls National Park

To whom it may concern; The above mentioned application with ref no 14/12/16/3/3/1/681 as per DEA letter of 18 June 2013 refers; The FSR only became available on the AURECON website 1 week late, which allowed very little time for perusal of the documents. The need to comply with government's optimistic targets for renewable energy generation according to the REIPPP initiative, resulted in applications with large gaps and little benchmarking for the Competent Authorities against which to base decisions. Some of the targets should be viewed as arithmetical exercises or estimates, because they seem to be random, considering conventional knowledge. The pressure which is created by this scenario is an international phenomenon and resulted in some regrettable decisions. We had the privilege to visit the proposed site on 9 October and even though the applicant went to great lengths to confirm the seemingly innocuous nature of hydro-electricity generation, it became even more evident that such a development would result in unacceptable cumulative impacts, which we have previously highlighted to the Competent Authority, the applicant/Hydro Tasmania and the consultants. The habitat involved is the only remaining relatively unspoiled portion of the river before the Augrabies waterfall and therefor irreplaceable and it would be an administrative error for the competent authority to allow the process to continue or to grant environmental authorisation at any time in future. The ICPDR report which established twenty "Guiding Principles on Sustainable Hydropower Development in the Danube Basin" confirms our notion that National Parks (and it buffer zones)

Coastal & Environmental Services 86 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA should not be subject to new hydropower developments and DEA should adopt it as a benchmark for the consideration of applications. We suggest that the Competent Authority should consider the environmental authorisation for the Neusberg scheme as the granting of the alternative to Augrabies/Riemvasmaak site, as provided for in the regulations. We also suggest that the proposed Boegoeberg scheme should be viewed as the second alternative, both of which are located outside of the buffer zones of the National Park and thus not fatally flawed in that regard. We record our objection to the the granting of environmental authorisation for this project and have furnished reasons in previous comments. We also record our objection to the granting of a water licence for the diversion of up to approximately 3,2 million cubic meters/day, for a reach of approx. 9 km along the Orange river inside the National Park. The RVM 1 application to DEA does not reflect that the applicants are applying for a water license as indicated on page 8 (section 3.2 ...... N/A) of the application, anyway. If the applicant does not read the explanatory notes (5) on page one, regarding cautious use of the term N/A, even after directing them to it, it is not possible to predict how they would interpret other documents/directives. Mr Christoff Le Grange of Hydro Tasmania is well aware of the "contested border" situation in the Lower Orange river valley and which has led to the launch of the LORI TFCA in 2008 by the Peace Parks Foundation, JMB and SA and Namibian government agencies and to which some parties including us, are still committed as recorded in the AFNP management plan which was recently approved by the Minister of Environmental Affairs. This management plan clearly underlines the desire of SANParks to change land use from agricultural (grazing) to formally "protected area" (in appropriate areas) in partnership with voluntary participants, in an effort to conserve a representative portion of the Nama-Karoo biome which is currently under-protected, thus classifying it as as a critical biodiversity area according to "South Africa's National Biodiversity Strategy and Action Plan; 2005, page 101 and DEA Environmental Indicators. This portion of the National Park land is already fragmented by

Coastal & Environmental Services 87 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA a road servicing the Riemvasmaak area, which would be further exacerbated by the linear disturbance of the proposed project. There are several potential solutions to satisfy the need for the generation of renewable energy and empowerment in the Riemvasmaak area, which would ultimately be more beneficial to the community, but it is the subject of another forum, since the applicant is only interested in developing hydroschemes. Regards Kobus van Coppenhagen 70. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, Thank you for our submission (12) relating to the proposed disappeared and we want to put it back on record. We will Daberas, comment by Riemvasmaak Run-Of-River Hydro Power EIA. be sending many e-mails in the next few days. (12) e-mail, 30 May 2015 I hereby acknowledge receiving your comments for the record Regards and inclusion in the environmental impact assessment study. Kobus van Coppenhagen Sincerely, From: Kobus van Coppenhagen [mailto:[email protected]] Shawn Johnston Sent: 02 March 2014 09:09 AM To: Louise Corbett; Danie Smit; M Gordon EAP’s response: Cc: Howard Hendricks; Dr. Hanneline Smit-Robinson; Kallie These comments were submitted to Aurecon during the BAR and Naud Scoping phases of the assessment and they are included, Subject: Application for Hydroscheme in Augrabies Falls together with responses, in Annexure C – Comments and National Park (AFNP) Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for Miss Corbett record purposes, as requested by the commentator. We have approached the Australian Public Corporation, Hydro Tasmania and also the Deputy Prime Minister of Tasmania Mr. Bryan Green, to inform them of the potential impact of a hydroelectric scheme on our National Heritage, but they chose to ignore all the issues and referred to the administrative process under way in South Africa. However, now they cannot claim innocence due a lack of knowledge/information. The Tasman Government has previously deproclaimed a National Park in order to erect a Hydro scheme and then subsequently proclaimed it as a National Park again. This type of activity would be referred to as "Greenwash" according to the "A to Z of Corporate Social Responsibility" (Visser, et al, p.248) and this is exactly what they want to repeat in South Africa 40 years later. We have previously referred to the financial viability of the

Coastal & Environmental Services 88 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA proposed Hydroscheme, because a low Internal Rate of Return (IRR) would not be attractive to investors, especially the local community, who seems to be "locked" in due to preconditions. We need replies on the following questions; What is the projected real IRR for this project, based on the REIPPP ? Is the applicant intending to apply for certification of the project as "additional" according to the rules of the the *UNFCCC, Clean Development Mechanism? Considering the information in the opening paragraph, it is certain that this application cannot qualify, or be accepted for "additionality" under the CDM rules. Did/will the applicant receive any public funds from an *Annex1 Party for this or any of the other hydroschemes, eg. Neusberg Hydroscheme ? Has the feasibility study for the project been conducted internally or by an independent authority? Please confirm the name of the entity which conducted the feasibility study and whether a case of conflicting interests could be established, from your impartial viewpoint? Our contention is that this project and perhaps some of the other Hydroscheme applications needs to be scrutinized carefully for financial viability and the start-up cost burden which is transferred to the local community, whose share is financed by the IDC. There is no sense in making them shareholders in businesses which would hardly be profitable, considering the alternative options in the field of renewable energy. The details of financial transactions and relationship between the developers and contractors and financial beneficiaries should also be disclosed, to ensure transparency. Sustainability of the project: The main factor in determining the long term viability of a Hydroscheme is dependant on the availability of a constant supply of water to guarantee effective operation of the plant. We have referred to large increases in in consumption which was planned, in a previous e-mail to you (Hydrology of the Orange River 10 April 2013), which you chose to ignore. Amongst several issues which we highlighted at the time was

Coastal & Environmental Services 89 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA that there was planning under way to increase the transfer/diversion of water between Catchment Management Areas, with a subsequent increase in consumption of water from the Lesotho Highlands Water Scheme (phase 2) which would reduce the total run-off in the Lower Orange River Valley. Reference to this Phase 2 agreement was made on the Electricity Governance Initiative website on 24 May 2013, that the quantity of water transferred would increase from 24.6 m3/s to 45.5m3/s (~660 m/m3/a) and it would generate 1GW of hydroelectricity. The project is scheduled for completion in August 2020. The consideration of only historical data would thus present a fatal flaw in determining the certainty of supply for a Hydroscheme and should be seen as a misrepresentation to all the other parties involved, especially since you have been informed, but chose to ignore it. It is imperative that a proper water balance determination be made for all the Hydroscheme applications as we have referred to on a previous occasion. Financial viability of this project versus key conservation areas: We want to draw your attention to work which was conducted in 1995 by *Creemers, et al., which concluded that the economic contribution of key conservation areas can rival the projected/potential revenue from a major mining activity, ... with the added benefit of realizing international obligations, as far as conservation targets are concerned and could thus be termed as a "win-win" situation. The status of the Augrabies Falls National Park as a key conservation area and driver of tourism in the Northern Cape is incontestable. We propose that this fact should be one of several overwhelming reasons for maintaining the status quo of the AFNP, rather than the applicant's proposal to rezone and further fragmentation and "privatization" of the northern section of the National Park. In any case there is no precedent for the activities which the applicant is "wishing" to conduct inside a South African National Park, although such precedent does exist in Tasmania. The contribution to the sustainability of a whole network of activities/businesses just by the existence of National Parks is not limited to accommodation income alone, but it is a major

Coastal & Environmental Services 90 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA driver of the local economy spread over a wide spectrum, starting with airlines, car rental, and then drilling down to the smallest establishments located in the countryside. Any deterioration in the perceived value of visitors experience, local or international, will harm the whole "value-chain". Perhaps it is the right time to elaborate on other issues related to the management of National Parks which are covered by Regulation 1061 and it's purpose. The wellbeing of humans are of great importance inside National Parks but special consideration must also given to the needs of fauna which is technically captive inside the the area. Thus any reference to disturbance does also include the disturbance of especially Fauna and explains the "limited" access provided to National Parks. Noise and waste: The EAP elaborates on the fact that noise from the proposed activity might not offend visitors due to being removed from the site by some distance. However, the animals which occur in an area which is essentially a wilderness are easily disturbed and stressed by noise. During the site visit Mr. Le Grange referred to the placement of heavy machines inside the ravine by a large helicopter, the noise of which would be seriously offensive to animals, etc. The proposed dumping of a large portion of the 500 000 tons of waste rock in the small beach area at the "dry falls" is also relevant since National Parks are not zoned to be receptacles for waste! The roads which "only need to be widened" is also a fallacy, since the silt which must be traversed in certain areas, cannot support large equipment and trucks and must be excavated to build a proper road (which is not required for the purpose of the Park) and it would generate a large amount of dust because the area does only receive occasional rain. Due to the lack of reliable financial information in the reports i.r.o. the IRR for this proposal (the BAR document showed a very low estimate of operational income), it would be sensible to refer to the Neusberg Hydroscheme as an example, since there is existing documentation which can be scrutinized and the project is registered by the CDM Executive Board. (The Project Proponent (PP) is also the representative in that application)

Coastal & Environmental Services 91 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA The following quotations from the "CDM Validation Report No. CCL0078/NGCHPP/07022012", conducted by Carbon Check (Pty) Ltd (CCL) (with the page number in brackets) are of particular interest; "The PP has presented the financial unattractiveness of the project activity through investment barrier for which the PP has applied by applying the benchmark analysis (p17: 3.6)." "The pre tax project IRR is calculated as 4.47% (p18)" and in the next paragraph 3.6.5, it continues the discussion to emphasize that the Prime Lending Rate of banks (to its high rated customer) in SA was set at 9%, at the time of the investment(sic) decision. "PP has appointed a competent, experienced Engineering company, ENTURA, well known in the industry, to evaluate the feasibility of the proposed project; based on the initial findings of the engineering company's report /25/ PP approached the lender, Nedbank Capital Limited, ...... (p18: 3.6.6)." The above quotation have relevance, since it would be not appropriate for a company to submit feasibility studies which were conducted internally, by shareholders or potential contractors/beneficiaries, as supporting documents with applications for finance as it could be construed as a conflict of interest. It also seems that public money by an *Annex 1 Party, has been used in this application, as is demonstrated by the submission to the Tasmanian Government Businesses Scrutiny Committee meeting (transcript 3/12/2013). According to the CCL validation report no public funding has been used in this project (p6 /21/, p 10, 27, 35, 36 & 63). The actual amount according to the audit report is AU$ 4.326 m (R 41.52 m ZAR at current exchange rate) which is supposed to represent 25% of the equity in the Neusberg Hydroscheme. It seems that the funds are actually used to pay ENTURA, thus Hydro Tasmania pays itself, according to the submission of Dr. Crean. (Both HT and ENTURA are trading entities of the HEC). Does this "methodology" mean that the company could be dysfunctional? Does HT get a better deal (substantial discount) for its share than other participants? The total cost of the project is estimated at around ZAR 489 m (have seen reference to R 540m?) and 25% would be around

Coastal & Environmental Services 92 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA ZAR 122.26. (Is the project cost inflated?) The following quotations from transcripts of meetings should be enlightening: The above information creates uncertainty as far as the real purpose of some of these projects are concerned. Because the applicant does not own the properties or offer a market related price for leasing it, the whole process should be regarded with suspicion. The applicant is also determining the ToR of investigations and appoint the specialists doing the investigations i.e. the applicant has control over virtually the whole process, which includes audiences with the Competent Authority, which we have not been able to secure after many attempts. This indicates that the administrative process is flawed in most aspects. Reference to the "additionality" of projects in terms of the CDM relates to its financial viability in a real world scenario, i.e. without financial assistance. It is understandable that such schemes can be promoted on private land, but definitely not in National Parks. It is not a win-win scenario! Surely, you must agree that we cannot sacrifice our heritage for a hand-out, which is not even guaranteed. Kobus van Coppenhagen 71. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, Thank you for our submission (13) relating to the proposed disappeared and we want to put it back on record. We will Daberas, comment by Riemvasmaak Run-Of-River Hydro Power EIA. be sending many e-mails in the next few days. (13) e-mail, 30 May 2015 I hereby acknowledge receiving your comments for the record Shawn you have to bear in mind that the EAP/applicant and inclusion in the environmental impact assessment study. "infighting" must have been ongoing since the end of 2013. In Sincerely, the meantime we were preparing for the DEIR which was just Shawn Johnston not forthcoming. We had to "unearth" the applicable documents, which should have been consulted before and EAP’s response: application was lodged. Thus, we are sure that there are just These comments were submitted to Aurecon during the BAR and too many gaps which remain at this stage. At the end we are Scoping phases of the assessment and they are included, referring to a scientific study(which can be downloaded) which together with responses, in Annexure C – Comments and shows that Mega Floods have occurred in the "recent" past i. Response Report 1 and 2 of Aurecon’s September 2013 Scoping The Lower Orange river. Report. The comments have been included in this report for Regards record purposes, as requested by the commentator. Kobus van Coppenhagen 0836564498

Begin forwarded message:

Coastal & Environmental Services 93 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA From: Kobusvc van Coppenhagen Date: 26 Mei 2014 9:09:10 vm. SAST To: Jeanne Nel , Mandy Driver , Peter Bradshaw Cc: Howard Hendricks , Danie Smit , A B Abrahams , M Gordon , Louise Corbett Subject: FEPA Project & "Global-Environmental-Change- Assessment-Aquatic-Ecosystems"

Good day Jeanne, Mandy and Peter We live on the western boundary of the Augrabies Falls National Park and are participating in the expansion of the National Park, to the west. The status of the National Park has been under threat of inappropriate development pressure, due to applications for prospecting rights in 2010 (in the western section) and lately (2012) by an application for the erection of a hydroscheme in the northern section of the Park. The prospecting rights application seems to have "fizzled out" when it became clear that the applicant had no money. The application for a Hydroscheme is another kettle of fish, since the applicants are composed of a South African company with no hydro experience and the infamous Hydro Tasmania (HT), whose hydro schemes in Tasmania are completed and they have a consulting "business" with about 300 employees, with very little work. South Africa, with its potentially lucrative REIPPP, has now become their next target and HT are financing applications for the erection of hydroschemes at sites with hydropower potential, regardless of its land-use zoning. Augrabies is a typical example, as far as their creativity is concerned. They propose that the northern section of the National Park be de-proclaimed to allow for the construction project which would create a river diversion of between 9 and 10 km and then to re-proclaim it, as was done previously in Tasmania. We have sent letters to the CEO of Hydro Tasmania and also to the Deputy Premier of Tasmania, requesting their withdrawal from this application, to no avail.

Coastal & Environmental Services 94 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA There is a substantial body of information which originated in various "spheres" of government and the scientific community, which presents compelling evidence for the protection of the National Park in its current format and for the expansion of its footprint. The documents which are referred to as subject (of which you are co-authors) are a case in point. It refers to the desirability of protecting both banks of a river, which in the case of the Orange river is occurring in Augrabies Falls National Park only. Unfortunately, due to slow data connections, I am not able to download the FEPA maps, which could provide us with valuable information, regarding the conservation value of the river reaches inside the Augrabies Falls National Park. The "Siyanda Environmental Management Framework Report of 2008"(EMF) however, classifies it as environmental control zone 3 and concludes on page 76: "In the instance of the Lower Gariep Alluvial Vegetation, conservation is the only acceptable use of the area because it represents: an endangered vegetation type with a conservation target that can already not be attained anymore due to the extent of transformation that has already occurred; and natural floodplain areas in the river system that is dynamic and subject to natural physical change over time due to the interaction between the alluvial nature of the area and flood events. The water body of the Orange River is the most important element in the area in terms of natural and economic services that depend on it. It is a dynamic and complex system. Any activity that will affect the functioning of the water body should be subjected to an appropriate environmental impact assessment. From a strategic long perspective such activities should be limited to the minimum." And page 74 (we have included the exclamation marks) "Zone 3: Potential high to very high vegetation conservation areas The area covered by this zone has the potential to become core parts of conservation areas that may be necessary in order to meet national conservation targets. It is therefore important that the potential is maintained by keeping these areas as natural as possible.

Coastal & Environmental Services 95 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA Due to the sandy nature and the grain size of the sand that occur in the area, the area is prone to severe wind erosion if the groundcover that acts as a protective layer is disturbed over large areas or in exposed places. "The following management parameters are suggested for the zone: Land uses and activities that are compatible with the zone and may be allowed without further assessment: Nature conservation.'!!!!!!!!!!!!!!!!!!!!!!!!!!! Land uses and activities that may be compatible (depending on the specific nature of land use or activity) and that may be considered in the zone after an appropriate level of impact assessment (as required by law) has been conducted: o Stock farming that does not exceed the carrying capacity of the veld; and o game farming that does not exceed the carrying capacity of the veld.

zone: o Agriculture of any kind; o establishment of towns or settlements (including components thereof) and related infrastructure; o opencast mining and quarrying; !!!!!!! o new tracks, roads, railways, pipelines and cables; and !!!!!!! o all off-road vehicle driving. !!!!!!

o The creation of unnecessary bare earth areas should be avoided at all cost; o The construction or creation of new roads and tracks should be avoided; o exposed bare areas should be paved or be rehabilitated with vegetation cover whenever feasible." Even though this document recommends that any activity inside certain zones/geographical areas can only be considered after being subjected to EIA process, the consultants only conducted a BAR, although they refer to the EMF in their desktop study? We believe that it is imperative that the relevant scientific data, together with its correct interpretation should be provided to the DEA to enable them to make an informed decision. The Renewable Energy Targets have caused

Coastal & Environmental Services 96 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA "some regrettable decisions" in Europe, which has led to the establishment of the Intercontinental Commission for the Protection of the Danube River (ICPDR), consisting of government departments, hydro industry, NGO's and scientists, which drafted the 20 "Guiding Principles on Sustainable Hydropower Development in the Danube Basin(PDF)." Principle 12 states:" In a first step those river stretches are identified where hydropower development is forbidden by national or regional legislation/agreements (exclusion zones). In a second step all other stretches will be assessed using the assessment matrix and classification scheme. Due to the lack of South African guidelines regarding hydropower development, we suggest that these principles should be adopted as a matter of precaution and suggest that you should perhaps consider those opinions in follow-up studies. Also, during our data collection activities, we did come across information which does perhaps explain the existence of the wide flood plain and multiple (dry?) waterfalls which leads into the Orange river ravine. *Apparently, four mega floods of around 27 000 cubic meters/s have occurred in the Orange river basin between 1450-1780 as determined by radiocarbon dating of sediments. As far as we are concerned these are recent events and since the sun is again entering a Maunder Minimum Phase, anything is possible. Several other major events are also described, which as a matter of interest, points to the inevitability of future occurrences. Would it be possible for anyone of you, to provide us with the relevant scientific information for the FEPA Project, as it relates to the Augrabies Falls National Park, and to the Environmental Assessment Practitioner from Aurecon, Louise Corbett, the Competent Authority at DEA mr Danie Smit and mr. AB Abrahams at DWA? We thank you in anticipation of a reply. Regards Kobus van Coppenhagen 0836564498 Augrabies.

*Extreme Floods around AD 1700 in the Northern Namib Desert, Namibia and in the Orange River Catchment, South

Coastal & Environmental Services 97 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA Africa - Were they forced by a decrease of solar irradiance during the Little Ice Age (PDF) Klaus Heine and J rg lkel. 72. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, Thank you for our submission (14) relating to the proposed disappeared and we want to put it back on record. We will Daberas, comment by Riemvasmaak Run-Of-River Hydro Power EIA. be sending many e-mails in the next few days. (14) e-mail, 30 May 2015 I hereby acknowledge receiving your comments for the record and inclusion in the environmental impact assessment study. The Council for Geoscience has removed earthquake data Sincerely, from their website and have NEVER responded to our Shawn Johnston questionnaires after events, which does not reinforce our trust in them as a public institution. We regard them as strictly EAP’s response: commercially oriented. These comments were submitted to Aurecon during the BAR and Regards Scoping phases of the assessment and they are included, Kobus van Coppenhagen together with responses, in Annexure C – Comments and 0836564498 Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for Begin forwarded message: record purposes, as requested by the commentator. From: Kobusvc van Coppenhagen Date: 29 Mei 2014 8:15:02 nm. SAST To: Andrew Hockley , Angus Tanner , Louise Corbett Cc: Danie Smit Subject: Tremors in Augrabies Hi Andrew We were in Upington on business for the whole day and just after arrival at home at about 18h05 today two tremors occurred in succession with a third 5 minutes later. At 18h50 another tremor occurred. This seems to be a repeat of the 2010 events. Are you in Augrabies? The Kai Garib municipality did have public meetings at the time and as far as we know an investigation was launched by them and Hannecke (my wife) spoke to the prof who was in "charge". The issue is that we had a number of rockfalls which occurred and which deposited material in the river bed. The explanation of the Council for Geoscience was really unsatisfactory and simplistic as far as conceptual matters are concerned. We have for example an ablution building at the campsite which was erected about 15 years ago and which is split (walls

Coastal & Environmental Services 98 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA and floor) on a NNE strike and this year after the the 100mm rain event we found on this strike about 400 m to the north an area in the river bed, a few meters wide which was still "bubbling air" 24 hours after the rain, which is really odd. We did phone the neighbor Gene Visser to go and have a look and he confirmed afterwards that it was still happening when he visited the site. This is probably an indication of a very deep seated joint. In that area to the north of that point, a kimberlite dike was encountered inside the diggings of the old tungsten mine workings and a kimberlite pipe occurs some 500 m to the west . (Daberas survey map and the "Geology of the Onseepkans Area" (Moen and Toogood) At that time we did some research and came across another very interesting document of which one page is pasted below; "Controls on post-Gondwana alkaline volcanism in Southern Africa" (PDF)(Moore, et al ) Fig. 4. The alkaline volcanic pipe lineament that extends from the west coast of South Africa into the Zambezi and Luangwa rifts of Zimbabwe and Zambia. The dates available for volcanic rocks on the lineament indicate a systematic increase in age to the NE. Note that the zircon ages only provide an upper limit on the emplacement age, as discussed in the text. The inset shows earthquake epicentres from Reeves (1972), a microearthquake study by Scholz et al. (1976), and epicentres from the National Earthquake information Centre (NEIC: http://earthquake.usgs.gov/regional/neic/). The Kalahari seismicity axis, approximately coincident with the lineament, was identified by Reeves (1972). Epicentres to the north west of the lineament in Botswana lie in the Okavango Rift Zone (Kinabo et al., 2007). Faults are marked in northern Botswana and the Mid Zambezi valley of Zimbabwe and Zambia from Scholz et al. (1976), Ballieul (1979), and Kinabo et al. (2007). Ok = Okavango Delta; Mk=Makgadigadi Pans. Key to pipe clusters: 1. Namaqualand Olivine melilitites; 2. Bushmanland Olivine melilitites; 3. post-Karoo diatremes; 4. Pofadder kimberlites; 5. Ariemsvlei kimberlites; 6. Noeniputs kimberlite; 7. Rietfontein kimberlite; 8. Southern Botswana kimberlites; 9. Kolongkweneng kimberlites; 10. Tsabong-Molopo kimberlites; 11. Khekhe fissure; 12. Mabuasehube kimberlites; 13. Kokong

Coastal & Environmental Services 99 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA kimberlites; 14. Kikao kimberlites; 15. Khutse kimberlites; 16. Gope kimberlites; 17. Orapa; 19: Binga kimberlites and Katete carbonatite; 20. Sengwa kimberlites; 21. Lower Luangwa (Kaluwe) carbonatites; 22. Kapamba lamproites. From this document and the info above you should be able to deduct that there are some geological formations which are deeply weathered and which might not be competent and could contribute to some of these events (Kimberlites weather deeply and easily due to its composition). The Daberas scenario described above is really "generic" of the area since we are located inside a kimberlite province. The "Geology of the Upington Area" (G Moen) p 117-121, discuss the structure of the area in more detail. It is imperative that a geologist engineer (geophysicist) investigate the stability of the site and it's suitability for the proposed installation, from a technical perspective. The cursory comments of the EAP, who was never present, regarding the tremors should be disregarded. A substantial number of insurance claims were lodged for damage sustained, after the events. It is an indication of the lack of engagement with the local community which is confirmation of their lack of understanding of its effect on the community. We have even suggested at some stage that the "thundering noise" generated by these tremors might be another reason for the name Augrabies. Kobus van Coppenhagen 73. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Coppenhagen, Thank you for our submission (15) relating to the proposed Our correspondence with AURECON seems to have Daberas, comment by Riemvasmaak Run-Of-River Hydro Power EIA. disappeared and we want to put it back on record. We will e-mail, 30 May 2015 I hereby acknowledge receiving your comments for the record be sending many e-mails in the next few days. (15) While and inclusion in the environmental impact assessment study. the consultants were not forthcoming with their DEIR we Sincerely, felt the need to point out some relevant information..... Shawn Johnston Kobus van Coppenhagen 0836564498 EAP’s response: Begin forwarded message: These comments were submitted to Aurecon during the BAR and From: Kobusvc van Coppenhagen Scoping phases of the assessment and they are included, Date: 02 Junie 2014 9:39:49 vm. SAST together with responses, in Annexure C – Comments and To: Louise Corbett Response Report 1 and 2 of Aurecon’s September 2013 Scoping Cc: A B Abrahams , Howard Report. The comments have been included in this report for Hendricks , M Gordon record purposes, as requested by the commentator.

Coastal & Environmental Services 100 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA , Danie Smit Subject: Incorrect Assumptions and Statements in the FSR for the hydropower station in Augrabies Falls National Park.

Miss Corbett We were expecting receipt of a copy of the revised "RVM1application" form for the proposed Hydropower scheme, as was directed by the DEA in a letter of 18 June 2013 and which was also requested by us on several occasions. In the meantime you have continued without complying with the instructions of the DEA and we are also still awaiting a response from the director of the DEA regarding the validity of the RVM1 application, considering its limited scope. We believe that currently, the DEA is only "indulging" your activities which are really a waste of public resources (administration) and that DWA has not received a water license application as suggested on the current RVM 1 application form. Your FSR document states on page 81: 5.4.5.3 Impact on Energy Production "The IRP sets out a 20 year electricity plan for South Africa and allows for an additional 123 000 MW of renewable energy in the electricity mix in South Africa by 2030", which is grossly overstated, because the figure estimated in 2010 for TOTAL generation capacity required in 2030 is actually 89 532 MW according to the IRP document, which does include the existing 48 220 MW total SA generation capacity(see B below), without Kusile and Medupi which adds about another 8 400 MW to the mix. The balance of the energy is made up of a variety of generation capabilities which includes renewable energy. Your interpretation of the NEED for renewable energy is thus overstated by a multiple of more than 4 and contextually incorrect. Thus, your Assumptions (p 21; FSR) on which this investigation (bullet 1) is based, are totally incorrect and exposes another fatal flaw in this application. 2.5 Assumptions and Limitations 2.5.1 Assumptions "In undertaking this investigation and compiling the Scoping

Coastal & Environmental Services 101 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA Report, the following has been assumed: The strategic level investigations undertaken by DoE regarding South Africa’s proposed energy mix prior to the commencement of the EIA process are technologically technically acceptable and robust; The information provided by the client is accurate and unbiased; The scope of this investigation is limited to assessing the environmental impacts associated with the proposed hydropower station and connections to the grid. The EIA does not include any infrastructure upgrades which may be required by Eskom to allow capacity in the local grid for the proposed project; and The AFNP Management Plan could be revised to allow for the proposed project, should the potential impacts assessed in this EIA be considered to be acceptable to DEA." Further discussion of IRP; The total generation capacity estimated to be required in 2030 has been reduced in the meantime, to 81 350 MW in the IRP 2010-2030 Update and requirements could be as low as 66 340 MW in certain scenarios, which again includes existing generation capacity. The amount set aside for renewables totals a small fraction of that quantity, which includes imports from INGA and Lesotho Highlands phase 2 (IRP page 32). 7.1.2 The Kobong pumped storage scheme in Lesotho which forms part of the second phase of the Lesotho Highlands Water Project. This facility provides 1200 MW of pumped storage capacity from 2023. This is the phase during which an additional 20,9 M3/s would be diverted/transferred to the Vaal Catchment. Thus, the use of the transferred water (which we have drawn your attention to on two occasions) to create an additional 1200 MW generation capacity, should also be viewed as a more beneficial use of the resource, considering the yield and perhaps as another site alternative for Augrabies and it represents a yield 30 times higher than the maximum of your proposed hydropower station. Future base load energy demand estimates should be considered as very flexible, especially since the consumer cannot be trapped in a spiral of escalation, forever. The

Coastal & Environmental Services 102 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA scenario described in the IRP Update p 33 section 8.0 regarding embedded generation refers; It is expected that up to 30 000 MW of embedded PV energy capacity could be installed in small installations by 2030, which would probably be the largest single contributing sector and government should prioritize training for that industry, due to the massive opportunities, or call on Elon Musk (a South African) who has done exactly that in the USA, by starting up the largest domestic installer of PV panels in that country. The main "danger" with renewable energy projects would be base generation "over-supply" scenarios or reduction in demand, due to the above scenario, which could cause a collapse of the large scale renewable energy installations, due to high financial start-up costs. This scenario is already happening in Australia as reported in the transcription of the Tasmania Legislative Council; Government Businesses Scrutiny Committee meeting for Hydro Tasmania, on 3/12/2013. It states on p16 : If you are unable to find/download this document we could forward a link on request. On top of this it seems that the wind farm industry in Germany and Australia are already facing financial difficulty and Hydro Tasmania made a statement recently, announcing substantial power purchasing agreement losses (AUD 103 million total, projected for period up to 2018-19) and suspension of further wind farm investments (The Australian 10 May 2014). A "pinch analysis" would reveal that if embedded renewable electricity can be fed directly into the grid, the excess could be used for pumped storage or hydrogen generation which could be utilized in vehicles (Toyota has just launched a hydrogen fuel cell vehicle, which is confirmation of confidence in the technology) or other applications. Obviously, the start-up of the "Hydrogen Economy" as proposed in the 1970's is overdue and needs due consideration by the authorities. We have also forwarded a copy of our request for FEPA (Freshwater Ecosystem Protection Areas) classifications, for your information and we request that you should consider the document as part of the comments provided by us for the FSR. The following information from the SIYANDA Environmental

Coastal & Environmental Services 103 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA Framework Report 2008 (EMF) deals with renewable energy generation in the Northern Cape and the document should be enlightening to you and the applicant; See also" Augrabies Weelde/Splendour " p33 by Prof. P. vd Walt which refers to the above-mentioned "tug-of-war" which occurred in the past between ESCOM and conservation authorities and which was only settled by government intervention, which led to the proclamation of the Augrabies Falls National Park on 5 August 1966. Instead the EMF refers to renewable energy opportunities on page 55; 2.3.6 Energy Use The rest of the article is not included for the sake of brevity. "Hydropower case studies and best practice examples" (PDF) of the ICPDR also highlights Norwegian best practice on p12; Norway Description: "Protection Plans for Watercourses The conflict between hydropower development schemes and environmental considerations brought about a need for protection plans for rivers and lakes as well as for master plans concerning hydropower development. Protection plans for inland waters were initiated in the early 1970s. By these plans, 388 watercourses (covering 40% of the catchment areas of Norway) have been protected against hydropower development and the hydro power production potential in these watercourses is close to 50 TWh. The purpose of the protection plans is to safeguard complete watersheds to maintain the environmental diversity stretching from the mountains to the fjords. The current plans only protect against hydropower, but a restraint policy should also be exerted towards other kinds of development activities. However, other activities may be permitted in accordance with the licensing system pursuant to the Water Resources Act. This may sometimes result in conflicting situations, where a protected watercourse/watershed actually can be exploited for other uses than hydropower, uses that can have even greater environmental impacts...... " To conclude; We have previously referred to the inability of Aurecon to

Coastal & Environmental Services 104 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA provide accurate and contextually reliable information for comment by the I&AP's and consideration by the Competent Authority and now we propose in the interest of administrative fairness, that this application must finally be closed by the Competent Authority and that all other Hydropower scheme applications which are not "linked" to existing infrastructure, be suspended until government has given proper consideration to the protection of South Africa's threatened rivers. Regards Hannecke & Kobus van Coppenhagen 74. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, Our correspondence with AURECON seems to have Coppenhagen, Thank you for our submission (16) relating to the proposed disappeared and we want to put it back on record. We will Daberas, comment by Riemvasmaak Run-Of-River Hydro Power EIA. be sending many e-mails in the next few days. (16) e-mail, 30 May 2015 I hereby acknowledge receiving your comments for the record Kobus van Coppenhagen 0836564498 and inclusion in the environmental impact assessment study. Begin forwarded message: Sincerely, From: Kobusvc van Coppenhagen Shawn Johnston Date: 05 Junie 2014 2:02:59 nm. SAST To: Lenka Thamae EAP’s response: Cc: Louise Corbett , These comments were submitted to Aurecon during the BAR and Danie Smit , M Gordon Scoping phases of the assessment and they are included, , A B Abrahams together with responses, in Annexure C – Comments and , Howard Hendricks Response Report 1 and 2 of Aurecon’s September 2013 Scoping Report. The comments have been included in this report for Subject: Hydropower installation in Augrabies Falls National record purposes, as requested by the commentator. Park & ORASECOM IWRM Plan.

Good day sir We live in the Lower Orange River Valley on the western boundary of the Augrabies Falls National Park and are participating in the Range Expansion Project of the Park to the west. The introduction of Renewable Energy Targets (RET) to combat climate change and eventually reduce carbon emissions, have created worldwide opportunity and "floods" of applications for renewable energy installations. The RET's have in general not been aligned with existing legislation and regulatory frameworks, which has led to some regrettable decisions especially regarding hydropower installations. It seemed as if the generation of renewable energy was of

Coastal & Environmental Services 105 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA overriding concern, to other activities and has even led to applications inside protected areas. In Europe it had a similar effect and the need for strategic planning prompted governments to direct investigations into the matter as quoted below from ICPDR document "Guiding Principles on Sustainable Hydropower Development in the Danube Basin"(PDF) page ll ; "Aware of the fact that hydropower plants offer an additional reduction potential for greenhouse gases but recognizing as well their negative impacts on the riverine ecology, the Ministers of the Danube countries asked in 2010 for the development of Guiding Principles on integrating environmental aspects in the use of hydropower in order to ensure a balanced and integrated development, dealing with the potential conflict of interest from the beginning. The “Guiding Principles on Sustainable Hydropower Development in the Danube Basin” have been elaborated in the frame of a broad participative process, with the involvement of representatives from administrations (energy and environment), the hydropower sector, NGOs and the scientific community. The “Guiding Principles” are primarily addressed to public bodies and competent authorities responsible for the planning and authorization of hydropower but are also relevant for potential investors in the hydropower sector as well as NGOs and the interested public. The Guiding Principles have the character of recommendations and do not exert any legally binding force. As a follow-up, implementation is recommended to take place on the national level, accompanied by a further exchange on experiences with regard to administrative processes and technical provisions." We request that ORASECOM consider the possibility of incorporating a similar set of guidelines for the 10 year IWRM Plan. We noted that ORASECOM and ICPDR are International Cooperating Partners, which would make the sharing of such technical knowledge legitimate. Please note that we do not want to fabricate a case against hydropower developments but rather that protected areas should not be legitimate targets for renewable energy projects. We thank you for your consideration.

Coastal & Environmental Services 106 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA Regards Kobus & Hannecke van Coppenhagen 0836564498 If you need specific information we would gladly forward it for your attention. If we need to correspond with another person at the secretariat, we would appreciate it if you would forward the contact details. 75. Dr McDonald and Shawn Johnston Kobus van On 29 Mei 2015, at 1:23 nm., Dave McDonald You suggested that I should phone later on, without stating Coppenhagen, wrote: that it would be "irregular" to speak to me, which seems almost Daberas, comment by Dear Mr van Coppenhagen, irregular? My question on the phone was quite simple and for e-mail, 29 May 2015 It would be irregular for me to answer your queries concerning my clarification only; botanical studies at Augrabies directly and would be a breach of We noticed that you were not contracted to EOH CES, for the the environmental process protocol if I were to do so. botanical survey and we wondered how the haul roads from Please would you direct all your queries in writing to Mr Shawn the base of the ravine could have been investigated by you if it Johnston ([email protected]) who is dealing with all was a new idea, according to the consultants? queries and comments from I & AP's. If necessary he would This requires a simple yes/no. direct you queries to me for a response. However, we do differ from your opinion in the sense that we It is vital that these channels be followed. Yours sincerely, believe that a directly affected party may present a question to Dave McDonald the specialist(in whichever way). This is not about your opinion, but rather a matter of fact and it is material. Shawn, we need this reply, still today. In fact we want to receive a copy of the report as he has presented it to Aurecon. Regards Kobus van Coppenhagen 0836564498 76. On 29 May 2015, at 2:26 PM, Kobus van Coppenhagen wrote: Kobus van Dear Mr. Kobus van Coppenhagen, Good day Shawn Coppenhagen, Thank you for our e-mail and request for information regarding You are aware that the comment period for the DEIR is closing Daberas, comment by the Ravine Haul Road Impact Assessment and the botanical soon, thus we would require a response today regarding the e-mail, 29 May 2015 assessment. I will request a response from the environmental Ravine Haul Road Impact Assessment, plus a copy of the impact assessment practitioner and the relevant specialist. I Botanical Report as presented to AURECON, in order to see if hereby acknowledge receiving your comments and request. it was done to suit the new project layout. As a matter of Sincerely, interest, could you forward some reference regarding this Shawn Johnston environmental process protocol, which the learned Dr. is referring to. EAP’s response We are still waiting for the minutes of the "FSR All specialist reports associated with the Draft EIA Report were acceptance"meeting with DEA. made available to the commentator, on a hand-delivered CD, Regards since he claimed that his internet connection was insufficient to Kobus van Coppenhagen download material from CES’s website.

Coastal & Environmental Services 107 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA 77. Hallo Shawn Kobus van Geagte Mnr Kobus van Coppenhagen, Die fokusgroep vergadering het blykbaar nie plaasgevind nie. Coppenhagen, Ek sal opvolg rondom die fokusgroep vergadering en terug kom Die bure het lokale gastehuise opgespoor wat blykbaar geen Daberas, comment by daaroor. kennis dra van hierdie aansoek nie. Ons voorstel is dat julle 'n e-mail, 02 June 2015 Mr. van Coppenhagen, hiermee bevestig ek, dat ek al die vergadering by nie Park reel vir die mense op 'n tyd wat hulle kommentaar ontvang het van u en u vrou, Hannecke van pas. Bevestig asb dat jy ons kommentaar x 2 ontvang het Coppenhagen. vanaf Hannecke v Coppenhagen se rekenaar. Ons het dit in Die uwe, elk geval wyd versprei. Shawn Johnston Groete Kobus van Coppenhagen 78. Good day Shawn Kobus van Dear Mr. Kobus van Coppenhagen, The e-mail from messrs Rowlston and Smit regarding consent Coppenhagen, Thank you for your e-mail regarding consent and the e-mails for the above activity refers; Daberas, comment by forwarded to you by Mr. Bill Rowlston. I hereby note you It seems as if mr. Rowlston is attempting to "choke" our e-mail, 6 June 2015 comments and will clarify it with the environmental impact requests as "concerned citizens" for the clarification regarding assessment practitioner. the procedures (other than stated in NEM:PAA) to be followed Sincerely, by the applicants in order to obtain consent/permission for the Shawn Johnston activities planned inside the National Park. It is correct that this permission should be obtained prior to the commencement of EAP’s response the activity and we are quite happy with the instruction of the This comment was also received from Mrs Van Coppenhagen DEA, that the applicant should submit this consent prior to the (see the very lengthy Comment 80 below), to which the response submission of the FEIR. This is important since the procedure was as follows, and which is equally applicable to Mr Van for obtaining permission for new activities inside National Coppenhagen’s comment: Parks are laid out in NEM:PAA and its regulations. However The commentator has misunderstood the piece of legislation she one of the specialist reports imply that the applicant has has quoted. The stipulation in NEM: PAA s50(5) is that “No obtained legal advice which states that the management plan development, construction or farming may be permitted in a can be changed to suit this project. national park, nature reserve or world heritage site without the Now, we are very interested that this information which is prior written approval of the management authority.” The Act already in the public domain, is also made available to all the does not require the management authority’s approval for the parties since it MIGHT affect the procedures which has to be preparation and submission of an EIA Report for a proposed followed to obtain this permission. For the moment this will development in a national park, only for the implementation of the suffice and we would prefer that you as the facilitator, should development itself. There was no question of the EAP refusing to liaise with the DEA and your client in order to provide us with accept the requirements of the Act or failing to respect legislation, the necessary information, which must satisfy the merely an insistence that it was correctly interpreted. DEA was in requirements of NEM:PAA, its regulations and norms and error in requiring evidence of SANParks’ approval of the project standards for the proper administration of National Parks. before submission of the EIA Report, and has confirmed that its You would have noted that those and other relevant interpretation of the Act’s requirement was mistaken (e-mail documents disappeared from the reference material after the dated 22nd May 2015 from Mr Danie Smit (DEA) to Bill Rowlston submission of the FSR. In the meantime we do insist that the (EOH CES)). A copy of this message has been provided to the applicants do not have SANParks approval for the proposed commentator, but he is evidently unwilling to acknowledge that

Coastal & Environmental Services 108 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA activities and that it must be made very clear in all documents. his interpretation of the Act, which is shared by his wife, was in Regards error. Kobus van Coppenhagen 0836564498 There is no reason that, if the project receives a favourable EA, the AFNP Management Plan cannot be amended to accommodate the project. 79. This row has been left deliberately empty Hannecke van Coppenhagen - Daberas (Draft Environmental Impact Assessment Comments) 80. Sirs, Hannecke van Dear Mrs Hannecke van Coppenhagen, Before commenting, it must be stated even the name of the Coppenhagen, Thank you for your submission dated 31 May 2015 relating to the project is chosen to mislead the general public. The correct Daberas, comment by proposed Hydro SA Riemvasmaak Run-Of-River Hydro Power description is PROPOSED HYDROPOWER STATION IN THE e-mail, 31 May 2015 Station EIA study and draft environmental impact assessment AUGRABIES FALLS NATIONAL PARK,(AFNP) as a large part report. of the footprint and impact of this power station will be INSIDE I hereby acknowledge receiving your comments on the draft AND ON the land of the AFNP. It does not take a genius to report and will forward it to the environmental impact assessment know why the name of AFNP is deliberately omitted. In a practitioner. recent television broadcast it was proudly announced that this Sincerely, project will be built in Riemvasmaak, but no word was uttered Shawn Johnston about the fact that it will be built in a National Park. However, it is clear that the applicant is trying to keep this fact under the EAP’s response blanket as far as possible. Project name: There is no intention to mislead the general public It was confirmed by Mr Rowlston in a recent public meeting or anyone else. The piece of land in question - Remainder of farm that it is in fact a "very big engineering project", with large Waterval No 497 - is clearly stated on the second page of the dumping sites, haul roads, underground pipelines to be Executive Summary of the Draft EIA Report, and later in section blasted through solid rock, a weir, a power house, power lines 2.6 of the report, to be (i) owned by the Republic of South Africa; and what not, IN THE NATIONAL PARK but then he compares (ii) included on the Assets Register of the Department of Public the scope of this project as equivalent to the construction Works, the custodian of all national property; (iii) reserved for the activities for a rest camp, which is very naive because he does National Parks Board (sic); and (iv) included within the not know the mission and purpose of SANParks. boundaries of the Park. In the same part of the report it is clearly In this recent public meeting , Mr Rowlston also confirmed that stated that the intention is to construct approximately 3.6km of the waterfall will be affected for 80% of the time, which in turn the underground headrace, approximately 6km of underground will affect conservation and tourism aspects within the Park power line, and approximately 6km of unpaved access road and the surrounding establishments, but it seems that the across this piece of land. The power station itself will not be consultant cannot accept the fact that at a project like this will constructed on this property, but will be situated on the adjacent have a serious impact. How would small establishments and Riemvasmaak land. tour operators mitigate a reduction in tourist numbers? Comparative size of the project: The commentator is correct in We have tried to put all our concerns forward to the competent her assertion that Mr Rowlston described the construction of the authorities and to the applicants since the onset of the hydropower project as a “very big engineering project”. She is, application in 2012 but have now discovered that it however, mistaken in saying that he likened the hydropower conveniently disappeared with the appointment of EOH CES. project to the construction of a rest camp in the park. What The applicants are using the promise of employment and Rowlston actually said was that he believed that tourists at the

Coastal & Environmental Services 109 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA electric power to the Riemvasmaak community as leverage for time the rest camp was constructed understood the need for it, this hideous project. although it would have directly and physically inconvenienced The fact is, as stated in the original Socio-•‐ Economic Tourism them, because they understood that it would ultimately improve (Urban – Econ 2012) Impact Assessment page 58 “The poor, the quality of their tourism experience. He went on to say that he disadvantaged groups may not be included in the job creation believed that tourists would also understand the need for the opportunities during the construction phase if local labour is construction of the hydropower project, which will take place in a not used or if the local population does not have the skills to part of the park to which the public is not allowed access, and do the job” and then according to the EIR, after the which is some distance from any part of the park to which public completion, there will be work for not more than 4 local people, access is allowed, because they will understand that the project this just make no sense. I am not sure whether this fact was will improve the quality of life of the people of South Africa and of properly conveyed to the Riemvasmaak people. We all know the area surrounding the park. that promises are easy to make but difficult to keep. Diversion schedule: The Commentator is correct in saying that To make matters worse is the fact that this community will the diversion of water from the Orange River will affect the inherit a financial burden, as it is clear that there will not be Augrabies Falls for 80% of the time. But, as she is well aware, enough water in the future to run this hydroelectric power this is by no means the full story. The actual situation was station, profitably. Again on page 58 it states “Also the poor, carefully explained at the public meeting, and is set out in section disadvantaged groups and future generations often bear a 3.3.1 of the Draft EIA Report, as follows: disproportionate share of the social and environmental costs of  For ±20% of the time no flow will be diverted into the tailrace: large projects/developments without gaining a commensurate  For ±15% of the time (55 days) the river flows at or less share of the benefits”. In an effort to illustrate the risk to the than 30m³/s, so no flow will be diverted into the headrace community we have requested a water balance study from the and the HPP will not operate. start, and have asked for it again at the last meeting. Mr  For ±5% of the time (18 days) the river flows at more than Rowlston could not provide it neither could he explain the fact 800m³/s. At this flow rate it is anticipated that the sediment why this has not been done. The problem for the applicant is loads in the river will begin to increase to such an extent that a water balance study is an integral requirement and will that sediment could be drawn into the headrace, and could show that this project is doomed from the outset, as a result of result in damage to the turbines. No flow will be diverted lack of water, and this is why it is not forthcoming. into the headrace; power generation will be shut down to The other fact is also that this project will be used to keep the prevent damage to the turbines. workforce at HT/Entura on the payroll, regardless of the cost to  For ±45% of the time (165 days, or 5.4 months) river flows the protected environment. This quote from an Australian are between 30m³/s and 90m³/s, diverted flow will newspaper explains the financial position of HT and in our progressively increase from zero to 38m³/s, and the power view AFNP is a soft target as a result of the REIPPP in South station will operate at less than its installed generating Africa. “A planning document, leaked to The Weekend capacity. Australian,(10 May 2014) shows Hydro Tasmania’s power-  For ±35% of the time (128 days, or 4.2 months river flows •‐purchasing agreements for its major Tasmanian wind farms – exceed 90m³/s but are less than 800m³/s, diverted flow will be Musselroe and Woolnorth – will return a $12.5m loss this at a maximum of 38m³/s, and the power station will operate at financial year, rising to $20.6m in 2014-•‐15. Cumulative its full design capacity losses total $103.6m ( about 1billion Rand ) by 2018-•‐19, This means that, during the time when flow will be diverted to the according to the document, the authenticity of which was hydropower station, the percentage reduction in the flow rate over confirmed by the company.” This illustrates why Hydro SA/HT the falls will range from zero at a total river flow of 30 cubic

Coastal & Environmental Services 110 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA stated that they are only interested in Hydro Electric power, metres per second (m3/sec) to 42.2% at 90m3/sec, falling to 4.2% because it suits them in this case. In the light of the accusation when the river flow is at 800 m3/sec. The commentator’s that are they paying less for their share in the REIPPP projects assertion that this alteration of the flow regime of the falls will should be seriously investigated. Is this why the Neusberg result in a decrease in tourism to the park, with knock-on effects project escalated from 433.76milion ZAR (Neusberg PDD on the local hospitality industry, is a reflection of her personal page 3) to 580mililion ZAR (IDC media), or is this a matter for fears, and is by no means the established fact that she believes it investigation by the Public Protector? to be. Furthermore, the Riemvasmaak community is made to believe Disappearing documents: The statement that we, EOH CES, that project will sort out all their power problems and they will have somehow deliberately made the commentators’ previous never have power failures again, as can be seen in their correspondence with the previous EAP “disappear” is without comments. It is the duty of the DEA as the competent authority foundation, and is rejected. These previous comments have been to stop this abuse. This is a company that is only interested to resubmitted and included in this Comment and Response Report line their own pockets regardless of the impact this project will Employment: The applicant is committed to employing as many have on our South African heritage and its people. local people as possible during all phases of the project’s lifetime, For the public, to try and comment on this project/study within as set out in section 6.8.2 - Project Employment Opportunities – a window of 30 days is unreasonable, bearing in mind that the of the Draft EIA Report. The applicant has also undertaken to applicant was allowed more than 30 months to compile the provide the necessary training to employees to enhance their study, therefore, our objection that it is procedurally flawed future employment prospects. The anticipated numbers of remains. However, let me point out a few fatal mistakes/flaws employment opportunities were presented to the Riemvasmaak and omissions which should render this report useless for Community members during three open-house meetings on 5th proper consideration going forward. and 6th of May 2015, which were attended by a total of 138 1.The unrealistic EFR scenario by the Environmental people (Vredesvallei 32; RVM Mission 43, Augrabies & Assessment Practioner, must be rejected due to the lack of a Marchand 63). scientific basis. This must be seen against the disregard for Availability of water; WULA: The alleged potential for there not any EFR as has been illustrated at Neusberg, by the very being sufficient water to operate the project in future, and the effective remote manipulation from Tasmania. EFR date, 20 requirement for a “water balance”, apparently refers to an May 2015 at 07h00 is +-•‐ 15cumec and the flow through the analysis of the balance between supply and demand in the Hydro scheme is 91cumec, and then the seemingly innocuous Orange River catchment as a whole. This is, of course, the statement by the consultants that “ we will never dry up the responsibility of the Department of Water and Sanitation, and the Falls” begins to look like an absolute certainty AND IN THE applicant cannot reasonably be expected to undertake such a LIGHT OR THIS A COMPULSORY WATER USE LICENCE task. This was carefully explained to the commentator at the PROCEDURE INCLUDING FULL PUBLIC PARTICIPATION public meeting. The applicant has, however, analysed the river’s MUST BE MANDATORY. Because of this irregularity it is flow regime for the past 20 years from the data recorded at the imperative that the Water use licence for Neusberg must be DWS gauging station a short distance upstream of the site of the made available for public scrutiny. diversion weir. He has satisfied himself that, under flow 2. The whole issue is the fact that a Special Management Area conditions in the river that have prevailed for the last 20 years, with a High Sensitivity value inside the AFNP, is the target for there will be sufficient water for the project, and that the project this development, where biodiversity conservation is a critical will be financially viable. The applicant has also consulted component and therefore the specialist study must consult the extensively with the Department, and has submitted an correct references. Then when looking at this study we realise application for a Water Use Licence for the project. In a letter

Coastal & Environmental Services 111 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA that the wrong area information was used for this study, the dated 8th July 2015 to the applicant, headed Confirmation of Namakwa District (DC6) (p25) was used for the assessment. It Water Availability for the Proposed 40MW Hydropower facility: is obvious that this study must be completely ignored and RVM Hydroelectric (Pty) Ltd, near Augrabies in the Orange Proto- cannot be used in a decision at all. The correct study area is CMA, Northern Cape Operations, the Department wrote: Siyanda District (DC8). Refer to our FEPA project comments Following due considerations of the water resource dated 26 May 2014, facilitator document no13. availability in the relevant catchment area, it was 3.The lack of respect for legislation became clear in a recent determined that sufficient water is available to meet the meeting when Mr Rowlston’s attention was drawn to the water requirement of the proposed project, requiring requirement that SANParks approval must be obtained before approximately 98 550m3 during the 36-month duration of the DEA would accept the final EIR. Refer to NEM:PAA 50 (5) the construction phase and 38 m3/s during the operational He blatantly refuse to accept it and stated that they will submit phase of 20 year long duration, which is a non- it anyway, regardless. consumptive water use. 4.The fact that new consultants were appointed should not be The department is evidently satisfied that the project is an excuse for the deliberate omission of any correspondence sustainable in the long term from the perspective of the and comments, we see this as a strategy to minimise public availability of water, and the commentator’s misgivings in this participation, neither should they be allowed to reintroduce old respect are therefore unfounded. reports that were tainted by false declarations or based on the Applicant’s partners in the project: The applicant has the right wrong ToR. It now seems from certain documents ( Socio-•‐ to choose his partners in this project, irrespective of the country economic report Jan 2014) that EOH CES was already of origin of the personnel involved. The performance of that entity appointed in January 2014, without notification. Furthermore, on projects in Tasmania is not relevant to this project, and neither the facilitator, Mr Shaun Johnston promised that a focus group is the cost of the Neusberg project. meeting will be held at the AFNP, and we did not even receive Availability of electricity in the area: No guarantees have been a courtesy call. This renders the process procedurally flawed, given to the Riemvasmaak community, or to anyone else in the fraudulent and unfair. project area, of an uninterrupted power supply when the project is 5.In all the specialist studies the word " mitigation" seems to implemented. The electricity generated by the project will be fed be the magic bullet, but all it confirms is that the destruction in into the National Grid. A 40MW hydro plant connecting into the the AFNP and Melkbosrant will be complete and no matter national grid Blouputs in the Northern Cape Province will have a what mitigation promises are made, the cumulative impacts positive impact on the stability of the South African Electricity will be overwhelming and irreversible. Grid. While the small relative size of the units will have negligible 6.As an affected party , with a vested interest, who is a impact on the overall system frequency stability, the units will voluntary participant in the expansion of the footprint of this provide significant local voltage support. This voltage support is National Park (see Park Management plan, page 20) we want mandated in the RPP Grid code for this sort of generating unit. to state categorically that the impact by the proposed activities The voltage support improves the efficiency of the local will be severe and we want to record our strongest objection to transmission and distribution network, makes solar PV facilities any notion of approval for this application. less prone to interruption due to voltage dips and enhances fault Hannecke van Coppenhagen detection and clearing through higher local fault levels. All these effects provide a more secure, reliable and higher quality electricity supply for customers in the region. The presence of synchronous generation in a region can also facilitate faster system restart after blackouts and assist the supply authorities in

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No. Issue Raised by Response from CES EIA team or Hydro SA system outage management. Comment period: The 2010 EIA Regulations (in terms of which this project is being assessed) do not explicitly specify the length of the period for I&APs to comment on Draft reports. This lack of specificity about the comment period is reflected in the Companion to the Environmental Impact Assessment Regulations, 2010, which was published by DEA in October 2010 as Guideline 5 in the Integrated Environmental Management Guideline series, except to say that comments should be submitted within the specified timeframes, or any extension agreed by the EAP. However, Guideline 6 in this series – Environmental Management Frameworks – recommends “at least a 30 day review period” for an EMF, and regulation 3(8) of the 2014 EIA Regulations says that “Any public participation process must be conducted for a period of at least 30 days.” DEA therefore regards 30 days as a reasonable period for I&APs to comment on reports. It should, however, be noted that the comment period was extended by 14 days at the commentator’s request. WULA: A Water Use Licence Application (WULA) was submitted to DWS by MBB Consulting Engineers Pmb) on 15th May 2015. A series of 40 documents relating to the WULA was made available for public comment on CES’s website. A copy of the Draft EIA report was submitted to the Department in support of the application, and its receipt was acknowledged in a letter dated 30th June 2015 from DWS. Subsequently the Department issued a non-binding letter confirming that water was available for the project (referred to above). The letter also specified that the letter was not an authorisation to proceed with the water use, and that a full assessment of the application would be undertaken once the project had received preferred bidder status in terms of the Department of Energy’s REIPP programme (which requires environmental authorisation to have been granted). Public comments on the WULA will be submitted to the Department once they have been collated and responses prepared. Namakwa District: We are not certain to which report the commentator is referring. There is no doubt that the project is in the Siyanda DM (since 1st July 2013 known as the ZF Mgcawu District Municipality) and not the Namakwa DM. We can find only two references to the Namakwa DM in the specialist reports. One

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No. Issue Raised by Response from CES EIA team or Hydro SA is a reference in the Heritage Impact Assessment to a previous HIA carried out by the specialist, which is not explicitly mentioned in the text. The other is a quotation in the Faunal study from the Namakwa District Biodiversity Sector Plan (NDBSP). 2008. Namakwa Bioregional Plan, Northern Cape. pp 146 (referenced in the text as NDBSP 2008), as follows: However, the hunting and trapping of predators can often lead to an increase in predator numbers because of the elimination of alpha males that restrict access of other predators within their territory (NDBSP 2008). The reference is intended to illustrate the problems with predator control. It is an example, and has nothing to do with the subject matter in the 26th May 2014 facilitator document No 13 quoted by the commentator, in which one of the highlighted issues is (emphasis by commentator, Mr K Van Coppenhagen): In the instance of the Lower Gariep Alluvial Vegetation, conservation is the only acceptable use of the area because it represents:  an endangered vegetation type with a conservation target that can already not be attained anymore due to the extent of transformation that has already occurred; and  natural floodplain areas in the river system that is dynamic and subject to natural physical change over time due to the interaction between the alluvial nature of the area and flood events. The Botanical specialist report, in which the Namakwa DM is not mentioned, discuses Lower Gariep Alluvial Vegetation as follows: The construction of the intake weir will impact Lower Gariep Alluvial Vegetation to a small localised extent and will not make a significant contribution to the cumulative loss of this Endangered vegetation type. The commentator has misunderstood the piece of legislation she has quoted. The stipulation in NEM: PAA s50(5) is that “No development, construction or farming may be permitted in a national park, nature reserve or world heritage site without the prior written approval of the management authority.” The Act does not require the management authority’s approval for the preparation and submission of an EIA Report for a proposed development in a national park, only for the implementation of the

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No. Issue Raised by Response from CES EIA team or Hydro SA development itself. There was no question of the EAP refusing to accept the requirements of the Act or failing to respect legislation, merely an insistence that it was correctly interpreted. DEA was in error in requiring evidence of SANParks’ approval of the project before submission of the EIA Report, and has confirmed that its interpretation of the Act’s requirement was mistaken (e-mail dated 22nd May 2015 from Mr Danie Smit (DEA) to Bill Rowlston (EOH CES)). Specialist reports: When we – EOH CES - were appointed to progress the assessment that was started by Aurecon, we undertook a comprehensive review of all reports prepared during the Scoping phase to determine their continued relevance to the project, We are confident that we did not “introduce old reports that were tainted by false declarations”, and we do not know what the commentator is referring to here. Any of the existing reports that were carried forward into the EIA phase were either of such a nature that the revised scope of the project did not affect the relevance of the report (the Agriculture and Heritage assessments, for instance), or they were amended to reflect the new scope (the Botanical study, for instance). All I&APs who had been registered for the Aurecon project were informed of EOH CES’s appointment as soon as the appointment was finalised. The commentator’s accusation that the consultation has been fraudulent, flawed and unfair is without foundation. With regard to the focus group meeting, Mr & Mrs Van Coppenhagen were asked to provide proof that they were mandated by their neighbours and lodge operators to represent them but no such evidence was provided. Since the Van Coppenhagens responded to the invitation to attend the meeting in Kakamas and the other did not, the necessity for an additional meeting was not evident. Assessment of impacts - mitigation measures: The approach adopted to assessing the impacts of this proposed development on the natural and social environments, and subsequently proposing measures to mitigate – reduce, lessen, moderate or diminish – the severity of impacts to acceptable levels, is explicitly required by the EIA Regulations, and is standard practice for all EIAs. The assertion that “the destruction of the AFNP and the Melkbosrant will be complete no matter what mitigation promises are made” is the commentator’s opinion, and is by no means supported by the evidence presented in the Draft

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No. Issue Raised by Response from CES EIA team or Hydro SA EIA Report and the supporting specialist reports. The extent and significance of the impacts of the project is the commentator’s personal; opinion, to which she is entitled, but it is not supported by the objective evidence presented in the EIA Report. We appreciate the commentator’s declaration of her vested interest (which is stated elsewhere by Mr Van Coppenhagen), and her objections to the project are noted 81. Sir, Hannecke van Dear Mrs Hannecke van Coppenhagen, The "Plan of Study Approval for EIA"; Appendix A ("A"), Draft Coppenhagen, Thank you for your second submission dated 01 June 2015 Environmental Impact Report (DEIR) and Specialist Reports Daberas, comment by relating to the proposed Hydro SA Riemvasmaak Run-Of-River which have been published for comments, have reference; e-mail, 01 June 2015 Hydro Power Station EIA study and draft environmental impact assessment report. The applicants knew from the outset that there is a legal I hereby acknowledge receiving your comments on the draft requirement to obtain SANParks consent (before submission report and will forward it to the environmental impact assessment of the Final EIR as required by NEMA 50(5)) and that the Park practitioner. Management Plan needs to reflect that the activity is Sincerely, appropriate. There is also the matter of a water license Shawn Johnston application which has not been launched yet and we are aware of the fact that the applicants have apparently asked for EAP’s response: a non-binding agreement from DWS for the other hydro These comments deal with the following issues: scheme applications, as a "substitute" for a water license. To  The commentator’s assertion that permission is required from assume that the diversion of a river, involving a volume of up SANParks to submit the EIA Report to DEA. to 1200 million cubic meters/a (MCM/a), over a distance of 10  The requirement for a water use licence for the project. km inside a National Park, would not require a compulsory  The commentator’s assertion that the project will “dry up the licensing procedure, would be naive. The water use license is falls”. needed to assess the long term sustainability of the activity  The commentator’s assertion that the park’s Management (Theron is talking about an 80 year period). During the recent Plan cannot be amended to accommodate the project. public meeting the sentence: “we will never dry up the falls” All of these issues have been addressed in previous responses. have been used many times, but when one look at the EFR manipulation (15cumec EFR, 91cumec Hydro: 20 May 2015@07h00) of the Neusberg Hydro Scheme it becomes apparent that it will become a certainty virtually from day one.

The assumption that the Park Management Plan and land zoning plan (p 13-15, 52-61, 69-71) can be changed ad hoc, in order to accommodate this project is fatally flawed. The facts will show that the applicants (Hydro SA/hydro Tasmania (HT)) presented their proposal to SANParks on 30 July 2012 and that the public meetings for the revision of the Augrabies Falls National Park Management Plan was held several months

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No. Issue Raised by Response from CES EIA team or Hydro SA later and this Plan was approved by the Minister of Environmental Affairs in September 2013, with the "project area" zoned as a special management area. Thus, to be procedurally correct, the applicants should have presented their proposal during this public consultation period for proper consideration, as far as its acceptance in terms of the Management Plan for 2013- 2023 is concerned, because the previous Management Plan did not make provision for such an activity either. 82. During the recent public meeting mr. Bill Rowlston stated that Hannecke van The issue of the applicant requiring permission from SANParks to the applicant is not interested in obtaining this consent from Coppenhagen, submit the EIA Report to DEA has been addressed in previous SANParks and that they will submit the Final EIR anyway. Daberas, comment by comments. The following quotations of N Theron were taken from the e-mail, 09 June 2015 minutes of the Riemvasmaak public meeting held on 6 August EAP’s response: 2013: SANParks has formally expressed its opposition to the project "2) NT noted that they met with SANParks and that SANParks (see comments from Dr Hendricks above), so Mr Theron’s did not in principle have a problem with the proposed project if remarks are not at issue. HydroSA could deliver on all their promises. NT also noted that it might not be necessary to rezone, but that it depended on SANParks and whether they came on- board. NT explained that there were individuals within SANParks that were against the project, but that they did not have all the information." It is clear from the above that he is wrong in both cases, since we have NEVER seen any communication from SANParks which should be interpreted as consent for the activities. It does seem as if the DEA is indulging the applicants tardiness and unfair procedures in finalizing this process within a reasonable timeframe, which is unacceptable. Neither have we received minutes of the meetings between DEA and the applicant, which we have been requesting for a long time. Refer to "A". 83. Fragmentation: We have previously referred to the fact that the Hannecke van EAP’s response: SANParks land to the north of the river is already fragmented Coppenhagen, The commentator’s assertion that Rowlston said he regarded by a service road to Riemvasmaak, resulting in a loss of about Daberas, comment by fragmentation as a fatal flaw is in error. He cannot imagine why 4000 ha and that further fragmentation would be completely e-mail, 09 June 2015 he would venture such an opinion, since unpaved roads, unlike intolerable, because that would lead to a loss of 8000 ha in fences and open canals, are not insurmountable barriers to total. Mr. Rowlston referred to the fact (in the public meeting) faunal movement. that fragmentation would be a fatal flaw for the project to proceed, without realising that we have already advanced that

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No. Issue Raised by Response from CES EIA team or Hydro SA proposal previously and that he was actually reinforcing our notion. The new proposals for haul roads 120 meters down into the ravine would convert/fragment the site completely into a true mining development area, which would harm the sense of place irreversibly. 84. Draft Environmental Impact Report Hannecke van EAP’s response: The omission of NEM:PAA, its regulations and norms and Coppenhagen, NEM: PAA & Regulations: We are aware of the requirements of standards for the management of National Parks, National Daberas, comment by the NEM: PAA and its Regulations. We are also aware that there Water Act and regulations, substitution of the Siyanda EMF e-mail, 09 June 2015 are no absolute legal prohibition of activities such as those 2008 with an unrelated report and SA National Biodiversity contemplated in respect of this project, but that it is necessary to Strategy and Action Plan (2005), from the reference material obtain permission from the management authority – in this case of this report is a grave error. Considering the recent changes SANParks - before the project may be implemented. However, in the scope of the proposal and the period of time which has we are of the opinion that this project can be developed and elapsed since the acceptance of the FSR, very little original operated with minimal effects on the nature of the park and its work of any value has been conducted, to justify the excessive surroundings, and with minimal effect on the Augrabies Falls, or delays. We urge the DEA to revisit it's repeated decisions to the Orange River as a whole, as a tourist attraction. We also allow more time for the finalization of the EIR due to a hiatus in believe that the project is necessary to contribute to resolving activity of almost 9 months, from April 2014 until the South Africa’s ongoing electricity shortages. appointment of new Geotechnical, Fauna and Aquatic specialists in 2015.(see facilitator doc 9 dated 27/8/2013 which Namakwa DM: The references to the Namakwa DM are refers to above docs) addressed in the response to Comment 80, also submitted by this We reserve the right to forward more comments in due time, to commentator, reinforce our objection to DEA's indulgence of the applicant's to failure to submit the DEIR on time, since it is related to the Procedural unfairness: The commentator is advised to address administrative and procedural fairness of the application. allegations of procedural unfairness, etc, on DEA’s part to the The DEIR refers to the Namakwa District Biodiversity Sector department. Plan (2008) on p 25 (as introduced by the fauna specialist?) and elaborates on it over several pages. It is true that the Flow sharing: Rowlston has no recollection of discussing “flow impacts on the riverine ecology in that district is related to sharing” during the public meeting in Kakamas, and does not mining (destruction) which is virtually irreparable. However, the understand what the commentator think it means in the context of correct document for the Augrabies area is the Siyanda this project. Environmental Management Framework Report 2008 (EMF), which deals very specifically with the remaining floodplains and riparian habitat. This was brought to the attention of the consultants and your reluctance to use this valid and material information, should be viewed as a fatal flaw. (Facilitator doc 13 dated 26 May 2014) DEIR 2.2.5 States that the study area should be an NPAES area and not a protected area, which is misleading and “Refer to 2.6 for explanation”, but it is not forthcoming in that section.

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No. Issue Raised by Response from CES EIA team or Hydro SA The EAP is clearly on the wrong path with this line of thought and it should be considered as a fatal flaw. 3.3 Diversion Weir During the public meeting mr. Bill Rowlston stated that the concept of "flow sharing has been accepted" (also by the SANParks?). This is categorically wrong, since SANParks are legally obliged to participate in the outcome of any activity, even in its buffer zones, which could directly influence the water flow regime into or through a National Park. 85. "Norms and Standards for the Management of Protected Hannecke van EAP’s response: Areas in South Africa" (Notice 528 of 2014) have been Coppenhagen, NEM: PAA et al: As we have stated previously, we are aware of published and serve as guidelines for securing National Parks Daberas, comment by the regulatory instruments cited by the commentator, and we do and its buffer zones: Page 10 and 11 elaborates e-mail, 09 June 2015 not dispute it. We do, however, point out that there is no absolute "6. The protected area secured in terms of legislation. prohibition on development of infrastructure in a national park, 6.1(b) Standard provided agreement can be reached with the management There are applicable legal mechanisms in place to control authority. inappropriate activities" This standard confirms that management cannot be WULA: The question of the necessity for a water use licence has discretionary, i.e. it is a tool for the rejection of inappropriate been addressed in previous comments, and at the time of writing activities, which could threaten the legal status of the National this response (August 2015) the commentator has been informed Park. that DWS has issued a non-binding letter to the applicant On page 13, 14 & 15 confirming that water is available for the project. "9. Planning outside the boundary to secure Protected Area Purpose ORASECOM EWR Assessments: A new section has been The purpose for this norm and its standards is to promote and added to the EIA Report - 3.3.2 Previous environmental water ensure the positive involvement of the protected area requirements recommendations – in which the EWR management in planning outside the protected area which recommendations in three previous ORASECOM studies were may affect its integrity. analysed. Of the three the 2010 study edited by Louw & ...... Koekemoer was the most comprehensive and science-based 9.1(c) Standard assessment of the reach of the Orange River between Water-use planning outside takes into account the objectives Boegoeberg and Augrabies. It recommended a Maintenance flow of the protected area. regime for PES Category C in which monthly flow rates varied Indicators seasonally between 18.9 and 41.7 m3/sec, with a total annual Management authorities play an active role in water use volume of flow of 886 Mm3. “High” flows added another 493 Mm3, planning affecting the protected area. bringing the total annual volume of flow to1 379 Mm3. The The water-use planning takes cognisance of the protected achievement of this flow regime ( as well as a desired regime to area and the achievement of protected area management achieve ES of Category B, with much higher rates of flow and a objectives." much higher annual volume of flow of 2 341 Mm3) will depend From the above standard it would become clear that a water almost entirely on the way in which upstream releases and license application, to divert the water away from a river (or abstractions are managed by DWS. The section concludes that

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No. Issue Raised by Response from CES EIA team or Hydro SA water fall) inside a National Park must be rejected. there is no conflict between the ORASECOM recommendations DEIR continues with a quotation from Orasecom documents outlined above (and described in considerably more detail in the (2) that the EFR is 900 MCM/a which is incorrect. The correct new section 3.2.2 in the EIA Report) and the establishment of document to quote is: Louw MD and S Koekemoer (editors); 30m3/sec as the flow rate at which diversion will commence, and Volume 1: Environmental Flow Requirements Produced for below which no diversion will be permitted WRP as part of Support to Phase II ORASECOM Basin Wide Integrated Water Resources Management Plan" 2010, which indicates on p (ix) that the long term mean EFR for the Present Ecological Status C, is 1251 MCM/a, which is a minimum figure and which should be expressed as periodic low and high flows, more or less in line with the current flow regimes, not even as a constant value of 40 cumec. Thus, your figure of 900 MCM /a or 30cumec for the EFR is unrealistic, unscientific and a FATAL FLAW. 86. Accepting this 900 MCM/a as the long term mean EFR would Hannecke van EAP’s response: immediately place this section of the river in a lower ecological Coppenhagen, EWR: The environmental flow requirements of the river are status, which would further decline once the diversions from Daberas, comment by addressed in the response to the previous comment. Lesotho Highlands Water Scheme (LHWS) phase II to the e-mail, 09 June 2015 Vaal Catchment are increased by an additional by 660 MCM/a Flow duration curve – availability of water: The availability of from around 2020. water for the project was derived from analysis of 20 years of Calculations from the optimistic flow duration curves in Fig. recorded data (daily average flow between 1994 and 2014) from 3.17 provide a yield of around 202 GWh/a, not 235 GWh/a as DWS’s hydrological gauging weir at Neusberg Weir (D7H014), stated elsewhere and which indicates a power factor of .57 some 47km upstream from the proposed diversion weir. On (about 680MCM diverted) which is already a low yield and DWS’s advice a constant 3m3/sec was deducted from the flow based on the WRONG EFR. Doing a type of haircut on your rates recorded at the gauging station to allow for abstraction for calculations would indicate a load factor below .40 which is irrigation between Neusberg and the diversion weir site. The approaching the original Basic Assessment Report scenario. energy model used in the analysis considers that the project does SANParks did question the justification for this increase from not operate until river flow is equal to 30m3/sec, and is shut down 20MW to 40MW. On the other hand, a relatively crude but when flows exceed 800m³/s, when high sediment loads are effective calculation would prove that the planned diversion for anticipated. We have no reason to doubt the validity of the the .57 load factor (680 MCM) would be reduced to virtually estimates of power that can be generated by the project. In NIL/ZERO when the 660 MCM of LHWS phase II is deducted. addition, we cannot imagine why the commentator imagines that AND this is if we do actually use your incorrect (low) EFR then applicant would contemplate making a substantial assumption. If one use your 235 GWh/a the diverted quantity investment in a project that was based on flawed data and would exceed 800 MCM...... ? erroneous calculations. 87. 4 Need and desirability Hannecke van EAP’s response: This project is inappropriate and undesirable for a National Coppenhagen, We note your objections to the project in this regard. Park Daberas, comment by We have previously made detailed comments in this regard e-mail, 09 June 2015 and the facilitator has received copies of some of our

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No. Issue Raised by Response from CES EIA team or Hydro SA correspondence. 88. 5.1 Fundamental Alternatives: The following statement on p 85 Hannecke van EAP’s response: refers; Coppenhagen, We note the commentator’s opinion of Mt Theron and Entura, and "Thus there are no other viable alternatives capable of being Daberas, comment by also the information she has provided concerning the generating bid in South Africa".... and in 5.1.2 ....."Hydro SA has does not e-mail, 09 June 2015 capacity of other hydroelectric schemes that are not related to the develop solar or wind energy projects and has no expertise or project under discussion. interest in doing so." The fact is that Mr. Theron (the applicant) doesn't have expertise in hydro electric schemes either, as his CV stated when HydroSA was part of Mulilo Energy Group, which was the case when this application was launched. Thus, another subsidiary of the group would have been able to propose/develop any one of the other types of RE scheme in Riemvasmaak, at the time. This confirm the facts regarding the overriding importance of job creation for Hydro Tasmania/ENTURA(his principals). As far as the contribution of hydro power to the energy mix, is concerned, it must be noted that the Kobong HPP would contribute 1000-1200 MW after completion of LHWS phase II. The INGULA HPP currently under construction, would also yield 1332 MW, peak demand power. It would be quite irrational to expect that many run of river/diversion hydro schemes could be erected in a country with low rainfall (below world average) and over- allocated "hard working" rivers. (Facilitator doc 12 & 15) This section creates the impression that only diversion/run-of- river hydro schemes can be classified as small hydro in the various RE generation scenarios, which is not true. It would be more correct if they state: Thus there are no other viable RUN- OF-RIVER/DIVERSION HYDRO SCHEMES capable of being bid in South Africa..... except that mr. Theron has mentioned at some stage that they did "withdraw" from another potential site in the Tugela river, supposedly because DWS would not issue water license for a guaranteed volume. 89. SPECIALIST REPORTS Hannecke van EAP’s response: 6.1 Agricultural Report. Coppenhagen, It is not possible to address this comment without knowing what The specialist fails to use the recommendations of the Daberas, comment by specific recommendations from the EMF regarding agriculture the SIYANDA EMF 2008, when doing this assessment, which e-mail, 09 June 2015 commentator is referring to. We do not find anything in the renders it useless and it must be rejected in its entirety. specialist report that is inimical to the EMF statements and recommendations. 90. 6.2 Aquatic Ecology Report. Hannecke van EAP’s response: This "new" report fails to take note of the original BAR report's Coppenhagen, Gas bubble disease: We are aware of Gas Bubble Disease, its

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No. Issue Raised by Response from CES EIA team or Hydro SA concern regarding the potential physical impact of super Daberas, comment by causes, and its potential impacts on aquatic life, especially fish. saturated water (which cause Gas Bubble Syndrome, "the e-mail, 09 June 2015 The typical occurrence of high total dissolved gas (TDG) occurs bends", which is a physical effect) which would affect aquatic in very large, high-discharge dam spillways that plunge into life detrimentally in the re-activated channel. Neither does it receiving waters below. The very high pressure of the plunging make provision for the mitigation of that effect, by suggesting water forces gases to dissolve in the receiving waters at super- the blending of the tailrace water in this channel, with fresh saturated concentrations, and this has been known to result in water, which should be a portion of the diverted water. Super fish kills. This is not such a project. The discharge from the saturation(with oxygen and nitrogen) of the water could easily turbines is relatively low, and will travel along a free-surface-flow occur under confined pressure and intimate mixing conditions, tunnel to discharge into the receiving stream via a relatively as was suggested by the original report. gently-sloping spillway equipped with energy dissipators.

This report does not deal with the excessive sediment Sediment: The diversion of flow into the HPP will cease at a river load/turbidity of the Orange river which is the highest in Africa flow of around 800 m3/sec, when it is anticipated that sediment and 4th highest in the world (PDF: A tenfold increase in the concentrations could be sufficiently high to be carried through the Orange River mean Holocene mud flux: implications for soil headrace and into the headpond. If sediment proves to be a erosion in South Africa, Compton et al) and its impact on the problem it will be possible to trap the sediment before it reaches dispatchability of a HPP because, during the higher flow the penstock by making modifications to the head pond design. events sediment removal by flushing is being practised. Take the example of Boegoeberg which is permanently inundated EWR: The environmental flow regime of the river is addressed with silt and where the sluice gates are permanently open to the response to comment 85, and the commentator is referred to prevent silt intrusion into the irrigation canals. This silt will new section 3.3.2 in the EIA Report. It should be noted that a cause premature failure of the turbines of a HPP. In the Lower constant flow of 30m3/sec is not the entire environmental flow Orange river, localised flash floods could deposit thousands of regime of the river, as the commentator appears to believe, but is tons of sand/silt into the river within one to two hours, (due to the lowest flow recommended by DWS over the Augrabies Falls tributary gradients) which would have the same effect. A (provided that upstream releases and abstractions permit such a remote operator would not even be aware of the fact before it flow rate), and is a flow rate that will not be violated by diversions is too late. into the project.

This report also use 30 cumec as the EFR, which is an Arsenic: The commentator’s remarks about the sources of unscientific method because the EFR should have seasonal arsenic in the river are noted. variations as it is currently regulated by DWS. Thus it should be clear that the EFR cannot be expressed as a fixed "magic" Surplus excavated material: We aware that the area proposed number beyond which water could be diverted away from the for the disposal of surplus excavated material until it can be water fall. This report does not justify the assumption of 30 removed for off-site use is part of the buffer zone that SANParks cumec for the EFR and this number must be rejected. The would like to establish around the park, but we disagree that it is correct EFR is discussed in detail, above. Neither does it refer a wetland area that will be desiccated and fragmented by to NEM:PAA and it regulations and the Siyanda EMF 2008, diversion of water into the power station. regarding disturbance of water courses in National Parks and water licenses affecting the same.(Facilitator doc 2, 4 &13) Table 9 refers to Arsenic (As) as if it originates from an

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No. Issue Raised by Response from CES EIA team or Hydro SA agrochemical pesticide. This is not correct, but the source should rather be geological conditions; originating locally as an erosion product of the Kinzigite/metapelite which contain arsenopyrite ores. This is simply stated to ensure that the impression isn't created that the local agricultural produce is contaminated by arsenic spraying.

The map above displays the unaffected reach of the Orange river in the (boxed) eastern section and the portion located inside the AFNP. This explains why SANParks listed in the adjacent property in its buffer zone, (target area for 55ha dump and overhead power line) as set out in the current Management Plan, in order to protect a larger portion of this endangered and sensitive ecosystem. This is a wetland area which will be fragmented and destroyed (dry and desiccated due to lack of water) due to a diversion of the river. The map does also show that more than 50% of the riparian habitat along the river (white strip south of river) doesn't form part of the National Park. This activity would reduce the unaffected and protected portion of the riparian habitat inside the AFNP substantially and it would make the continued existence of the Park as a Protected Area senseless, if the activities are approved. 91. 6.3 Vegetation and Botanical Report. Hannecke van EAP’s response: We have contacted the specialist in order to ascertain whether Coppenhagen, Botanical study: The botanical study conducted in 2014 for his study (for Aurecon) of April 2014 considered the impact of Daberas, comment by Aurecon was updated in April 2015, and is therefore relevant to the proposed haul roads 120 m down into the ravine, which is e-mail, 09 June 2015 the current 40MW project. The specialist has confirmed in a recent development, but could not receive a reply except for correspondence with EOH CES that the study has considered the a request stating (in an e-mail) that there was some kind of impacts on the vegetation along the two potential routes of the protocol which prevents him from doing so, even though he haul roads, since there is nothing to suggest that the vegetation was not contracted to EOH CES. This should be interpreted as of these areas differs appreciably from the vegetation in the area NO, that development was not considered, which leaves more of the headpond and the power station headworks. or less the same document as for the BAR. It does deal with The specialist is aware that the proposed location for storage of the adjacent property regarding the 55ha spoil heap, but surplus excavated material is in the buffer zone that SANParks because he did not consult the AFNP Management Plan, his would like to establish around the park, but this does not affect opinion doesn't recognise that it falls inside the buffer zone of the nature of the vegetation in this area, not the fact that the the Park and that it would be undesirable as a waste disposal piece of land in question is in private ownership. area. The boundary of this property is part of the wetland The specialist is explicit in acknowledging the conservation status shown in the NFEPA map elsewhere in this document. of the riparian vegetation, and has assessed the impacts of the project on these areas as Low.

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No. Issue Raised by Response from CES EIA team or Hydro SA This report does not consider the NEM:PAA and its regulations, or the National Biodiversity Strategy and Action Faunal study: The specialist’s reference to the Namakwa BSP Plan 2005, nor the Siyanda EMF 2008 which deals very has been addressed in the response to Comment 80, from the specifically with the remaining floodplain area and riparian same commentator. habitat. (Facilitator doc 1, 6, 9& 13) The specialist is aware that the requirements of the NEM: PAA and its regulations, but these do not alter the kinds of animals 6.4 Faunal Report. that will be found in the area, or his assessment of the potential The Terms of Reference (ToR) on which this report is based is impacts of the project on them. just wrong. Branch introduced the Namakwa District Biodiversity Sector Plan 2008, the concept that biomes and fauna should be endangered to justify protection in a National Park, the concept of the secondary channel being a paleo- channel, the notion that the tail race outlet (with its super saturated water) will have a positive impact on aquatic life, which is clearly NOT the probable scenario, which makes it incoherent and of no value for consideration of the proposed activities.

This report does not consult NEM:PAA and it regulations in order to establish the legitimacy of the conversion of the protected landscape and disturbance to fauna which is technically captive in a relatively small area which would become fully fragmented by the proposed activities, nor does it refer to the Siyanda EMF 2008, to establish whether the proposed activity would be desirable, even outside of a protected area. (Facilitator doc 6, 9 &13) 92. 6.5 Seismic Study and Geotechnical Report. Hannecke van EAP’s response: The seismic study is very relevant for us as inhabitants of the Coppenhagen, Mining: The proposed underground excavations (for the area and we have forwarded detailed information to the EAP Daberas, comment by penstock, ventilation and access shafts, power chamber and i.r.o. other earthquake focussing mechanisms (volcanic e-mail, 09 June 2015 tailrace tunnel) do not fall under the definition of mining, since its alkaline lineament, Kalahari seismic axis and various hot primary purpose is not the sustainable development of the springs) which does exist in our area, for the specialist's nation’s mineral resources. If it proves possible for some of the consideration, but again with no result.(facilitator doc14) surplus excavated material to be used offsite, any statutorily- The new methodology which is now being considered, to required permits and authorisations will be sought from the excavate and shift the several hundred thousand tons of rock relevant regulatory authorities. from the base of the ravine to ground level 120 meters above, together with the construction of haul roads and a crusher, are the equivalent of a major mining operation inside a National Park and it would be absolute madness to allow it. The number of measures which would be needed to render the site

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No. Issue Raised by Response from CES EIA team or Hydro SA safe for the contemplated "mining activity" and continued existence of infrastructure like the "haul road"etc., would make it look like a christmas tree. The mining of about 1 000 000 tons of rock in total, some of which will be crushed on site for use, should be subject to a "mining and waste management license", because that is what the activity entails; producing aggregate for construction purposes. 93. 6.6 Heritage Impact Assessment. Hannecke van EAP’s response: This report dates from 2012 but it states correctly under 3.4 Coppenhagen, Legality of agreement: Since the commentator wrote her Limitations Daberas, comment by comment a lease agreement has been signed by the RVM "ACO was requested at very short notice.....and this e-mail, 09 June 2015 Community Development Trust and RVM Hydro 1 (see EIA unfortunately precluded proper preparation for the Report section 2.6.1). fieldwork...."(p8) This does not in any way alter the applicant’s obligation to adhere This is followed up by the ASSUMPTION 7.3 (p37) : "The to the mitigation measures proposed by the heritage specialist, cultural landscape here is not deemed highly significant for two and included in the EMPr. With regard to graves these measures reasons. One is that it is not very old and the other is THAT include ceasing work on discovery of what may be a grave, THE COMMUNITY THAT CREATED IT HAS GIVEN ITS verification by a qualified specialist, followed by statutorily- PERMISSION FOR THE PROPOSED PROJECT TO GO required measures to remove and relocate human remains AHEAD. This ASSUMPTION was FALSE, because the should the discovery prove to be a gravesite. The mitigation community had not even been consulted at the time. measures also address non-grave cultural heritage sites and 7.2 (p37) Graves artefacts. "...... , there are a large number of features on the landscape which may be graves. ....The Riemvasmaak community members need to be made aware of this issue and should be requested to issue a statement indicating their wishes for the deceased should any such features turn out to be graves". Because the alignment cannot be changed at that stage. None of the NEW alignments, ie ravine haul roads or proposed dump could have been investigated. The conclusion of the specialist must be weighed against the wrong information (ToR) from the applicant, that the community has already approved the project in 2012 regardless of the impact on their heritage. This specialist certified that a public participation process (bullet 8) has been followed, weeks before the public participation was announced in 2012. The popular booklet "Augrabies Splendour/Weelde" (P vd Walt) describes the historical background to the establishment of the AFNP and the cultural and heritage value of the Falls

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No. Issue Raised by Response from CES EIA team or Hydro SA and Riemvasmaak in a colourful and sensitive language and should be compulsory reading for anyone interested in the area. The displacement of the "Riemvasmakers" in the 1970's was wrong, but it was corrected with the return of their land with the first land claim under the new dispensation. However, government recognised the cultural significance and sense of place of Melkbosrant and directed that it should only be used for conservation purposes. The cultural heritage of the area (sense of place, cultural artefacts and graves) will be irreversibly harmed by this proposal, and should be rejected! Regulation 1061 states; Prohibitions 4. (1) No person shall, other than in an open access protected area, in a special nature reserve, national park or world heritage site, without the prior written consent of a management authority, license, permit or receipt (i) significantly alter or change the sense of place or any environmental, cultural or spiritual values; 94. 6.7 Baseline Noise Assessment. Hannecke van EAP’s response: Screening Noise Report: states in section 2.2 :"The Coppenhagen, NEM: PAA et al: The issue of NEM: PAA and its regulations has Environment Conservation Act", .... which is clearly not Daberas, comment by been raised before by the commentator. We are aware of these applicable in this case, since the relevant act is actually e-mail, 09 June 2015 instruments, but they do not affect the ways in which the impacts NEM:PAA 2003 and Regulation 1061 as published in GG of the project are assessed. Because of the nature of the project- 28181 of 28 October 2005 and it is applicable in all the affected environment the act and its regulations do influence the National Parks (in 2.5 it is stated that no noise control severity of the impacts and the mitigation measures to address regulations exist for the Northern Cape) the impacts. This is reflected throughout the EIA Report. R 1061 states We recommend that the commentator re-reads section 2.2 of the "22. Other activities; report, as well as section 2.5, to gain an understanding of the No person shall, without the written permission of a relevance of the ECA in the specific context of noise regulations. management authority a) use or cause to be used, any loud When EOH CES was appointed to complete the EIA process speaker or similar device or noisy equipment ...... " started by Aurecon all specialist studies undertaken thus far were Further on the specialist states: carefully studied to determine their continued relevance or * "This assessment however could not identify receptors living otherwise to the 40MW project. The noise study was found to be within 2,000 meters from the proposed development still relevant. (excluding the powerline). .... " see reg 43 (m) below which Alleged fraud / damnation: We are not able to comment on the would specify what should be identified as "receptors". commentators’ allegations of fraud, nor on their assertion that "43. General Prohibitions: they will be damned, since we are not able to find any statement No person shall in a special nature reserve, national park or by the specialist in his report that a public consultation process world heritage site -(m) ...... in any way whatsoever cause any had been conducted prior to a public consultation process being noise in a manner that is likely to disturb any species or conducted.

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No. Issue Raised by Response from CES EIA team or Hydro SA specimen or other person," * Thus, the statement above, from the executive summary (p iii) of the above report, shows that the terms of reference (ToR) are incorrect and this report must be rejected in its entirety! This report was published with the launch of the application in 2012 and the declaration by the specialist (bullet 8) states that a public participation process have been followed and that comments were considered, weeks before the public participation process was launched. This same report is now presented with a new declaration. If this does not constitute fraud, we'll be damned. 95. 6.8 Socio-economic Assessment revision 4 and DEIR 2.4 The Hannecke van I EAP’s response: Socio-economic environment Coppenhagen, Meetings prior to our appointment: It is not possible for us to The DEIR 6.8.3 (p98) states: ".... No concern has been raised Daberas, comment by respond in an informed manner on the commentator’s regarding damage to existing graves, historical artefacts or e-mail, 09 June 2015 observations on events that took place before we were appointed areas of cultural significance to the Riemvasmaak as environmental practitioner in the latter part of 2014. This is Community." This statement proves that the concerns uttered particularly so in respect of statements allegedly made by during public meetings have not been considered and it is a participants in meetings at which we were not present and in red flag, eg. Riemvasmaak public meeting 6 August 2013: which we had no part. "4) Samango noted that some people were against the project Accordingly we will not attempt to respond to the commentator’s at the last meeting and wanted to know if the community has comments relating to the various meetings held between the given permission for the proposed project or if the meeting applicant and the RVM community. was an opportunity for the community to give permission. Entura: Similarly we will not respond to the commentator’s Samango also wanted to know if HydroSA had a financial plan allegations concerning Entura’s motives for involving itself in the and what the plan says in terms of job opportunities and project (which were also raised at length in the commentator’s ownership/ shareholding...... NT noted that this was a long previous set of comments), nor will we comment on the estimates process and that the numbers would be communicated to the of the capital cost of the project. community before any contracts were signed." Lease agreement: We are able to confirm that a lease This section of the document describes the need for social agreement has been signed between the RVM Community upliftment of the local communities, which is common/general Development Trust and RVM Hydro 1 (see EIA Report section knowledge. We have forwarded details of other types of 2.6.1), and this indicates that the community are not averse to the renewable energy projects which would be of greater financial project. and continued employment benefit to the community and Employment: The anticipated employment opportunities from which can be achieved with skills training on the job and which the project are set out in section 4.3.2 of the EIA Report does not have to be installed inside the National Park section, Project financing: There is no requirement in the funding which is of great cultural significance to the community. arrangements for the Riemvasmaak Community Development Another factor which should be considered for the need of this Trust to contribute to the capital cost of the project, nor to provide specific project, is that one of the applicants; (Hydro funds if the project runs at a loss. This is explained in more detail Tasmania/Entura) had a century long era of building hydro in section 4.3.2 - Benefits to local communities – of the EIA

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No. Issue Raised by Response from CES EIA team or Hydro SA schemes, which are now complete and a "project" workforce of Report, which has been expanded to include an explanation of more than 300 (until recently), most of which are now the concept of Non-Recourse Financing. redundant. It is a matter of record that Hydro Tasmania has a high debt ratio and have entered into speculative wind farm transactions which could lead to losses of about R 1000 million rand in five years. The cold fact is that this relentless drive to specifically build a hydro scheme inside the Augrabies Falls National Park, is to create continued employment for HT/Entura and the social needs of the community is a convenient shield behind which to hide the true motivation for the application. This pressing need is confirmed in a transcription of their Tasman Government Business Scrutiny Committee meeting (3 Dec 2013) and we suggest that in this case, the "social" motivations which are presented should be regarded with suspicion and should be rejected. We have submitted detailed comments to the AURECON in this regard, which have vanished from the record. (Facilitator doc 5, 8 & 12) In doc 8 we deal with the initial DENIAL that HT was involved with the application at all. 8.2.2.1 This paragraph from the specialist report, serves to confirm that the Riemvasmakers and other local inhabitants will not benefit from employment as is suggested elsewhere in documents. The contradiction in in order to remedy this specialist statement (DEIR p99 section 6.8.3) is quite extensive . The Riemvasmaak community will not accept that they may lose Melkbosrant if this project fails, because it would serve as security for the construction loan. Riemvasmaak public meeting 6 Aug 2013: "2) NT explained that the project is the bank’s security.(who lends the money) With regards to shareholding NT noted that at the moment HydroSA is looking at giving RVM 12 – 15% shareholding in the project." Which makes them a partner/shareholder in the project! Not an IAP...... Could SANParks allow government land to be bonded against a loan for an unrelated activity and who would sign off on this perpetual security ?What type of guarantees would be provided by the applicant as security against default, which includes faulty design. The high construction cost with exceptional escalation (300

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No. Issue Raised by Response from CES EIA team or Hydro SA million ZAR, 600 million ZAR, 700-1000million ZAR, currently 1300 million ZAR, what next?)of the project is not considered (by the specialist) and its affordability to the community should be investigated as a legal requirement. Riemvasmaak is actually going to finance up to 15% of the project (as shareholders who must borrow the money) according to Theron. He is even lying about the lifespan of other RE technologies in order to encourage support for his own project. An alternative RE project will be much more affordable and profitable to the community. (He actually confirmed that a PV RE project will be paid off sooner than a hydro project. Theron states that the average flow of the Orange river is 150-200 cumec for (9 months of the year), which would satisfy most listeners concern regarding the availability of water to operate the HPP. HOWEVER, THIS IS NOT TRUE. He also stated that the project design takes a 1 in 1000 year flood into consideration, which is nonsense. His deceit is further illustrated with some quotes from the public meetings below: Extracts from Marchand Public meeting, 22 August 2013. 7. BK asked what the impacts on the natural environment would be as the area, especially Augrabies Falls National Park (AFNP), is a tourism destination. He wanted to know if any structures would be visible from the AFNP. NT noted that everything would be buried and only the switchyard would be constructed above ground at the powerhouse. NB notedthat a visual specialist has been appointed to assess the potential visual impact that the proposed project could have." "BK wanted to know if the proposed power station would be able to operate during very low flows and during floods. NT explained that the proposed project would use a maximum of 37 m3/s. He explained that the Orange River’s average flow is between 150 – 200 m3/s. NT noted that the low flow period is usually between June, July and August with approximately 30 m3/s of water flowing over the falls. He explained that the proposed project would only take water once 30 m3/s have been let through. NT further noted that the power station would be designed to withstand a 1: 1 000 year flood. He noted that the 1988 flood was not a 1: 1 000 year flood. NT explained that there would be three turbines and that turbines would

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No. Issue Raised by Response from CES EIA team or Hydro SA operate independently. He noted that the design is such that it could operate during low flows and would be shut down during really high flows." A major flood would cause extensive damage to the buried pipeline and cables and the roads and headpond will wash away. The cost of this proposal has escalated from R300 million to R 1300 million, with the addition of 20 MW turbines, because the other elements of the PROJECT are dimensionally the same as for the "original" 2x10 MW plants.(we have identified this flaw right from the start, which is why they changed the project design, in order to "escape" from their numerous errors). This massive construction cost escalation should be considered against the very low price which HT seems to be spending for its share, as is evidenced by our previous communications to the EAP. Vredesvallei 6 Aug 2013 2)NT explained that solar panels have a 20 year lifespan with the panels being paid off in the early years and then the panels have to be replaced. NT went on to explain that this means that you have to pay for new panels if you want to extend the lifespan for another 20 years. NT noted that it is almost the same for wind, but with hydropower you install the machinery once and it operates for 50 to 100 years As a closing argument we want to quote from the public meeting held in Vredesvallei 6 Aug 2013, where Malcolm Green (a lawyer) of Hydro Tasmania makes the following extremely exaggerated statement: MG explained that Hydro Tasmania has a young engineers program that takes in approximately 50 students each year and that they are planning to start something similar at RVM. MG also added that the current 50 students had been tasked with fundraising money that could be contributed to schools in the area and that this could hopefully be done while the process was still on-going. We have attempted to find details of this number, but now believe that it would be substantially less, maybe not even 10 per annum. The HT Government Business Scrutiny Committee Meeting for 2011 mentions 11 apprentices and although there would be a number of young engineers, the number was not

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No. Issue Raised by Response from CES EIA team or Hydro SA considered worth mentioning. 96. Tourism Hannecke van EAP’s response: The assessment is clearly not attempting to address the very Coppenhagen, Tourism: The risks to and impact on the tourism sector were real risk to the tourism sector, because it is not part of the ToR Daberas, comment by assessed in the specialist report, in which it was observed that and none of the tourism establishments in the area have e-mail, 09 June 2015 the national park was one of a number of tourist attractions in the actually been consulted about the potential impact on its area, and that any project-related impact would be felt most operations and the number of jobs which could be at stake. Mr strongly by the park itself. The implication is that the health of the G Visser has also made the point during the recent public private tourism sector of the area is not exclusively linked to the meeting, that many tourists who are visiting the National Park, national park do actually stay over at private establishments (like Nevertheless, we recommend that the commentator should read Riemvasmaak, Plato Lodge, etc.) in the area and any Chapter 9 of the report (Tourism), and those parts of Chapter 10 reduction in tourist numbers would be impacting on those (Impact Assessment and Mitigation) carefully before arriving at operations, which is not considered in this assessment and the conclusion about the potential impacts of the project on the which would drastically impact on employment in that sector, private tourism sector in the general area. which is the third largest in South Africa. The number of jobs which could be lost permanently if tourism is affected would run into hundreds and it would also discourage further voluntary participation in the extension of the National Park to the west, which is a stated goal of the Park Management Plan. We have indicated to the project team (during public meeting) that there are people without any services, which should also receive consideration, not only from a RE project social responsibility perspective, but also by the municipal service providers. 97. The executive summary contains several incorrect statements; Hannecke van EAP’s response: "Long term hydrological records indicate that sufficient water Coppenhagen, Availability of water: The question of the availability of water in will be available in the Orange River to generate base load Daberas, comment by the river for the project and the need for a :”water balance” for the electricity for 80% of the time." This is a fatal flaw in the e-mail, 09 June 2015 Orange River catchment are addressed in the response to application which we have dealt with in detail above. The Comment 80, submitted by the same commentator. The applicant has refused since early 2013 to provide us with a availability of water for the project has been confirmed by DWS, long term water balance determination, which is crucial and and we recommend that the commentator contact this mandatory for a water license which would allow the diversion department for details of the calculations that led to this of 3,2 million cubic meters(MCM)/day or 1 200 MCM/a, away conclusion. from the National Park. Benefits of power generated: The impacts of the power Mr. Theron has indicated (in media) that Kakamas will never generated by the project are described in the response to experience load shedding again, because the Neusberg Comment 43 above. These remarks have been included in the Project provides base load electricity, which is nonsense. Base EIA Report in section 4.2.6. load electricity is calculated on theoretical maximum demand SANParks, RVM Community Development Trust and RVM for a large area/country and to make a broad statement that a Hydro 1: The relationship between the alleged management tiny electric power plant (of whichever type), does provide agreement between SANParks and the RVM Community

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No. Issue Raised by Response from CES EIA team or Hydro SA base load electricity for "X" thousand homes (based on Development Trust and the actual lease agreement between average annual consumption) shows a complete lack of RVM Hydro 1 and the RVM Community Development Trust is understanding of the subject matter and creates the wrong discussed in the Legal Opinion on land ownership and perception. He has also been proved wrong, since Kakamas management, summarised in section 2.6.1. of the EIA Report, experienced load shedding on the day of the public meeting. with the full text included as Appendix G-1. Land Ownership and Rights. The applicant's attempt to enter The question of temporary rezoning to facilitate the into a contract with a party where an existing relationship implementation of the project will be addressed with the exists creates a conflict of interest and might be illegal. appropriate regulatory authorities if and when the need arises. References to the National Parks Act, 57 of 1976 is outdated. The final two paragraphs of the comment are recommendations The correct reference would be NEM:PAA 2003, Schedule 2 as to how DEA and DWS should proceed with this application as in GN 236 of 2013, etc. (close the application for environmental authorisation, refuse to The notion that only a temporary departure from the current accept the water use licence application, and so on), which we zoning is required is most ridiculous because the activities are will leave to the departments to decide. not even envisaged in the Siyanda EMF of 2008, which states that the riverine floodplains and riparian habitat cannot be developed (regardless of ownership). We hope that the department has any interest in finalising this application soon. The first step would be to instruct the applicants to provide a letter of consent from SANParks considering the consultant’s comment during the public meeting and a water balance determination which takes known future uses/allocations and transfers into account. The visual specialist states on p(i) that the applicant has obtained legal opinion indicating that the AFNP Management Plan may be revised. This is highly irregular and definitely not within the scope/rules of administrative procedures. We suggest that the department close this application to allow the legal process which the applicant intends to follow to run its course and that DWS should not accept a WULA, until the intentions are clear. We are also very concerned that these applicants, who are also operating the Kakamas Hydro Electric Project are operating it outside the EFR parameters which are set for the Augrabies area. We suggest that this application should now be closed as allowed for in the regulations, since the site alternatives being Neusberg and Boegoeberg, which have been identified during the Public Participation Process, has been granted environmental approval by the DEA. Kobus and Hannecke van Coppenhagen – Daberas (Water Use Licensse Application Comments) 98. Sir, Kobus and Hannecke EAP’s response:

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No. Issue Raised by Response from CES EIA team or Hydro SA The letter of Edwin Jenkins of MBB Consulting Engineers van Coppenhagen, This is a request for DWS to refuse the water use licence (Pmb), dated 14 May 2015, refers; Daberas, comment by application (WULA) submitted by MBB Consulting engineers to For the sake of clarity, we are stating that we are an Affected e-mail, 09 June 2015, DWS on behalf of the applicant. Party in the application of RVM 1 Hydro Electric Power (Pty) comment sent to AB Ltd, for the erection of a hydro electric power station and the Abrahams DWS, Danie Since DWS has already issued a non-binding letter to the diversion of 38 cumec away from the Augrabies Falls (1 200 Smit, Howard applicant, confirming water availability for the project we do not million cubic meters/annum) within a riverine floodplain Hendricks and Shawn intend to respond to the commentator’s remarks. wetland (NFEPA Map) inside the Augrabies Falls National Johnston Park(AFNP) and its associated buffer zones, as laid out in the AFNP Management Plan (2013-2023), which maps out the actual zoning plan and which was properly constituted (in terms of section 39 and 41 of NEM:PAA, Act 57 of 2003) and approved by the Minister of Environmental Affairs in Sept 2013. The voluntary incorporation of our land into the AFNP, on a long term (99 years) contract is dealt with on p 20 of same and has been ongoing since 2008. We hope that all the parties understand that this establishes a legitimate basis for our participation in all the procedures and processes related to the proposed activities and its short and long term impacts on the objectives and viability of the conservation effort of the National Park. Firstly, we do suggest that it is procedurally incorrect for the applicant to request a non-binding letter which should state that there is sufficient water in the resource for this activity to proceed with a competitive bidding process in the REIPPP round 5 and that it would be an administrative error of DWS to grant or issue such a letter. There is no documentary proof in the application to suggest that the quantity of water applied for (1 200 million cubic meters/a MCM/a) is actually available. Also, since it is not a schedule 1 water use and the applicants want to register a servitude on the property, which is legally managed by SANParks, it must be noted that its permission is required according to NEM:PAA 50(5), GN 528 and R1061. This documentary proof is not provided anywhere and since Niel Theron and Hydro Tasmania consider this as an eighty to one hundred year activity(media reports), the precautionary principle should be applied strictly and the application returned to the applicants. Thus, we do object to the granting of this request in the strongest terms possible, especially since the DEA has previously warned the applicants that the proposed

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No. Issue Raised by Response from CES EIA team or Hydro SA activities are inappropriate for a National Park. Neither do the applicants (Hydro SA and Hydro Tasmania/ENTURA) have the consent of SANParks in terms of NEM:PAA(2003) 50(5), in order to obtain Environmental Authorization from DEA for such activities as listed in the related applications. Regulation 1061 (specifically prohibit activities related to water courses) and GN 528 (relating in this case to the participation of SANParks in water license applications which could affect its objectives) are also applicable in this (environmental authorization) case, over and above requirements of the National Water Act and its regulations. Many of the activities applied for, are specifically prohibited by the above (conservation) legislation. There are numerous other guidelines and planning documents which should also be taken into account, but since the applicant cannot provide proof of consent from SANParks, we insist that this application be returned to the sender. It should be noted as stated in our DEIR comments, that the applicants are not interested (public meeting) to obtain this legally required consent and because the Competent Authority is being informed in due time, of this lack of intent to comply with legislation, a cautious approach would prevent further procedural chaos. We beg the Competent Authority to refuse this flawed application outright and to revert to us as soon as possible in this regard. 99. Mr Abrahams, Kobus van Dear Mr van Coppenhagen Our previous correspondence (below) refers; Coppenhagen, Your e-mail is acknowledged with thanks. We need your conformation that DWS will not issue a "non- Daberas, comment by Please note that the application by RVM is handled by the binding letter" as requested by the applicants, which would e-mail, 24 July 2015, Orange Proto-CMA, which is headed by the Acting CEO Mr allow them to engage in a bidding process, because the comment sent to AB Moses Mahunonyane. document would be misleading. We have provided a number Abrahams DWS, Danie Mr Mahunonyane of reasons over the 3 previous calendar years in Smit, Howard Can you please provide the necessary feedback to Mr Van correspondence (which was also forwarded for your attention), Hendricks and Shawn Coppenhagen. which would support our request. Johnston Kind regards, We would appreciate your response to this very urgent matter Abe Abrahams and would forward copies of the correspondence for your information, if required. Regards, Kobus & Hannecke van Coppenhagen 0836564498

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No. Issue Raised by Response from CES EIA team or Hydro SA Lea Visser – Plato Lodge 100. Hi Shawn, I am not given my support to the Hydro Electric Lea Visser, Plato Dear Mrs Lea Visser, Thank you for our submission relating to Power station project at the Augrabies Falls. Lodge, comment by e- the proposed Hydro SA Riemvasmaak Run-Of-River Hydro I am totally against the project because this is our area and mail, 01 June 2015. Power Station EIA study and draft environmental impact our Lodge(Plato Lodge) greatest tourist attraction. And to take assessment report. I hereby acknowledge receiving your a certain amount of water away from the falls is rediculous. comments on the draft report and will forward it to the Our population will definitely take off because of the difference environmental impact assessment practitioner. in the water that fell over the falls. So therefor I am totally Thank you for our second submission relating to the proposed against this project. Hydro SA Riemvasmaak Run-Of-River Hydro Power Station EIA I am totally against the project because the falls is our greatest study and draft environmental impact assessment report. I hereby tourist attraction and the project are gonna have a great acknowledge receiving your comments on the draft report and will influence in the water flow of the falls. So they do not have my forward it to the environmental impact assessment practitioner. support. Sincerely, Regards Lea Visser Shawn Johnston

EAP’s response: The commentator’s lack of support for the project is noted. Diversion of water: The impact of diverting water from the falls to the power station is addressed in detail in section 3.3 of the EIA Report. Lead To Business – Melanie Miles 101. Dear Sir, Melanie Miles, Lead To Dear Melanie, Your company is currently conducting a Environmental Basic Bisiness, comment by Thank you for your e-mail. You have been registered and as a Assessment Process Report for the RVM 1 Hydro Electric e-mail, 28 April 2015. interested and affected party. Find attached the BID for the RVM Power - 40 MW Hydroelectric Scheme on Orange River, Kai Project. Garib Local Municipality, Riemvasmaak. Please could you Sincerely, forward me the BID for this application and register me as a Shawn Johnston Interested & Affected party? Thanking you in anticipation of a favourable response. Kindest Regards, Melanie Miles Content Researcher [email protected] Leon Marias – Lawson’s Birding, Wildlife and Custom Safaris 102. Hi Shawn. Leon Marias , Dear Mr. Leon Marais, Just read in the SA Tourism Update about being registered as Lawson’s Birding, Thank you for your e-mail. I have registered you as a interested I&AP’s with respect to the HE power scheme at Augrabies. Wildlife and Custom and affected party on the Riemvasmaak Hydro Project This is obviously a bad idea in terms of tourism, so how do we Safaris, comment by e- Environmental Impact Assessment. Please send all of your list our objections? mail, 14 August 2015. concerns and objections to me directly. Thanks, Leon Marais. Sincerely, Shawn Johnston

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No. Issue Raised by Response from CES EIA team or Hydro SA Thanks Shawn. Are there any ‘stock’ concerns and objections you can supply It would just make it easier and quicker to list them. The impact on tourism potential would be the main cause for concern for us. Leon.

Thanks Shawn. Unfortunate reality is that most people who are not directly affected just don’t have the time to go through for such documents. If there was a quick way to lodge concerns, it would garner much more momentum. Regards, Leon. Luise Niemoller Coertzen and JHB van der Merwe - Pofadder Tourism 103. Dear Mr Johnston, I refer to your recent telecon with ms luise Annas van der Merwe, Dear Mrs Luise Niemoller, niemoller; Van Der Merwe – Miller Thank you for your e-mail. Please note the 6 CDs have been sent due to her hardware problems still persisting, she requested Incorporated, to your post office box form our office. us to follow up on the said communication on her behalf and Pofadder, comment by Sincerely, request that as per your undertaking you forward 6 copies of e-mail, 27 April 2015. Shawn Johnston the full EIA ( on cd) inclusive of all relevant documentation as discussed, to her following address LUISE NIEMOLLER, P O BOX 45, POFADDER, 8890; thank you. Groete / Regards Annas van der Merwe 104. Business development in Pofadder is mainly dependant on Luise Niemoller Dear Luise & Annas, attracting tourist to our area. The flow of tourist and the Coertzen and JHB van Thank you for your comments. I hereby acknowledge receiving subsequent future development of our area will be damaged der Merwe - Pofadder your comments and will be processing it into the comments and beyound repair. Tourism, comment by response report. Thank you for your participation and input. The Augrabies Falls, 122km on the N14 from Pofadder, is the e-mail, 23 June 2015. Sincerely, only known tourist attraction in the area of Pofadder. Tourist Shawn Johnston going through Pofadder are not interested in the Augrabies Falls with not “enough” water to make it impressive. The other EAP’s response: main attraction of the Pofadder/Orangeriver area is it Augrabies Falls and the Orange River: The project will not ruin remoteness from development and natural state where people either the Augrabies Falls or make it noticeably less impressive. can escape to. This will be ruined if the falls are toucehed Neither will it have any significant effects on the Orange River or further by human/industrial hand. People living along the its fish life. The project will not affect the remoteness of the Orange River depend on fishing for food and the fishlife is Pofadder area. The impact on the falls and the river are set out in already damaged. section 3.3 of the EIA Report, and are summarised in the SMME development as requested by or required by the South response to Comment 8 above as follows: African Government will be seriously hampered by damage to The impact of the project on the flow regime of the river is set out the tourism development of the area. And damage to the in section 3.3.1 of the EIA Report as follows:

Coastal & Environmental Services 136 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA Augrabies Falls will damage tourism development as well as  For ±20% of the time no flow will be diverted into the tailrace: SMME development amongst previously disadavantaged local  For ±15% of the time (55 days) the river flows at or less people. Wihin all future meetings regardig the development the than 30m³/s, so no flow will be diverted into the headrace damage to the falls, the Orange River lower down in the and the HPP will not operate. Pofadder/Khai-Ma area will have to be brought to the table.  For ±5% of the time (18 days) the river flows at more than Accommodation development during the current development 800m³/s. At this flow rate it is anticipated that the sediment area will stand as ghost town reminders of a foolish project loads in the river will begin to increase to such an extent against our area. that sediment could be drawn into the headrace, and could Little cottag exists because of eco tourist in the Lower Orange result in damage to the turbines. No flow will be diverted River, therefore any negative impact in the lower Orange River into the headrace; power generation will be shut down to will have a direct adverse effect on this and other small prevent damage to the turbines. enterprises accommodating 2 to 3 persons per night. In an  For ±45% of the time (165 days, or 5.4 months) river flows are area where business opportunities are nearly non existent, the between 30m³/s and 90m³/s, diverted flow will progressively negative effect of the proposed development can never be increase from zero to 38m³/s, and the power station will redressed. operate at less than its installed generating capacity. Onseep River Camp is an eco tourist destination downstream  For ±35% of the time (128 days, or 4.2 months river flows from the Augrabies waterfalls (AWF). The AWF remains the exceed 90m³/s but are less than 800m³/s, diverted flow will be foremost drawcard for tourism in the Lower Orange River area. at a maximum of 38m³/s, and the power station will operate at The proposed project will impact negatively on the tourism its full design capacity industry as a whole and the smaller outfits like ORC will not be This means that, during the time when flow will be diverted to the able to withstand such impact causing downscaling and even hydropower station, the percentage reduction in the flow rate over closure which leads to job loss and loss of financial benefit to the falls will range from zero at a total river flow of 30 cubic the area. Thedamaging influence on the fish population metres per second (m3/sec) to 42.2% at 90m3/sec, falling to 4.2% downstream leads to the loss of interest of tourist in recrational when the river flow is at 800 m3/sec. fishing a main attraction at Orange River Camp. The project will therefore never reduce the flow over the falls to a trickle. The flow regime over the falls can only be reduced to accord with the commentators; fears by improper management of releases from the very large dams upstream of Augrabies, and mismanaged and / or uncontrolled abstractions from the river for off-channel consumptive uses. Tourism: The assessment indicates that tourism and the SMME sector will not be significantly affected by the project. In particular, since the project will affect the flow regime of the river for a distance of about 10km from the diversion weir to a point about half way down the Augrabies Gorge, there will be no impact on the river further downstream, There will be no impacts on the river at Onseepkans or where it passes Pofader. Mariana Delport - DEDT registered Cultural and FGASA Level 2 Field Guide 105. The Augrabies Falls is one of South Africa’s Natural Wonders Mariana Delport, DEDT Dear Mariana, and has been preserved for many years. I have taken many registered Cultural and Thank you for your e-mail and registering as an interested and

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No. Issue Raised by Response from CES EIA team or Hydro SA overseas and local tourists to the park, and will be taking my FGASA Level 2 Field affected party. You comments will be added to the issues and next group of overseas tourists there in a bit more than 2 Guide, comment by e- response report of the final environmental impact assessment weeks’ time. These tourists are in awe when they hear and mail, 16 August 2015. report. see the water fall and experience the pristine habitat and the Sincerely, wild life to be found in the park. Apart from the conservation Shawn Johnston status of the park it also provides lots of job opportunities for the local residents. Now greed seems to take over and a EAP’s response: Natural Wonder is at stake. This can simply not be allowed! The commentator is referred to the response to Comment 104 Please register me as an Interested and Affected Party. above for a description of the effect of the project on the flow Regards, Mariana Delport regime of the Augrabies Falls, and to section 3.3 of the EIA Report. Marinda Louw Coetzee 106. Hallo Shaun Marinda Louw Dear Mrs Marinda Coetzee, I would like to formally object to the proposed hydro-electrical Coetzee, comment by Thank you for your e-mail. I hereby acknowledge that you have project for the Augrabies region of the Orange River. e-mail, 20 August 2015 been registered as an interested and affected party and that your 1) It would affect tourism to the Augrabies National Park comments and objections have been received. 2) It would affect road usage, farming operations and water Sincerely, usage to the export grape farmers in the area Shawn Johnston 3) It might create jobs, but the local population might not have the required skill sets needed. This will mean that EAP’s response: 'incomers' will settle in the area after the project is done Tourism: The assessment indicates that tourism and the SMME and lead to a non-sustainable increase in the population. sector will not be significantly affected by the project. 4) It will cause destruction of the environment Road usage: There will be an increase in traffic in the project Please consider other option such as solar and wind power. If area during construction, but measures will be put in place to the project does go ahead, please ensure transparent tender ensure that there is minimal disruption to local road users. process and thorough, well-advertised public participation Water: DWS has confirmed that there will be sufficient water to processes and information sessions. meet the project’s requirements during construction and Best regards operation. There will be no impact on other water users. marinda louw coetzee Employment: The applicant is committed to maximising photographer / journalist +27(0)832787383 employment opportunities to local people, and offering training to maximise post-construction opportunities for further employment. Environment: The assessment has shown that, with diligent implementation of mitigation measures, the project can be developed and operated without unacceptable impacts on the natural environment. Public participation: An open and transparent public participation process has been conducted for the EIA phase of the assessment. Nathalie Tedder 107. Dear Shawn, Nathalie Tedder, 06 Dear Mrs Nathalie Tedder,

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No. Issue Raised by Response from CES EIA team or Hydro SA Please register me. Nathalie Tedder, June 2015, comment Thank you for your e-mail. I herby confirm that you have been 11 Ottawa Avenue, Cape Town, 8005 083 283 7099 by e-mail. registered as a interested and affected party.  Sincerely, Shawn Johnston 108. Comments on the draft EIA for the proposed Hydropower Nathalie Tedder, 06 EAP’s response: Plants at Augrabies Falls, Northern Cape. Submitted by: June 2015, comment We note the strong similarities between Ms Tedder’s comments - Nathalie Tedder June 04 2015 by e-mail. Nos 108 to 113 - and those submitted by Ms Kellet of the African We recognise the need to develop alternative energy Paddling Association and Gravity Adventures (Nos 1 to 15, which production technologies in order to reduce our reliance on were also exactly duplicated in Mr Craig Eksteen’s submission, fossil fuels. We are, however, 100% opposed to developing Comments Nos 28 to 34); in many cases the wording is identical. any projects in pristine, wilderness areas and areas of Where the wording is identical or very similar the response to Ms ecological importance. Sites of less ecological significance Kellet’s comment has been copied here. should be investigated as a priority over sites of such a pristine and ecological sensitive nature. As noted previously, the response to Ms Tedder’s comments 1. Flawed Public Participation Process: We object in the relate only to the proposal to develop a hydroelectric power strongest possible terms to the public participation process for project (HPP) – the Riemvasmaak HPP - using the natural head the following reasons; generated by the Augrabies Falls, as set out in the EIA Report a. The Augrabies Falls (Riemvasmaak) project is of national currently under consideration. The possibility of an HPP being and international importance – Augrabies Falls is in a national developed that uses the head generated by the Ritchie Falls has park and is of importance to the whole country. Despite this, nothing whatever to do with the Riemvasmaak HPP, and this the consultants and developer have treated it as a local project response does not address any aspect of such a project. We do and have only notified people in the immediate area. This has not agree that the two sites are “irrevocably linked”. These not changed with the appointment of the new consultants, comments not relevant to the issues at hand. CES, despite this view being expressed during the Scoping process. Alternative sites: Alternative sites studied by the applicant are In terms of legislation, the following is required of a public discussed in Chapter 5 of the EIA Report, where it is pointed out participation process; that there are few sites on South African rivers that are suitable • Develop “the understanding, skills and capacity necessary for the generation of electricity without the need to construct for achieving equitable and effective participation.” This would large impounding reservoirs to generate the necessary head, require some objective studies and, subsequently, an such as, for instance, the Gariep and Van der Kloof dams, both educational programme to develop understanding and capacity of which have had, and will continue to have, a profound in the local community so that they truly understand what you influence on the flow regime of the Orange River. In this context propose, their rights and responsibilities and the true impact we note that DEA has recently granted environmental the project would have on their culture and lifestyle. It does not authorisation for another large instream dam, about 30m high, on seem that this has been done. the Orange River, to facilitate the generation of 22MW of power • “The interests, needs and values of all interested and at the Rooikat HPP. affected parties” must be considered. It is clear that this has Public participation process: The commentator’s objections not been done. Please note it says “All” I&APs. are noted. The availability of the Draft EIAR was advertised • “Full participation therein must be promoted.” nationally, provincially and locally in the Sunday Times (25th This project should have been advertised at a provincial and April), and Die Burger, Die Gemsbok and Die Volksblad (29th

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No. Issue Raised by Response from CES EIA team or Hydro SA national level with a meaningful public participation process. April), all as required by DEA. We believe we have conducted a National and provincial tourism bodies as well as civil society consultation process that provides an opportunity to comment on should have been fully and meaningfully consulted. the proposed project to anyone who wishes to do so. We believe For these and other reasons, in our opinion, the public we have fulfilled the legislated requirements in respect of a public participation is fatally flawed and should be declared null and participation process. void and the process started from scratch. 109. 2. Cumulative Effects: Individualised Scoping studies and Nathalie Tedder, 06 EAP’s response: EIA’s fail to recognise the cumulative effects of the various June 2015, comment Cumulative impacts: The cumulative effects of the development of hydro schemes, dams and ‘flood control’ weirs being by e-mail. structures in and on the Orange River are considered in section 7.6 constructed and planned for the Orange. This applies of the EIA Report. It is important to note that the RVM HPP will not particularly to the site identified at the Ritchie Falls near destroy the Augrabies Falls, neither will it have anyeffect on the river Onseepkans as the combined effect of this and the Augrabies at Onseepkans. The commentator is referred section 3.3.1 of the EIA Falls project will be to destroy two of the last remaining Report for details of the effect of the project on the flow regime of the wilderness areas on the entire river. The combined effects of falls. all of this construction need to be considered as a whole and proper consultation done. In our opinion, a Strategic Environmental Assessment is of vital importance before any projects progress any further. 110. 3. Transboundary River Nathalie Tedder, 06 EAP’s response: The Orange River is a transboundary river, whose basin is June 2015, comment The Orange as an international river: We are aware of the status shared between Lesotho, South Africa, Botswana and Namibia by e-mail. of the Orange River as an internationally-shared river, and of the and is goverened by various international agreements and various instruments that relate to its management. However, given administered by ORASECOM. None of these are referenced in that the proposed project will affect the flow regime of the river only the EIA and ORASECOM is not even listed as an IAP. between the diversion weir and the point at which the diverted flow is In a similar vein, the National legislation of the participating returned undiminished to the mainstem river, a distance af about countries requires water resources to be managed from a 10km, mostly through the rocky gorge downstream of the Augrabies catchment approach i.e. from source to sea. In light of these Falls, the project will not affect the downstream riparians, and will proposed hydropower plants, a strategic assessment that certainly not affect the upstream riparian, Lesotho). Accordingly there assess the cumulative impacts of all of the proposed hydro- is no significant effect on the river that requires consultation with the power plants on the Orange river should be carried rather than other basin states in accordance with the SADC Protocol. the current process of individual site-specific assessments. The South African Department of Water and Sanitation is responsible for the management of the Orange River Basin in South Africa, and for administering water-related agreements between South Africa and Namibia. The department has not raised any objections to the project, and has written to the applicant confirming that sufficient water is available for the construction (3 years) and operational (20 years) phases of the project, should it be approved. The period of availability of water for operation relates to the maximum period of a water use licence, and not to the anticipated lifetime of the project, which may be of the order of 80 years or more..

Coastal & Environmental Services 140 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA 111. 4. Impact on Augrabies National Park and the Augrabies Falls Nathalie Tedder, 06 EAP’s response: Sense of Place and the Wilderness Experience – Augrabies June 2015, comment The commentator’s doubts about the credibility of the results of the Augrabies Falls is the Orange River’s highest waterfall and is by e-mail. impact assessment are noted. classified as pristine wilderness. This will be negatively impacted by the proposed hydro plant as follows; During Construction All of the impacts of a major engineering project – in a national park!  Noise  Dust  Aesthetics  Sense of place  Wilderness character  Ecological effects All will be significant and no amount of mitigation will disguise the fact that the construction of this project will have a huge impact on the wilderness character of this site. The specialist studies claim that the impact will at worst be low to medium but this is impossible, given the nature of this site. After construction The permanent structures and power lines will be visible from various points in the park and cannot be disguised. Similarly, the noise generated by the project will definitely not be natural. The wilderness character will be permanently lost. 112. 5. Socio Economic Impact and Ecotourism: Augrabies Falls Nathalie Tedder, 06 EAP’s response: The Riemvasmaak community (who own the land) support the June 2015, comment Employment: The applicant is committed to maximising project but it is clear that they have not been made aware of a by e-mail. employment opportunities to local people, and offering training to number of very important points; maximise post-construction opportunities for further employment. 1. Of the 150-200 temporary jobs, only SOME will go to them. Environment: The assessment has shown that, with diligent In fact, many will go to skilled workers and it is not clear how implementation of mitigation measures, the project can be many Riemvasmaakers will be employed. developed and operated without unacceptable impacts on the 2. The jobs will be around for only three years. After that, only natural environment. 1 job is guaranteed to go to a local person and that will be a skilled job RVM Community Development Trust Shareholding: The 3. They will be shareholders in the company and will receive details of the financial arrangements for the project are set out in dividends – only if the company is profitable, nowhere does it section 4.3.2 - Benefits to local communities – of the EIA Report, say that if the company does not make money, that they will which has been expanded to include an explanation of the be responsible for the debt as well. Given the long term doubt concept of Non-Recourse Financing. around the sustainability of this project (given that global

Coastal & Environmental Services 141 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA climate change predicts less water that is needed to run the Availability of electricity: No guarantees have been given to power plant) the Riemvasmaak community, or to anyone else in the project 4. They are under the impression that the power generated area, of an uninterrupted power supply when the project is will go their community and that they will no longer suffer implemented. The electricity generated by the project will be fed electricity shortages. This is, of course, completely untrue but into the National Grid. A 40MW hydro plant connecting into the at no stage in the reports does it note that the consultants national grid Blouputs in the Northern Cape Province will have a corrected their misunderstanding of the perceived benefits. positive impact on the stability of the South African Electricity The above points relate back to the public participation Grid. While the small relative size of the units will have process which was not properly done. If it was, the community negligible impact on the overall system frequency stability, the may not be as supportive as they are currently. units will provide significant local voltage support. This voltage support is mandated in the RPP Grid code for this sort of generating unit. The voltage support improves the efficiency of the local transmission and distribution network, makes solar PV facilities less prone to interruption due to voltage dips and enhances fault detection and clearing through higher local fault levels. All these effects provide a more secure, reliable and higher quality electricity supply for customers in the region. The presence of synchronous generation in a region can also facilitate faster system restart after blackouts and assist the supply authorities in system outage management. 113. 6. Conclusions Nathalie Tedder, 06 EAP’s response: Ritchie Falls and Orange Gorge: Given the many negative June 2015, comment The commentators’; recommendations that the RVM HPP be impacts identified above, we strongly recommend that further by e-mail. abandoned are noted, together with the recommendation to DEA planning permission for this project be denied and that this that an SEA be conducted relating to further development on the area be given protected status as soon as possible to help Orange River. prevent any such projects in the future. This is part of our country’s natural heritage and should not be handed over to a private company to generate profit for their own benefit and to our detriment.

Augrabies Falls: Given the national and international significance of the site, we recommend that this project be abandoned completely. Alternatively, given the fatally flawed consultation process, we recommend that this project be halted and started again from scratch.

Augrabies Falls and Ritchie Falls projects and all other proposed projects along the length of the Orange River: Given the unknown cumulative effects of all of the various structures being planned for the Orange, including but not limited to

Coastal & Environmental Services 142 RVM 1 Hydro Electric Power Environmental Impact Assessment Report – Comment and Response Report

No. Issue Raised by Response from CES EIA team or Hydro SA hydro-electric power stations, dangerous “flood control’ weirs etc, we recommend that a Strategic Environmental Assessment as well as a Reserve Assessment be conducted for the river as a whole. South African National Roads Agency – Rene de Kock 114. Good day Shawn, Rene de Kock, South Dear Rene, Find attached requested locality maps. Thank you for your email. African National Roads Sincerely, Please forward locality plan to me. Agency Limited, Shawn Johnston Kind regards, Rene Western Region, comment by e-mail, 28 April 2015. 115. Riemvasm aak Run-of-River Hydro Power Station Water Use Rene de Kock, South Dear Rene, Application African National Roads You are most welcome. Agency Limited, Sincerely, Dear Shawn, Western Region, Shawn Johnston Thank you for your email. comment by e-mail, 28 Kind regards, Rene April 2015. Wilderness Foundation – Angus Tanner 116. Good afternoon Shawn, Angus Tanner, Dear Angus, Thank you for sending me the documents regarding the Wilderness Thank you for your e-mail. I have registered yourself and the proposed HydroSA Riemvasmaak Hydro Project. The Foundation, Senior Wilderness Foundation on the proposed HydroSA Riemvasmaak Wilderness Foundation was previously register as a IAP for Manager, Hydro Project environmental impact assessment study. Please this project in the beginning when the public stakeholder Conservation, provide me with comments once you have reviewed the current process was being handled by another company. I now see comment by e-mail, 11 draft environmental impact assessment report on the Coastal that we are not on the list of IAP’s according to the register May 2015. Environmental Services web site. attached to your mail. Can I re-•‐register us as an interested I look forward to receiving your input on the proposed project. and affected party with you? Sincerely, Shawn Johnston Thank you, Angus

Coastal & Environmental Services 143 RVM 1 Hydro Electric Power