FAUNA & FLORA SPECIALIST IMPACT ASSESSMENT:

NUWEVELD WEST WIND ENERGY FACILITY

PRODUCED FOR AURECON

First Draft April 2020

Revised October 2020

[email protected] EXECUTIVE SUMMARY

Red Cap Energy Pty Ltd (Red Cap) is proposing to develop three wind farms on a 35,000ha site situated about ~65km north of Beaufort West along the R381 to Loxton, in the Beaufort West Local Municipality, Central Karoo District Municipality, Western Cape. Aurecon South Africa are conducting the required EIA process and 3Foxes Biodiversity Solutions has been appointed to provide a specialist terrestrial fauna and flora specialist study of the proposed three wind farms as part of the EIA applications, one of them being the Nuweveld West Wind Farm which this study deals with.

The purpose of the Nuweveld West Terrestrial Biodiversity Report is to describe and detail the ecological features of the proposed site; provide an assessment of the ecological sensitivity of the affected area and identify the likely impacts that may be associated with the development of a wind farm on the site. Several site visits as well as a desktop review of the available ecological information for the area was conducted in order to identify and characterise the ecological features of the site.

Overall, the Nuweveld West site is considered generally favourable for development of the wind farm. Although there are some constrained areas where development should be minimised, there are large tracts of the site that are considered medium or low sensitivity and where development would have a low impact. Although impacts on the Riverine Rabbit are a potential concern, its presence on the escarpment is unlikely and the total extent of available habitat is low. Nevertheless, the high threat status associated with this species demands a conservative approach and no turbines or buildings (incl. substation and associated battery facility) should be located within the feature or buffer areas around the identified habitat features. With this avoidance in place, long-term impacts on Riverine Rabbits are likely to be low. The site also has a confirmed population of the Endangered Mountain Reedbuck and the development is likely to result in some transient impact on this species. The local population is however small and unlikely to be compromised by the development. In order to better understand the responses of these two species and fauna more generally to the development of the wind farm, it is recommended that that funding is provided towards a Fauna Monitoring Programme to be implemented at the site. The purpose of the monitoring would not be to directly inform or alter the operation of the current wind farm as a form of mitigation, but rather that the opportunity is used to collect baseline information on the manner in which fauna react to the construction and operation of a wind farm so that this information can be used to reduce potential conflict between wind farms and fauna more generally in the karoo and especially in areas where these conflicts may be potentially of greater consequence.

The most significant impacts associated with the Nuweveld West WEF would occur during the construction phase as a result of disturbance and habitat loss. Long-term operational impacts would be lower and restricted to low-level operational disturbance and turbine noise effects. Although there are some CBA1 areas within the site that would be affected by the development, a review of the basis and validity of these reveals that they are not irreplaceable and the general mitigation and avoidance of sensitive features identified as part of this assessment would be effective at maintaining the ecological functioning of the site. As such, the potential impacts of the development on CBAs are considered acceptable. In terms of cumulative impacts, the area has experienced no impact from wind farm development to date with the result that the wider area is still largely intact and the contribution of the current development to cumulative impact would be minor.

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The overall footprint of the development is well within the set limits of acceptable change and as such, there are no fatal flaws in this regard. There are no impacts associated with the development of the Nuweveld West WEF that cannot be mitigated to an acceptable level. As such, should all the proposed mitigation be implemented, this development is deemed acceptable from an ecological impact perspective. It is thus the reasoned opinion of the specialist that there the Nuweveld West WEF development should be allowed to proceed to the EIA phase.

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COMPLIANCE WITH APPENDIX 6 OF THE 2014 EIA REGULATIONS, AS AMENDED

Addressed in the Requirements of Appendix 6 – GN R326 2014 EIA Regulations, 7 April 2017 Specialist Report 1. (1) A specialist report prepared in terms of these Regulations must contain- a) details of- i. the specialist who prepared the report; and 6 ii. the expertise of that specialist to compile a specialist report including a curriculum vitae; b) a declaration that the specialist is independent in a form as may be specified by 7 the competent authority; c) an indication of the scope of, and the purpose for which, the report was Section 1 prepared; (cA) an indication of the quality and age of base data used for the specialist report; Section 2

(cB) a description of existing impacts on the site, cumulative impacts of the Section 3 proposed development and levels of acceptable change; d) the date and season of the site investigation and the relevance of the season Section 2.3 to the outcome of the assessment; e) a description of the methodology adopted in preparing the report or carrying out Section 2 the specialised process inclusive of equipment and modelling used; f) details of an assessment of the specific identified sensitivity of the site related to the proposed activity or activities and its associated structures and Section 3 infrastructure, inclusive of a site plan identifying site alternatives; g) an identification of any areas to be avoided, including buffers; Section 3 h) a map superimposing the activity including the associated structures and infrastructure on the environmental sensitivities of the site including areas to be Section 3 avoided, including buffers; i) a description of any assumptions made and any uncertainties or gaps in Section 2.3 knowledge; j) a description of the findings and potential implications of such findings on the Section 3 impact of the proposed activity or activities; k) any mitigation measures for inclusion in the EMPr; Section 6 l) any conditions for inclusion in the environmental authorisation; Section 7 m) any monitoring requirements for inclusion in the EMPr or environmental Section 6 authorisation; n) a reasoned opinion- i. whether the proposed activity, activities or portions thereof should be authorised; (iA) regarding the acceptability of the proposed activity or activities and Section 6 ii. if the opinion is that the proposed activity, activities or portions thereof should be authorised, any avoidance, management and mitigation measures that should be included in the EMPr, and where applicable, the closure plan; o) a description of any consultation process that was undertaken during the course See Main Report of preparing the specialist report; p) a summary and copies of any comments received during any consultation See Main Report process and where applicable all responses thereto; and

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q) any other information requested by the competent authority. 2) Where a government notice gazetted by the Minister provides for any protocol or Since Government minimum information requirement to be applied to a specialist report, the requirements Notice No. 320 has as indicated in such notice will apply. been gazetted, a verification report (Annex 5) and protocols (Annex 7)= and Annex 8) aligned with the requirements have been included in this report

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... 2 Compliance with Appendix 6 of the 2014 EIA Regulations, as Amended ...... 4 Table of Contents ...... 6 List of Figures ...... 8 Short CV/Summary of Expertise – Simon Todd ...... 10 Specialist Declaration ...... 12 1 Introduction ...... 13 1.1 Scope of Study ...... 13 1.2 Approach & Assessment Philosophy ...... 14 1.3 Relevant Aspects of the Development ...... 17 2 Methodology ...... 19 2.1 Data Sourcing and Review ...... 19 2.2 Site Visits & Field Assessment ...... 20 2.3 Sensitivity Mapping & Assessment ...... 21 2.4 Limitations & Assumptions ...... 25 2.5 DEA Site verification ...... 25 3 Description of the Affected Environment – Nuweveld West Wind Farm ...... 26 3.1 Vegetation & Plant Communities ...... 26 3.2 Listed Plant Species ...... 35 3.3 Critical Biodiversity Areas & Broad-Scale Processes ...... 35 3.4 Faunal Communities ...... 40 4 Nuweveld West WEF Sensitivity Assessment ...... 54 5 Impacts and Issues Identification ...... 58 5.1 Identification of Potential Impacts ...... 58 6 Assessment of Impacts – Nuweveld West WEF ...... 60 6.1 Construction Phase Impact 1. Impacts on vegetation and plant species of conservation concern ...... 60 6.2 Construction Phase Impact 2. Direct and indirect faunal impacts ...... 61 6.3 Construction Phase Impact 3. Construction Phase Impacts on Riverine Rabbits ...... 62 6.4 Construction Phase Impact 4. Construction Phase Impacts on Mountain Reedbuck ...... 64 6.5 Construction Phase Impact 5. Impact on CBAs ...... 65 6.6 Operational Phase Impact 1. Impacts on Fauna during operation ...... 66

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6.7 Operational Phase Impact 2. Impacts on Riverine Rabbits during operation ...... 67 6.8 Operational Phase Impact 3. Impacts on Mountain Reedbuck during operation ...... 68 6.9 Operational Phase Impact 4. Increased soil erosion risk during operation ...... 69 6.10 Decommissioning Phase Impact 1. Faunal impacts due to decommissioning ...... 70 6.11 Decommissioning Phase Impact 2. Increased soil erosion risk following decommissioning ... 71 6.12 Cumulative Impact 1. Cumulative Impacts on Broad-Scale Ecological Processes ...... 72 6.13 No-Go Alternative ...... 72 6.14 Summary Assessment...... 74 7 Conclusion & Recommendations ...... 74 8 References ...... 76 9 Annex 1. List of Plant Species ...... 78 10 Annex 2. List of Mammals ...... 95 11 Annex 3. Supplementary Herpetofauna Study By Sungazer Faunal Surveys ...... 97 ABBREVIATIONS ...... 99

EXECUTIVE SUMMARY ...... 100

11.1 INTRODUCTION AND STUDY AREA ...... 102

11.2 TERMS OF REFERENCE ...... 102

11.3 STUDY APPROACH AND METHODS ...... 103

11.4 RESULTS : GENERAL SITE DESCRIPTION AND HABITAT DIVERSITY ...... 104

11.5 RESULTS : REPTILE AND AMPHIBIAN LOCALITY RECORDS ...... 109

11.6 RESULTS : CHECKLISTS AND SPECIES OF CONSERVATION CONCERN ...... 111

11.7 CONCLUSIONS AND RECOMMENDATIONS ...... 119

11.8 REFERENCES ...... 121

11.9 APPENDIX 1: OBSERVATIONS OF THE 2020 SURVEY ...... 123

11.10 APPENDIX 2: TAXONOMIC NOTES AND INTRODUCED SPECIES ...... 124

11.11 APPENDIX 3: DECLARATION OF INDEPENDENCE ...... 127 12 Annex 4. Butterfly Specialist Assessment ...... 129 13 Annex 5. DEA Screening Tool Site Verification Report ...... 142 14 Annex 6. Beaufort West Bypass ...... 147 15 Annex 7. Criteria For The Assessment And Reporting Of Impacts On Terrestrial Animal Species For Activities Requiring Environmental Authorisation ...... 151 16 Annex 8. Criteria For The Assessment And Reporting Of Impacts On Terrestrial Biodiversity For Activities Requiring Environmental Authorisation ...... 155

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LIST OF FIGURES

Figure 1. Satellite image showing the location of the three proposed Nuweveld WEFs relative to Beaufort West and the R381. The boundary of the Nuweveld West WEF is shown with the yellow border...... 19 Figure 2. The national vegetation map (Mucina & Rutherford 2006/2012) for the Nuweveld West WEF and surrounding area. Rivers and wetlands (pans) delineated by the National Freshwater Ecosystem Priority Areas Assessment (Nel et al. 2011) are also depicted...... 27 Figure 3. Typical view of the plateau area which represents the majority of the Nuweveld West WEF study area, corresponding with the Eastern Upper Karoo vegetation type. Typical and dominant species include Pentzia incana , Eriocephalus spp., Rosenia spp., Lycium cinereum , Ruschia intricata and Zygophyllum retrofractum ...... 29 Figure 4. Aerial view over the plateau which forms the majority of the Nuweveld West WEF site. Although most of this area can be considered to represent Eastern Upper Karoo, there are also numerous slopes and rocky outcrops present which represent Upper Karoo Hardeveld...... 30 Figure 5. There are numerous rocky outcrops as well as rocky slopes within the Nuweveld West site that represent the Upper Karoo Hardeveld vegetation type...... 31 Figure 6. Most of the drainage lines within the Nuweveld West Wind Farm site are not well-developed or occur on bedrock, with the result that there is very little riparian vegetation present. Such drainage lines are considered unlikely to harbour Riverine Rabbits...... 32 Figure 7. Well-developed riparian vegetation along a drainage line within the Nuweveld West site. Such areas with dense riparian vegetation dominated by palatable species are considered to represent the most favourable habitat for Riverine Rabbits at the site, but are of very limited extent...... 32 Figure 8. A drainage line with permanent pools within the Nuweveld West study area. Such permanent pools are important for fauna such as amphibians, but would also be vulnerable to disturbance and pollution from nearby development activities...... 33 Figure 9. Example of one of the endorheic (without outflow) pans which occurs on the plateau area of the Nuweveld West wind farm...... 34 Figure 10. Example of one of the rock pavements from the area. Although these areas appear to be devoid of vegetation, they are home to numerous small succulents (as pictured in the thumbnails at right) and geophytes which are specialised inhabitants of these areas...... 34 Figure 11. Extract of the Western Cape Biodiversity Spatial Plan for the Nuweveld West study area, showing that there are several small isolated CBAs within the site as well as some larger more extensive CBAs with a few turbines in them...... 40 Figure 12. Canids and Felids observed at the site include, clockwise from top left, Aardwolf, Caracal, Black-backed Jackal, African Wildcat, Cape Fox and Bat-eared Fox...... 46 Figure 13. Small carnivores present at the site include, from top left, Suricate, Yellow Mongoose, Striped Polecat, Water Mongoose, Common Genet and Cape Grey Mongoose...... 47

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Figure 14. Rodents and Afrotheria present at the site include from top left, South African Ground Squirrel, Rock Hyrax, Aardvark and Cape Porcupine...... 48 Figure 15. Indigenous ungulates present at the site include, clockwise from top left Klipspringer, Mountain Reedbuck, Kudu, Steenbok and Springbok...... 49 Figure 16. Splitting hares… Hewitt's Red Rock Hare top left and the remaining images are all the Cape Hare illustrated from various camera locations and habitats across the site. No Riverine Rabbits were recorded by the camera traps...... 50 Figure 17. Reptiles photographed during the site visits. From bottom left, Karroo Girdled Lizard, Ground Agama, Puff Adder, Leopard Tortoise and Karoo Tent Tortoise...... 52 Figure 18. Amphibians observed at the site include the Karoo Toad, top left and the Common Platanna, above and Cape River Frog, left...... 53 Figure 19. Ecological sensitivity map for turbines, roads, cables and overhead lines for the Nuweveld West WEF area...... 57

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SHORT CV/SUMMARY OF EXPERTISE – SIMON TODD

Simon Todd is Director and principal scientist at 3Foxes Biodiversity Solutions and has over 20 years of experience in biodiversity measurement, management and assessment. He has provided specialist ecological input on more than 200 different developments distributed widely across the country, but with a focus on the three Cape provinces. This includes input on the Wind and Solar SEA (REDZ) as well as the Eskom Grid Infrastructure (EGI) SEA and Karoo Shale Gas SEA. He is on the National Vegetation Map Committee as representative of the Nama and Succulent Karoo Biomes. Simon Todd is a recognised ecological expert and is a past chairman and current deputy chair of the Arid-Zone Ecology Forum. He is registered with the South African Council for Natural Scientific Professions (No. 400425/11).

Skills & Primary Competencies • Research & description of ecological patterns & processes in Nama Karoo, Succulent Karoo, Thicket, Arid Grassland, Fynbos and Savannah Ecosystems. • Ecological Impacts of land use on biodiversity • Vegetation surveys & degradation assessment & mapping • Long-term vegetation monitoring • Faunal surveys & assessment. • GIS & remote sensing

Tertiary Education: • 1992-1994 – BSc (Botany & Zoology), University of Cape Town • 1995 – BSc Hons, Cum Laude (Zoology) University of Natal • 1996-1997- MSc, Cum Laude (Conservation Biology) University of Cape Town

Employment History • 2009 – Present – Sole Proprietor of Simon Todd Consulting, providing specialist ecological services for development and research. • 2007 Present – Senior Scientist (Associate) – Plant Conservation Unit, Department of Botany, University of Cape Town. • 2004-2007 – Senior Scientist (Contract) – Plant Conservation Unit, Department of Botany, University of Cape Town

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• 2000-2004 – Specialist Scientist (Contract ) - South African National Biodiversity Institute • 1997 – 1999 – Research Scientist (Contract) – South African National Biodiversity Institute

A selection of recent work is as follows:

Strategic Environmental Assessments Co-Author. Chapter 7 - Biodiversity & Ecosystems - Shale Gas SEA. CSIR 2016. Co-Author. Chapter 1 Scenarios and Activities – Shale Gas SEA. CSIR 2016. Co-Author – Ecological Chapter – Wind and Solar SEA. CSIR 2014. Co-Author – Ecological Chapter – Eskom Grid Infrastructure SEA. CSIR 2015. Contributor – Ecological & Conservation components to SKA SEA. CSIR 2017.

Recent Specialist Ecological Studies in the Vicinity of the Current Site Environmental Impact Assessment for the Proposed Komsberg East and Komsberg West Wind Farms and Associated Grid Connection Infrastructure: Fauna & Flora Specialist Impact Assessment. Arcus Consulting 2014. Proposed Rietkloof & Brandvallei Wind Farms and Associated Grid Connection Infrastructure: Fauna & Flora Specialist Impact Assessment Report. EOH 2016. Proposed Gunstfontein Wind Farm and Associated Grid Connection Infrastructure: Fauna & Flora Specialist Impact Assessment Report. Savannah Environmental 2016. Mainstream South Africa Dwarsrug Wind Energy Facility: Fauna & Flora Specialist Impact Assessment Report. Sivest 2014. Phezukomoya and San Kraal Wind Energy Facilities and associated grid connection. Fauna and Flora specialist studies. Arcus Consulting 2018. Kokerboom Wind Energy Facilities (1-4) and associated grid connections. Fauna and Flora specialist studies. Aurecon 2017.

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SPECIALIST DECLARATION

I, ..Simon Todd...... , as the appointed independent specialist, in terms of the 2014 EIA Regulations, hereby declare that I: . . I act as the independent specialist in this application; . I perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant; . regard the information contained in this report as it relates to my specialist input/study to be true and correct, and do not have and will not have any financial interest in the undertaking of the activity, other than remuneration for work performed in terms of the NEMA, the Environmental Impact Assessment Regulations, 2014 and any specific environmental management Act; . I declare that there are no circumstances that may compromise my objectivity in performing such work; . I have expertise in conducting the specialist report relevant to this application, including knowledge of the Act, Regulations and any guidelines that have relevance to the proposed activity; . I will comply with the Act, Regulations and all other applicable legislation; . I have no, and will not engage in, conflicting interests in the undertaking of the activity; . I have no vested interest in the proposed activity proceeding; . I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority; . I have ensured that information containing all relevant facts in respect of the specialist input/study was distributed or made available to interested and affected parties and the public and that participation by interested and affected parties was facilitated in such a manner that all interested and affected parties were provided with a reasonable opportunity to participate and to provide comments on the specialist input/study; . I have ensured that the comments of all interested and affected parties on the specialist input/study were considered, recorded and submitted to the competent authority in respect of the application; . all the particulars furnished by me in this specialist input/study are true and correct; and . I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of the Act.

Signature of the specialist: ______

Name of Specialist: ____Simon Todd______

Date: ____14 April 2020______

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1 INTRODUCTION

Red Cap Energy (Pty) Ltd is proposing to develop three wind farms on a 35,000ha site situated about ~65km north of Beaufort West along the R381 to Loxton, in the Beaufort West Local Municipality, Central Karoo District Municipality, Western Cape. Aurecon South Africa are conducting the required EIA process and 3Foxes Biodiversity Solutions has been appointed to provide a specialist terrestrial fauna and flora specialist study of the three proposed wind farms as part of the EIA applications, one of them being the Nuweveld West Wind Farm which this study deals with .

The purpose of the Nuweveld West Terrestrial Biodiversity Scoping Report is to describe and detail the ecological features of the proposed wind farm site; provide a preliminary assessment of the ecological sensitivity of the affected area and identify the likely impacts that may be associated with the development of a WEF and associated infrastructure. Numerous site visits (detailed in Section 1.1.4) as well as a desktop review of the available ecological information for the area was conducted in order to identify and characterise the ecological features of the site. This information is used to derive an ecological sensitivity map that presents the ecological constraints for the development and which has been used to inform the layout of the development. Finally, a statement is made as to the general ecological acceptability of the Nuweveld West Wind Farm and whether or not the development should proceed into the EIA phase.

1.1 SCOPE OF STUDY

The study includes the following activities:

• a description of the environment that may be affected by a specific activity and the manner in which the environment may be affected by the proposed project; • a description and evaluation of environmental issues and potential impacts (including assessment of direct, indirect and cumulative impacts) that have been identified; • a statement regarding the potential significance of the identified issues based on the evaluation of the issues/impacts; • an indication of the methodology used in determining the significance of potential environmental impacts; • an assessment of the significance of direct indirect and cumulative impacts of the development; • a description and comparative assessment of all alternatives including cumulative impacts; • recommendations regarding practical mitigation measures for potentially significant impacts, for inclusion in the Environmental Management Programme (EMPr); • an indication of the extent to which the issue could be addressed by the adoption of mitigation measures; • a description of any assumptions uncertainties and gaps in knowledge; and

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• an environmental impact statement which contains: • a summary of the key findings of the environmental impact assessment; • an assessment of the positive and negative implications of the proposed activity; and • a comparative assessment of the positive and negative implications of identified alternatives.

General Considerations for the study included the following:

• Disclose any gaps in information (and limitations in the study) or assumptions made. • Identify recommendations for mitigation measures to minimise impacts. • Outline additional management guidelines. • Provide monitoring requirements, mitigation measures and recommendations in a table format as input into the EMPr for faunal or flora related issues. • The assessment of the potential impacts of the development and the recommended mitigation measures provided have been separated into the following project phases: - Planning and Construction - Operational - Decommissioning

1.2 APPROACH & ASSESSMENT PHILOSOPHY

This assessment is conducted according to the 2014 EIA Regulations (Government Notice Regulation 982) in terms of the National Environmental Management Act (Act 107 of 1998) as amended (NEMA), as well as the recently promulgated notice issued in terms of NEMA, “National Environmental Management Act, 1998 (Act No. 107 Of 1998): Procedures to be followed for the assessment and minimum criteria for reporting of identified environmental themes in terms of section 24(5)(a) and (h) and 44 of the National Environmental Management Act, 1998, when applying for environmental authorisation [G 43110 – GN 320]”. The applicable site verification report as required, is included under Annex 5 of this report and the required Protocol for the assessment and reporting of environmental impacts on terrestrial animal species is provided in Annex 7 criteria for the assessment and reporting of impacts on terrestrial biodiversity for activities requiring environmental authorisation is provided in Annex 8. It should however be noted that this assessment does not need to be aligned with the protocols, since the DEA has indicated that irrespective of whether an EA application for a development has been submitted, if an assessment started before the protocols came into effect on 9 May 2020 the protocols are not applicable and the assessment should adhere Appendix 6 of the EIA regulations. Since this assessment commenced in 2019, the study should comply with Appendix 6. However, the content of this report is aligned to be compliant to Appendix 6 and protocols

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In terms of NEMA, this assessment demonstrates how the proponent intends to comply with the principles contained in Section 2 of NEMA, which amongst other things, indicates that environmental management should: • (In order of priority) aim to: avoid, minimize or remedy disturbance of ecosystems and loss of biodiversity; • Avoid degradation of the environment; • Avoid jeopardizing ecosystem integrity; • Pursue the best practicable environmental option by means of integrated environmental management; • Protect the environment as the people’s common heritage; • Control and minimize environmental damage; and • Pay specific attention to management and planning procedures pertaining to sensitive, vulnerable, highly dynamic or stressed ecosystems.

Furthermore, in terms of best practice guidelines as outlined by Brownlie (2005) and De Villiers et al. (2005), a precautionary and risk-averse approach should be adopted for projects which may result in substantial detrimental impacts on biodiversity and ecosystems, especially the irreversible loss of habitat and ecological functioning in threatened ecosystems or designated sensitive areas: i.e. CBAs (as identified by systematic conservation plans, Biodiversity Sector Plans or Bioregional Plans) and Freshwater Ecosystem Priority Areas.

In order to adhere to the above principles and best-practice guidelines, the following approach forms the basis for the study approach and assessment philosophy: • The study includes data searches, desktop studies, site walkovers / field survey of the property and baseline data collection, describing: - The broad ecological characteristics of the site and its surrounds in terms of any mapped spatial components of ecological processes and/or patchiness, patch size, relative isolation of patches, connectivity, corridors, disturbance regimes, ecotones, buffering, viability, etc.

In terms of pattern , the following will be identified or described:

Community and ecosystem level • The main vegetation type, its aerial extent and interaction with neighbouring types, soils or topography; • Threatened or vulnerable ecosystems ( cf. SA vegetation map/National Spatial Biodiversity Assessment, fine-scale systematic conservation plans, etc ).

Species level • Species of Conservation Concern (SCC) (giving location if possible using GPS);

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• The viability of an estimated population size of the SCC species that are present (including the degree of confidence in prediction based on availability of information and specialist knowledge, i.e. High=70-100% confident, Medium 40-70% confident, low 0-40% confident); • The likelihood of other Red Data Book species, or SCC, occurring in the vicinity (include degree of confidence).

Fauna • Describe and assess the terrestrial fauna present in the area that will be affected by the proposed development; • Conduct a faunal assessment that can be integrated into the ecological study; • Describe the existing impacts of current land use as they affect the fauna; • Clarify species of special concern and that are known to be: o endemic to the region; o that are considered to be of conservational concern; o that are in commercial trade (CITES listed species); or o are of cultural significance. • Provide monitoring requirements as input into the EMPr for faunal related issues.

Other pattern issues • Any significant landscape features or rare or important vegetation associations such as seasonal wetlands, alluvium, seeps, quartz patches or salt marshes in the vicinity’ • The extent of alien plant cover of the site, and whether the infestation is the result of prior soil disturbance such as ploughing or quarrying (alien cover resulting from disturbance is generally more difficult to restore than infestation of undisturbed sites); • The condition of the site in terms of current or previous land uses.

In terms of process , the following will be identified and/or described: • The key ecological “drivers” of ecosystems on the site and in the vicinity, such as fire. • Any mapped spatial component of an ecological process that may occur at the site or in its vicinity (i.e. corridors such as watercourses, upland-lowland gradients, migration routes, coastal linkages or inland-trending dunes, and vegetation boundaries such as edaphic interfaces, upland-lowland interfaces or biome boundaries). • Any possible changes in key processes, e.g. increased fire frequency or drainage/artificial recharge of aquatic systems. • Furthermore, any further studies that may be required during or after the EIA process will be outlined. • All relevant legislation, permits and standards that would apply to the development will be identified. • The opportunities and constraints for development will be described and shown graphically on an aerial photograph, satellite image or map delineated at an appropriate level of spatial accuracy.

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1.3 RELEVANT ASPECTS OF THE DEVELOPMENT

The Nuweveld West Wind Energy Facility is illustrated below in Figure 1 and includes potential locations up to 38 turbines, although a maximum of 35 turbines will be developed on site. This assessment therefore assumes the worst case in terms the area affected by the development. A summary of the project components and their estimated footprint areas is provided below in Table 1.

Table 1. Summary of the Nuweveld West Wind Farm components and specifications. Project Specifications & Footprint areas Estimated Components Combined Description Footprint (ha) Approximately 65 km north of Beaufort West and approximately 30 km south of Location Loxton along the R381. Land use of the site and surrounding properties comprise of extensive livestock farming (grazing). Total Wind farm area is 12796 ha • 38 potential turbine locations assessed for approval but only up to a maximum of 35 wind turbines will be constructed. • No Turbines are located to the West of the R381. • Turbine envelope:

o Rotor diameter: 120m to 190m (up to 95m blade / radius) Wind Turbines o Hub height: 80m to 150m o Rotor top tip height: 140m to 245m (maximum based on 150m hub + 95m blade = 245m) o Rotor bottom tip height: minimum of 25 m (and not lower). • Generation capacity: up to maximum of 8MW output per turbine • Nuweveld West has a targeted nameplate capacity of up to a maximum of 280MW. Turbine Each turbine will have a circular foundation with a diameter of up to 32m and 4.5ha (permanent) Foundations this will be placed alongside the 40m wide hardstand resulting in an area of about 40mx32m that will be permanently disturbed for the turbine foundation. Turbine Each turbine will have a hardstand of 80m x 40 m. 11.2ha (permanent) Hardstands Turbines to be connected to on-site substation via 33kV cables. Cables to be laid underground in trenches mainly adjacent to roads or overhead via 33kV monopoles where burying is not possible due to technical, geological, 1.7ha (temporary) environmental or topographical constraints. The length of the cabling that is Cabling not adjacent to the wind farm roads is 5.8km but of this about 0.3km is running along an existing road thus reducing the impact. The potential area impacted is recorded here for the off-road cables and those sections that run along proposed wind farm roads are covered within the temporary road disturbance footprint, see below. Internal WEF 5.3km of 33kV overhead powerline with pylons of up to 20m high. The overhead majority of this (2.9km) will be running next to the proposed Eskom grid 1.6ha (permanent) powerlines connection ensuring the majority of the internal overhead line impacts are in the same corridor as the proposed grid connection. Permanent roads will be 6m wide and may require side drains on one or both ≤54-65ha sides. All roads may have underground cables running next to them. A 12m Site roads (permanent)* wide road corridor may be temporary impacted during construction and rehabilitated to 6m wide after construction. For Nuweveld West a total road ≤46ha (temporary)* network of about 76,4km is proposed and the area impacted is presented

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here. Of this 76,4km, a total of 27 km is shared infrastructure with Nuweveld North & East. A temporary bypass road is required on the N1 to avoid the town of Beaufort West with the major Wind Farm components. The road will be up to 6m wide 6.8ha (temporary) N1 Bypass Road but a 12m wide road corridor may be temporary impacted during construction

and rehabilitated once construction is complete. The length of the temporary road will be about 5.6km of which about 2.5km is along an existing track. Wind farm will have a 150m x 75m substation yard which includes an Wind farm Operation and Maintenance (O&M) building, Substation building and a High Substations and Voltage Gantry as well as a 2.4 ha area for battery storage facility which may 3.6ha (permanent) battery facility be adjacent or slightly removed from the substation depending on the local constraints. The substation and battery facility will be connected by an underground or overhead cable Operations and The O&M area will include all offices, stores, workshops, laydown area Forms part of maintenance Building & Substation building will be housed in the substation yard. Substation yard (O&M) area

• Security gate and hut to be installed at entrance to site. • No fencing around individual turbines, existing fencing shall remain Security 20m 2 around perimeter of properties. • Temporary and permanent yard areas to be enclosed (with access control) with an up to 2.4m high fence. • Wind farm temporary construction areas: 2.2ha (temporary) Temporary o laydown, staging Temporary site camp/s areas: 20,000m2 o and yards areas Batching plant area of approximately 2,000m2 required for the o Each wind farm will have a bunded fuel & lubricants storage facility on construction / site in fixed tanks not exceeding 80m 3 (situated at the site camp). decommissioning • phase. Individual turbine temporary laydown areas including crane boom laydown areas, blade laydown areas and other potential temporary areas 17.5ha (temporary) will be up to a maximum of 5000m2. 75ha temporary and Total disturbance footprint 86ha permanent*

*these areas represent more than will be impacted given the road values are based on all 38 turbines being constructed wherein reality only 35 turbines will be developed as part of this application.

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 18

Figure 1. Satellite image showing the location of the three proposed Nuweveld WEFs relative to Beaufort West and the R381. The boundary of the Nuweveld West WEF is shown with the yellow border.

2 METHODOLOGY

2.1 DATA SOURCING AND REVIEW

Data sources from the literature consulted and used where necessary in the study includes the following:

Vegetation: • Vegetation types and their conservation status were extracted from the South African National Vegetation Map (2018 update). • Information on plant and animal species recorded for the wider area was extracted from the SABIF/SIBIS database hosted by SANBI. Data was extracted for a significantly larger area than the study area, but this is necessary to ensure a conservative approach as well as counter the fact that the site itself has not been well sampled in the past. • The IUCN conservation status of the species in the list was also extracted from the database and is based on the Threatened Species Programme, Red List of South African Plants (2020).

Ecosystem: • Freshwater and wetland information was extracted from the National Freshwater Ecosystem Priority Areas assessment, NFEPA (Nel et al. 2011).

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 19

• Critical Biodiversity Areas in the study area were obtained from the 2017 Western Cape Biodiversity Spatial Plan (WC-BSP), for the Beaufort West municipality, which includes the study area.

Fauna • Lists of mammals, reptiles and amphibians which are likely to occur at the site were derived based on distribution records from the literature and the ADU databases (ReptileMap, Frogmap and MammalMap) http://vmus.adu.org.za. • Literature consulted includes Branch (1988) and Alexander and Marais (2007) for reptiles, Du Preez and Carruthers (2009) for amphibians, EWT & SANBI (2016) and Skinner and Chimimba (2005) for mammals. • The faunal species lists provided are based on species which are known to occur in the broad geographical area, as well as an assessment of the availability and quality of suitable habitat at the site. • The conservation status of mammals is based on the IUCN Red List Categories (EWT/SANBI 2016), while reptiles are based on the South African Reptile Conservation Assessment (Bates et al. 2013) and amphibians on Minter et al. (2004) as well as the IUCN (2020).

2.2 SITE VISITS & FIELD ASSESSMENT

The site was visited on four occasions for the current study, from 13-15 June 2019, 17-19 September 2019, 10-12 October 2019 and 24-28 February 2020. The initial site visit included a helicopter flight along the power line alignment as well as across the wind farm area, which was important in obtaining an aerial view of features not easily observed on the ground. During the site visits, the wind farm site was extensively investigated in the field. Potentially sensitive features within the site were investigated, validated and characterised in the field including any pans, rocky outcrops and major drainage features that were observed in the field or from satellite imagery of the site. As the site has been investigated for wind farm development previously, the area was also visited in August 2013 for a screening study for a previous wind farm development in the area. Apart from the above site visits, the vegetation of the veld and riparian areas at various locations in the study area was sampled by the consultant in 2018 as part of EWT-lead research into veld condition and Riverine Rabbit habitat assessment. Thus the consultant has a very good understanding of the site which has been developed over the years from 2013 to present.

In terms of the actual sampling approaches that has been used, the vegetation of the site has been characterised through walk-through surveys distributed across the site, in which plant species lists for the different habitats observed were compiled. Specific attention was paid to the presence of species of conservation concern (SCC) as well as other species which are considered to be of ecological significance. In terms of fauna, active searches were conducted for reptiles and amphibians across the site, within habitats where such species are likely to be encountered. In addition, all reptiles and amphibians encountered while doing other field work

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 20 were recorded. As the Riverine Rabbit is a species of particular concern at the site, camera trapping was extensively used across the whole Nuweveld site to establish the presence or absence of the Riverine Rabbit and also to characterise the fauna of the site more generally. A total of 50 camera traps were distributed across the site, which includes the Nuweveld West as well as the Nuweveld East and Nuweveld North WEFs project areas. As the Riverine Rabbit was identified as a species of particular potential concern, camera traps were concentrated within riparian areas identified as potential habitat for this species. This amounted to approximately two-thirds of the cameras and the remainder were located in other habitats. In order to increase the number of fauna captured, the cameras were placed along paths, fences etc. where fauna are likely to pass and be captured by the cameras. The cameras were placed in November 2019, checked in February 2020 and removed in mid July 2020, resulting in 8 months of continuous camera trapping information available for the current study.

2.3 SENSITIVITY MAPPING & ASSESSMENT

An ecological sensitivity map of the site was produced by integrating the results of the site visits with the available ecological and biodiversity information in the literature and various spatial databases as described above. As a starting point, mapped sensitive features such as wetlands, drainage lines, rocky hills and pans were collated and buffered where appropriate to comply with legislative requirements or ecological considerations. Additional sensitive areas were then identified from the satellite imagery of the site and delineated. All the different layers created were then merged to create a single coverage. The ecological sensitivity of the different units identified in the mapping procedure was rated according to the scale as indicated below.

• Low – Areas of natural or transformed habitat with a low sensitivity where there is likely to be a negligible impact on ecological processes and terrestrial biodiversity. Most types of development can proceed within these areas with little ecological impact. • Medium - Areas of natural or previously transformed land where the impacts are likely to be largely local and the risk of secondary impact such as erosion low. These areas usually comprise the bulk of habitats within an area. Development within these areas can proceed with relatively little ecological impact provided that appropriate mitigation measures are taken. • High – Areas of natural or transformed land where a high potential impact is anticipated due to the high biodiversity value, sensitivity or important ecological role of the area. These areas may contain or be important habitat for faunal species or provide important ecological services such as water flow regulation or forage provision. Development within these areas is undesirable and should only proceed with caution (such as specific consideration of the footprint within these areas and field verification of the acceptability of development within these potentially sensitive areas) as it may not be possible to mitigate all impacts appropriately. • Very High – Critical and unique habitats that serve as habitat for rare/endangered species or perform critical ecological roles. These areas are usually no-go areas from a developmental perspective and should be avoided. Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 21

Riverine Rabbit Sensitivity Mapping As the potential presence of the Riverine Rabbit at the site is a potential issue of very high significance, this has been explicitly and independently dealt with from the rest of the ecological sensitivities. Riverine Rabbit sensitivity was dealt with as follows:

• Areas of potential riparian habitat associated with the potential presence of the Riverine Rabbit at the site were identified from satellite imagery, the flight over the site and ground-based fieldwork. • Areas where there appeared to be sufficient suitable habitat to support rabbits were mapped and buffered by 300m to create areas of high potential occurrence considered to be Very High sensitivity. An additional outer buffer of 200m was also created and mapped as High sensitivity. The buffers were then extended or reduced based on the landscape features present such that the buffer was reduced where they extended into adjacent steep mountainous terrain where rabbits are unlikely to occur or extended subjectively on plains where rabbits are more likely to forage outside of the riparian areas. • As the major long-term impact associated with the wind farm is potentially noise generated by the turbines, the buffer is intended to keep turbines away from areas where there is a high potential presence of rabbits. As such, the very high sensitivity areas are considered no-go areas for turbines, buildings and the substation (and associated battery facility), but a limited amount of access roads or other infrastructure within the Very High sensitivity areas is considered acceptable contingent on the total footprint within these areas remaining within the limits of acceptable change as outlined below. • It is important to note that no rabbits have, as yet, been confirmed present in the identified areas despite having numerous cameras located in these areas. However, given the high threat status of the rabbit, the buffering and sensitivity mapping is considered precautionary.

Limits of Acceptable Change Over and above the sensitivity rating mapping, a further level of impact reduction is applied by using limits of acceptable change within each of these sensitivity ratings. Limits of acceptable change for each sensitivity category are indicated below and refer to the extent of on-site habitat loss within each sensitivity category that is considered acceptable before significant ecological impact that is difficult to mitigate and which may compromise the development is likely to occur. The limits of acceptable change are better assessed in a cumulative approach and have thus been determined considering the outer boundaries of the three wind farms that comprise the Nuweveld Wind Farm Development. As the sensitive habitats are not defined by each individual wind farm boundary but run across these ecologically arbitrary boundaries it makes more sense from an ecological perspective to look at all three adjacent wind farms together when looking at limits of acceptable change as this would be assessing the worst case scenario for such change. If one or two of the wind farms for some reason do not go ahead, then there will be less habitat loss than is being assumed here which ensures that this assessment represents a worst case scenario in terms of habitat loss within each sensitivity category. This provides a guide for the

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 22 developer in terms of ensuring that the spatial distribution of impact associated with the development is appropriate with respect to the sensitivity of the site. In addition, it provides a benchmark against which impacts can be assessed and represents an explicit threshold that when exceeded indicates that potentially unacceptable impacts may have occurred. In terms of this latter criterion, exceeding the limits of acceptable change for either High or Very High sensitivity areas is considered to represent an immediate fatal flaw, while the limits within either Low or Medium sensitivity areas could potentially be exceeded, provided that the total footprint in these two areas combined does not exceed the overall combined acceptable loss within these classes. However, in the latter case, this would raise significant concern regarding the suitability of the development and the exact spatial configuration of the development and the likely impacts on ecological processes would need to be considered.

It is important to note that irrespective of the limits of acceptable change and whether the development is within the limits, the specialist may still identify areas within the site that are unacceptable for development and will require the turbines and/or infrastructure to be moved outside these areas. This is further discussed in Section 4.

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 23

Table 1. Limits of acceptable change associated with the wind farm development, within each of the sensitivity categories as defined below. Acceptable Sensitivity Description Loss Units with a low sensitivity where there is likely to be a low impact on ecological processes and terrestrial biodiversity. This category Low 5% represents transformed or natural areas where the impact of development is likely to be local in nature and of low significance with standard mitigation measures. Areas of natural or previously transformed land where the impacts are likely to be largely local and the risk of secondary impacts such Medium 2% as erosion low. Development within these areas can proceed with relatively little ecological impact provided that appropriate mitigation measures are taken. Areas of natural or transformed land where a high impact is anticipated due to the high biodiversity value, sensitivity or important ecological role of the area. Development within these High 1% areas is undesirable and should only proceed with caution. Where roads are required through these areas, existing access roads should preferably be used as this reduces both the impact and the footprint of any access roads. Critical and unique habitats that serve as habitat for rare/endangered species or perform critical ecological roles. These areas are essentially no-go areas from a developmental perspective and should be avoided. Where linear Very High sensitivity features need to be traversed, existing roads or disturbance footprints should be used as far as possible. From a practical perspective some access roads will need to traverse drainage lines which are classified as Very High sensitivity. The Very High/No <0.5% acceptability of the final locations should be informed by the Go freshwater specialist, but should also be subject to the limits of acceptable change as determined here. Where there are existing transformation footprints within these areas, these should be used in preference to creating new access routes or other disturbances. Not all existing road footprint areas are included in the current fine- scale mapping and the final calculation of the footprint within the very high sensitivity categories will take cognisance of areas where access routes follow existing major roads.

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 24

2.4 LIMITATIONS & ASSUMPTIONS

The current study is based on numerous site visits as well as an associated desktop study. This significantly reduces the assumptions required for the current study and in particular the sensitivity mapping. Although it was very dry during the 2019 site visits, there were good summer rains in the summer with the results that the conditions in the February 2020 were excellent for the vegetation assessment. As a result there are few limitations in this regard and the timing of the site visit is not seen to limit the results of the study in any way.

In terms of fauna, many species are shy or rare and their potential presence at the site must be evaluated based on the literature and available databases. In many cases, these databases are not intended for fine-scale use and the reliability and adequacy of these data sources relies heavily on the extent to which the area has been sampled in the past. Many remote areas have not been well-sampled with the result that the species lists derived for the area do not always adequately reflect the actual fauna and flora present at the site. In order to further reduce this limitation, and ensure a conservative approach, the species lists derived for the site from the literature were obtained from an area significantly larger than the study site. As the site falls within the known distribution of the Riverine Rabbit, specific attention was paid to the presence and distribution of the riparian floodplains known to be the dominant habitat of this species in the area. In addition, 50 camera traps were distributed across the three Nuweveld wind farms in order to check for the presence of this species within the wind farm site as well as inform the presence of fauna in the area more generally. This information is significantly more reliable than the available desktop information and provides a reliable and comprehensive indication of the terrestrial vertebrate faunal community of the site.

2.5 DEA SITE VERIFICATION

Government Notice No. 320, dated 20 March 2020, includes the requirement that an Initial Site Sensitivity Verification Report must be produced for a development footprint. The outcomes of the Site Verification Report determine the level of assessment required for the site.

The full verification report is included in Annex 5 but in summary, the DEA Screening Tool identified the site as having a medium and high animal sensitivity theme due to the presence of the Riverine Rabbit in the area and the modelled potential presence of the Karoo Padloper in the area. There were no botanical sensitivities known from the area and the overall combined Terrestrial Biodiversity theme indicates that the site consists largely of low sensitivity areas with areas of Very High sensitivity associated with the CBAs and drainage features of the site. There is a relatively high level of congruence between the animal species sensitivity theme and the mapped ecological sensitivity in this study. The output of the combined Terrestrial Biodiversity theme is coarse and does not adequately capture the heterogeneity of the site and the delineation of the actual features present. The outputs of the Screening Tool are based on existing biodiversity information, which for many areas such as the Nuweveld, is very sparse and not well-populated, with the result that this consists largely of modelled data and the

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 25 potential presence of species of concern which need to be verified through the field assessment and site verification exercise. To this end, the current study identified a number of additional fauna species of concern that are either confirmed present such as the Mountain Reedbuck, or potentially present on site or in the general area including the Black-footed Cat Felis nigripes (VU), Grey Rhebok Pelea capreolus (NT), and Brown Hyena Hyaena brunnea (NT).

Due to the fact that the site contains areas of High sensitivity in terms of the Animal Species Theme and Very High sensitivity in terms of the Terrestrial Biodiversity Theme, a Terrestrial Animal Species Impact Assessment and a Terrestrial Biodiversity Impact Assessment as outlined within the “The Assessment And Reporting Of Impacts On Terrestrial Animal Species For Activities Requiring Environmental Authorisation “ and “Protocol for the specialist assessment and minimum report content requirements for environmental impacts on terrestrial biodiversity ”, respectively, must be undertaken and the protocols for these assessments should be followed. This assessment is aligned with both the protocols. For reference purposes and as guide to the content of this report, the protocols are provided in Annex 7 and Annex 8 of this report. In terms of the Plant Species Protocol, since the site is located in a low sensitivity area, a terrestrial plant species compliance statement must be compiled. Since the other two protocols require impact assessments, this study goes over and above the content requirements of a compliance statement.

3 DESCRIPTION OF THE AFFECTED ENVIRONMENT – NUWEVELD WEST WIND FARM

This section deals with the baseline environment of the Nuweveld West Wind Farm and adjacent affected areas. The proposed Beaufort West bypass road is some distance from the wind farm and in order to maintain clarity between these two areas and since its shared infrastructure between the three wind farms, the baseline environment of the bypass is described in Annex 6, along with the maps illustrating the vegetation types, CBAs etc. as relevant to the bypass.

3.1 VEGETATION & PLANT COMMUNITIES

The national vegetation map (Mucina & Rutherford 2006 & 2018 update) for the study area is depicted below in Figure 2. The majority of the Nuweveld West site is classified as Eastern Upper Karoo with some areas of Upper Karoo Hardeveld associated with the steep slopes and escarpments of the site. This is however a gross oversimplification of the vegetation of the site and a more detailed habitat map to inform the current study was produced through detailed mapping from satellite imagery and ground verification (Figure 3). A particular shortcoming of the VegMap is the under-mapping of Upper Karoo Hardeveld at the site, which predominates on most slopes and escarpment edges of the site. The different vegetation and habitat types within the site are described and illustrated below with images from characteristic sites within the WEF.

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 26

Figure 2. The national vegetation map (Mucina & Rutherford 2006/2012) for the Nuweveld West WEF and surrounding area.

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 27

Figure 3. Detailed map of plant communities and habitats observed at the Nuweveld North Wind Farm site. This is considered to provide a more realistic and representative indication of the vegetation of the site than the VegMap, which is very coarse and does not adequately capture the heterogeneity of the site.

Eastern Upper Karoo Eastern Upper Karoo, has an extent of 49 821 km 2 and is the most extensive vegetation type in South Africa and forms a large proportion of the central and eastern Nama Karoo Biome. This vegetation type is classified as Least Threatened, and about 2% of the original extent has been transformed largely for intensive agriculture. Eastern Upper Karoo is however poorly protected

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 28 and less than 1% of the 21% target has been formally conserved. Mucina & Rutherford (2006) list eight endemic species for this vegetation type, which considering that it is the most extensive unit in the country, is not very high. As a result, this is not considered to represent a sensitive vegetation type.

Figure 4. Typical view of the plateau area which represents the majority of the Nuweveld West WEF study area, corresponding with the Eastern Upper Karoo vegetation type. Typical and dominant species include Pentzia incana , Eriocephalus spp., Rosenia spp., Lycium cinereum , Ruschia intricata and Zygophyllum retrofractum .

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 29

Figure 5. Aerial view over the plateau which forms the majority of the Nuweveld West WEF site. Although most of this area can be considered to represent Eastern Upper Karoo, there are also numerous slopes and rocky outcrops present which represent Upper Karoo Hardeveld.

Upper Karoo Hardeveld The Upper Karoo Hardeveld vegetation type is associated with 11 734 km 2 of the steep slopes of koppies, buttes mesas and parts of the Great Escarpment covered with large boulders and stones. The vegetation type occurs as discrete areas associated with slopes and ridges from Middelpos in the west and Strydenburg, Richmond and Nieu-Bethesda in the east, as well as most south-facing slopes and crests of the Great Escarpment between Teekloofpas and eastwards to Graaff-Reinet. Altitude varies from 1000-1900m. Mucina & Rutherford (2006) list 17 species known to be endemic to the vegetation type. This is a high number given the wide distribution of most karoo species and illustrates the relative sensitivity of this vegetation type compared to the surrounding Eastern Upper Karoo.

Most of the valleys and steep slopes within the Nuweveld West site consist of Upper Karoo Hardeveld and this unit has been significantly under-mapped within the national vegetation map. This vegetation type usually consists of very rocky ground and is often associated with steep slopes, with the result that it is considered vulnerable to disturbance but is also an important habitat for fauna. It also contains a higher abundance of protected plant species than the adjacent areas of Eastern Upper Karoo. Consequently, it is generally considered higher ecological sensitivity than the surrounding areas. Three different forms have been recognised within the Nuweveld site, each associated with different edaphic conditions. The most typical form as per the vegetation type description occurs associated with dolerite ridges and koppies with large exposed boulders. This habitat creates a wide variety of microhabitats for fauna and flora and the areas with large amounts of exposed rock have been mapped as high sensitivity.

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Figure 6. There are numerous rocky outcrops as well as rocky slopes within the Nuweveld West site that represent the Upper Karoo Hardeveld vegetation type.

Southern Karoo Riviere Although not all areas associated with this vegetation type have been mapped in the VegMap, the vegetation along the major rivers within the site corresponds with the Southern Karoo Riviere vegetation type. To the north of the site, riparian areas are mapped as Bushmanland Vloere, but this is not an appropriate designation for these areas and the riparian areas within the site and within the upper Sak and Krom rivers more generally, corresponds better with the Southern Karoo Riviere vegetation type.

The Southern Karoo Riviere vegetation type is associated with the rivers of the central karoo such as the Buffels, Bloed, Dwyka, Gamka, Sout, Kariega and Sundays Rivers. About 12% has been transformed as a result of intensive agriculture and the construction of dams. Although it is classified as Least Threatened, it is associated with rivers and drainage lines and as such represents areas that are considered ecologically significant. As the majority of the Nuweveld West WEF is located on the plateau of the Harpuisberg, there are few well-developed drainage lines within the site (Figure 7). There are however some limited sections of a few minor drainage lines with sufficient silt accumulated on their floodplains to support dense riparian vegetation (Figure 8). These limited areas with dense riparian vegetation are considered to represent the best habitat for Riverine Rabbits at the site. The total extent of such areas is however very limited and as no Riverine Rabbits were observed in these areas, it is more likely that this species is not present within the drainage lines of the Harpuisberg and other high-lying parts of the site. Common and dominant species in the drainage lines and within the adjacent floodplain vegetation include Sporobolus ioclados , Helichrysum pentzioides , Drosanthemum lique , Pentzia globosa , Salsola aphylla , Tribulis terrestris , Felicia muricata , Atriplex vestita, Zygophyllum

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 31 retrofractum, Cynodon dactylon, Chrysocoma ciliate, Stipagostis namaquensis, Lycium pumilum , Lycium cinereum , Artemisia africana , Tripteris spinescens , Exomis microphylla and Derverra denudata .

Figure 7. Most of the drainage lines within the Nuweveld West Wind Farm site are not well- developed or occur on bedrock, with the result that there is very little riparian vegetation present. Such drainage lines are considered unlikely to harbour Riverine Rabbits.

Figure 8. Well-developed riparian vegetation along a drainage line within the Nuweveld West site. Such areas with dense riparian vegetation dominated by palatable species are considered

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 32 to represent the most favourable habitat for Riverine Rabbits at the site, but are of very limited extent.

Unique & Special Habitats There are a few specialised habitats within the study area that warrant specific attention. Most of the drainage systems of the site are ephemeral and do not hold water for more than a few days or weeks within the larger pools. There is however a permanent pool fed by springs along one of the larger drainage lines of the site, located near the R381 (Figure 9). This is however outside of the development footprint and would not be affected by the Nuweveld West Wind Farm. Numerous species were observed here that are not present elsewhere and it is also important as a natural water source for the wildlife of the area. A camera trap set up on this pool had a high diversity of fauna present, including the largest number of Mountain Reedbuck as well as red-listed Black Stork. On the plateau, there a few smallish pans present (Figure 10). As these are rare habitats, they should be avoided as much as possible and have been mapped as very high/ no go on the sensitivity maps. As the pans are generally small, these features can be easily avoided and would not pose a significant limitation for development. Apart from the pans there are also some localised areas of rock pavement (Figure 11). These usually consist of areas of flattish exposed bedrock with numerous small pockets of soil or gravel that create habitat for associated dwarf succulents and geophytes. As this is a rare habitat with specialised associated plant species such as Stomatium , Anacampceros and Trichodiadema , these areas are considered sensitive and should be avoided. These areas are generally of very small extent and it would not be difficult to avoid these features.

Figure 9. A drainage line with permanent pools within the Nuweveld West study area. Such permanent pools are important for fauna such as amphibians, but would also be vulnerable to disturbance and pollution from nearby development activities.

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Figure 10. Example of one of the endorheic (without outflow) pans which occurs on the plateau area of the Nuweveld West wind farm.

Figure 11. Example of one of the rock pavements from the area. Although these areas appear to be devoid of vegetation, they are home to numerous small succulents (as pictured in the thumbnails at right) and geophytes which are specialised inhabitants of these areas.

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3.2 LISTED PLANT SPECIES

As many as 18 red-listed plant species are known from the broad area around the Nuweveld West WEF. Investigation of the list however reveals that at least 6 of these are erroneous and included on the list due to outdated taxonomy and do not in fact occur in the vicinity of the site (Species have been split into several species or they were incorrectly identified at the time). Of the remainder at least half can be confirmed present or have a high probability of occurring at the site. Despite the errors in the database, this is still a relatively high total for the Nama Karoo which is generally low in endemic and rare species. The high number can be ascribed to the location of the site along the Great Escarpment which is wetter than the surrounding areas and also contains a number of relictual species. The listed species known from the area are provided in Table 1 below. Although not all of these species are likely to occur within the WEF site itself, there is a reasonable probability that a moderate proportion of these are present. The high-lying plateau areas of the Nuweveld are poorly known and further investigation is likely to turn up additional listed species. The high-lying dolerite areas are likely to prove most fruitful in this regard.

Table 2. Listed plant species known from the broad area around the Nuweveld site. Not all of these species would occur within the affected area.

Family Species Status Probability

GERANIACEAE Pelargonium chelidonium EN V.Low ASPHODELACEAE Kniphofia ensifolia subsp. autumnalis EN Incorrect ID MESEMBRYANTHEMACEAE Sceletium expansum VU Incorrect ID ROSACEAE Cliffortia arborea VU Not Present ASPARAGACEAE Asparagus stipulaceus NT Incorrect ID ASTERACEAE Gnaphalium declinatum NT Incorrect ID GERANIACEAE Pelargonium exhibens NT Moderate AMARYLLIDACEAE Gethyllis longistyla Rare High ASTERACEAE Phymaspermum schroeteri Rare Possible CRASSULACEAE Adromischus humilis Rare Possible FABACEAE Lotononis azureoides Rare Low LOBELIACEAE Lobelia eckloniana Rare Incorrect ID MALVACEAE Anisodontea malvastroides Rare Low ASTERACEAE Cineraria lobata subsp. lobata Declining Moderate APOCYNACEAE Duvalia angustiloba DDD Revised to LC High APIACEAE Annesorhiza filicaulis DDT Incorrect ID

3.3 CRITICAL BIODIVERSITY AREAS & BROAD -SCALE PROCESSES

There are numerous small CBAs distributed across the Nuweveld West site as well as two larger CBAs along the boundary with the Nuweveld East WEF (Figure 12). In the northeast, there is a

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 35

CBA with a single turbine inside of it, while in the southeast of the site there is a larger CBA with 4 turbines inside of it. Wind farm development is not seen as compatible with CBA1 areas within the land-use guidelines that accompany the 2017 Western Cape BSP. However, this should be put in context before considering whether or not this is acceptable. A large proportion of the Western Cape has experienced a significant degree of transformation for agriculture or urbanisation, with the result that the primary aim of designating many areas as CBA1 is to prevent further habitat loss within these areas. It is no longer possible to meet conservation targets for many vegetation types, with the result that any further habitat loss compromises future conservation options and also threatens the ecological functioning and biodiversity value of the affected areas. However, within the Karoo, most vegetation types are still largely intact, with the result that habitat loss is not seen as the primary threat to these areas. Within the Karoo, livestock grazing and the failure to implement favourable livestock management practices is usually the primary determinant of veld condition and the overall ecological health of these areas. In threatened vegetation types, all remaining intact vegetation is seen as being largely irreplaceable, whereas in the Karoo, where the dominant vegetation types are all still more than 95% intact, most areas have a low irreplaceability value and there remain many alternatives to meet conservation targets. As a result, the CBA maps for these areas are much less constrained and there is usually a variety of alternatives available that can be used for the final CBA configuration. An additional factor of relevance is that the baseline information across most of the Karoo is very sparse with the result that there is little biodiversity pattern information that can be used to inform the CBA mapping with the result that these are usually based on various surrogates such as topographic features and broad-scale ecological features. As a result, the CBA mapping within these areas does not necessarily reflect the biodiversity pattern on the ground and the CBAs should be validated in the field before being used to assess the suitability of development within these areas.

A summary of the various underlying features that drive the selection of the CBA1 areas within the Nuweveld West site are identified and discussed below in Table 2. The majority of the CBAs are driven by the selection of areas of Eastern Upper Karoo, with lesser significance or frequency for water resource protection, areas identified as Very High Sensitivity under the Shale Gas SEA, protection of ecological processes and finally, selection of areas of Upper Karoo Hardeveld. As none of these are seen as being unique or of specific significance to the study area, the affected CBAs are all seen as being of low irreplaceability and the development is highly unlikely to compromise the ecological functioning of the study area or the future ability to meet conservation targets in the Upper Karoo.

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Table 3. Summary of the various underlying drivers of the CBAs present within the Nuweveld West WEF study area and the potential impact of the development on these features or reasons. The underlying CBA basis is ordered top to bottom from most to least important cited factor in the CBA explanation table that accompanies the Western Cape BSP. Feature Description & CBA Basis Consequence & Potential Impact Analysis Irreplaceability

These areas have been selection Habitat loss associated with the wind farm in order to meet the within these areas would not compromise the representivity requirement for the ability to meet future conservation targets for Eastern Upper Karoo vegetation this vegetation type. There are still extensive Eastern Upper type. As this vegetation type is tracts of intact similar habitat available in the Karoo still largely intact and is classified area and the affected areas have low as Least Threatened, it is irreplaceability. As a result, the implications of considered to have low the development for habitat loss within the irreplaceability. Eastern Upper Karoo are minimal.

The development of the wind farm would potentially pose some threat to the integrity of the hydrological systems and processes operating within the affected CBAs. However, These areas have been it is important to note that the CBAs are based designated CBA in order to on large hexagonal planning units and actual protect drainage features or features that require protection have not been wetlands from development Water Resource mapped in detail. These features have impact. This could be direct Protection however been mapped in detail here in this impact such as habitat loss report in an ecological context and have also within the wetlands or indirect been mapped in the freshwater specialist impact such as damage through study. The mapping, along with the required erosion and consequent siltation . mitigation and avoidance measures suggested in this and the freshwater study, would ensure that impacts on the hydrological systems of the study area are minimised.

The sensitivities mapped in the Shale Gas SEA were specific to shale gas development and exploration and different development options such as wind energy pose very different risks to these areas. While these are generally still These areas have been Shale Gas Very considered to represent more sensitive parts of identified as being very high High Sensitivity the landscape, the potential impacts posed by sensitivity in the Shale Gas SEA. wind energy development are very different from those posed by Shale Gas development, which has a more intensive and intrusive nature compared to wind energy. Areas considered unsuitable for Shale Gas

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development are not necessarily unsuitable for wind energy development. The detailed, ground-truthed sensitivity mapping produced as part of this study are considered to represent are more realistic representation of the sensitivity of the site and the actual development constraints for wind energy.

Given the low overall footprint of the development and the low existing level of impact in the study area, the development is These areas have been unlikely to impact important ecological Ecological identified as being important for processes. In addition, the footprint within Processes ecological processes such as areas with high ecological significance has dispersal. been highly constrained through the limits of acceptable change and as such, this is intended to ensure that the ecological functioning of the wind farm area is maintained.

Habitat loss associated with the wind farm These areas have been selection within these areas would not compromise the in order to meet the ability to meet future conservation targets for representivity requirement for the this vegetation type. There are still extensive Upper Karoo Hardeveld tracts of intact similar habitat available in the Upper Karoo vegetation type. As this area and the affected areas have low Hardeveld vegetation type is still irreplaceability. In addition, there is overwhelmingly intact and is significantly more of this vegetation type classified as Least Threatened, it available in the wider area than has been is considered to have low mapped under the VegMap. As a result, the irreplaceability. implications of the development for habitat loss within the Upper Karoo Hardeveld are minimal.

The CBAs within the study area are based largely on broad-scale considerations and the Although one can break down presence of un-validated habitat features such the various reasons an area has as wetlands. As the CBAs are not aimed at been identified as a CBA, the protecting areas of known high biodiversity overall pattern also attempts to significance, the affected CBAs are not meet the required targets with considered to have high irreplaceability value Implications for the optimal design that requires and it is likely that the same targets can be met optimal design the least land. As a result, if an with minimal additional cost elsewh ere. area required for optimal design Furthermore, the actual features of can no longer be used as a CBA, significance that are present within the study a significantly larger area may be area would be protected from impact through required to meet the same target. the detailed sensitivity mapping conducted here. As a result, the overall impact of the development within the areas of CBA is seen

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as being relatively low and would not compromise the ability to meet these targets elsewhere or significantly compromise the biodiversity value or ecological functioning of the affected CBAs.

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Figure 12. Extract of the Western Cape Biodiversity Spatial Plan for the Nuweveld West study area, showing that there are several small isolated CBAs within the site as well as some larger more extensive CBAs with a few turbines in them.

3.4 FAUNAL COMMUNITIES

Mammals

As many as 70 mammals are listed for the study area in the MammalMap database, but many of these are introduced or conservation dependent and approximately 48 can be considered to be free-roaming and potentially impacted by the development (Annex 2). This includes several red-listed species including the Riverine Rabbit Bunolagus monticularis (CR), Black-footed Cat Felis nigripes (VU), Grey Rhebok Pelea capreolus (NT), Mountain Reedbuck Redunca fulvorufula (EN) and Brown Hyena Hyaena brunnea (NT). Of these, the Riverine Rabbit is of greatest concern, firstly because of its threat status and secondly because of a higher likelihood of impact on this species as compared to the others. A summary of the likely presence of these red-listed species, within the site and within the broader area is provided below in Table 4.

Table 4. Red-listed mammals known from the broad area and their likely presence in the Nuweveld more generally and within the Nuweveld West WEF area itself. Likely Presence Species Status Wider Nuweveld Area Nuweveld WEF

Camera trapping has not picked up this species on the site and the Confirmed present in the area, limited extent of potentially suitable Riverine Rabbit especially along the R381 in the habitat suggests that it is not present Bunolagus CR vicinty of the Sak River, but also within the high-lying areas where the monticularis in some areas along the Krom turbines would be located. It may and these rivers’ tributaries. however be present within the site in the low-lying areas along the R381.

This is a secretive species and while There are historical records from it may be present in the area, the Black-footed the Nuweveld area and it is camera traps did not pick this Cat Felis VU considered to be possibly species up and there is a low but nigripes (VU) present within the Karoo reasonable probability that it is National Park but not confirmed. present on the site.

This species is confirmed This species was not detected by the present in the area and can camera traps and it appears that it is Grey Rhebok NT commonly be seen in most areas not present within the site. The Pelea capreolus of high-lying ground in the Karoo habitat is however considered and along the Great escarpment. broadly suitable and it may be

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present on the site at low density or in areas that were not camera trapped and hence some distance from the development footprint.

This species is confirmed Mountain present in the area, both within This species is confirmed present on Reedbuck the Karoo National Park and the site at a relatively low density EN Redunca more generally in the area, in and restricted to certain areas of fulvorufula high-lying areas with good grass favourable habitat. cover.

This species occurs at a naturally low density within the Although this species may pass Brown Hyena Karoo and is known from a few through the area on occasion, it is Hyaena NT records from the Karoo National considered unlikely to be present on brunnea Park but may also roam freely on the site on a regular basis. farmland.

The summary results of the camera trapping are listed below in Table 2. A total of 25 different species were recorded at the site. These are illustrated below in Figure 13, Figure 14, Figure 15, Figure 16 and Figure 17. The only non micro-mammal species which were not captured by the camera traps and which have a reasonable possibility of occurring at the site are the Honey Badger and the Vaal Rhebok. The density of Honey Badger in the Karoo is low and it is possible that this species is occasionally present on the site, but given the length the camera traps have been active on the site, it is not likely that there is a resident population. The Vaal Rhebok is more conspicuous and are usually resident within an area, suggesting that they are not present on the site as this species is usually easily detected by camera traps. Given the wide distribution of the camera traps across the site and the large number of records of fauna that were obtained, the results of the camera trapping are considered to provide a reliable indication of the faunal community on the site. In terms of the listed species, only the Mountain Reedbuck was observed on the site. The absence of the Brown Hyena is not surprising and it is seen as being unlikely that this species maintains a free-ranging population in the area. Similarly, the Black-footed Cat prefers areas with a higher prey density and it is also unlikely that this species is present especially within the high-lying parts of the site. Most significantly, no Riverine Rabbits were observed at the site, despite the high density of cameras within the riparian areas identified as being potentially suitable for this species. The failure to detect this species within the site is most likely explained by the limited extent of suitable habitat within the site and hence the inability of these limited areas to actually support a viable population of Riverine Rabbits.

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Table 5. Summary of camera trapping observations from 50 camera traps located across the Nuweveld site. Species IUCN Status Total Observations Camera Sites Frequency (%) Aardvark LC 60 16 41.0 Aardwolf LC 109 17 43.6 African Wildcat LC 26 9 23.1 Bat Eared Fox LC 176 21 53.8 Black-backed Jackal LC 205 21 53.8 Cape Fox LC 60 19 48.7 Cape Grey Mongoose LC 77 15 38.5 Cape Hare LC 1124 31 79.5 Cape Porcupine LC 795 32 82.1 Caracal LC 22 11 28.2 Ground Squirrel LC 104 4 10.3 Klipspringer LC 1 1 2.6 Kudu LC 48 9 23.1 Mountain Reedbuck EN 58 4 10.3 Polecat LC 24 8 20.5 Rock Hyrax LC 165 7 17.9 Rock Rabbit LC 19 5 12.8 Spotted Genet LC 22 8 20.5 Springbok LC 216 5 12.8 Suricate LC 38 12 30.8 Steenbok LC 226 26 66.7 Water Mongoose LC 44 8 20.5 Yellow Mongoose LC 7 6 15.4 Leopard Tortoise LC 607 14 35.9 Rock Monitor LC 1 1 2.6

Of some significance, is the presence of the Mountain Reedbuck on the site. This species is currently listed as Endangered has declined markedly (61%) in abundance within monitored populations within formally protected areas between 1998 and 2013. The total population within South Africa is estimated to be at least 15 000 but potentially as much as 33 000 individuals. The population trends on private land are not well known and have not been monitored. The reasons for the decline are not known. The density within the Karoo and hence at the site is estimated at 10 individuals / 100km 2, which results in a population estimate for the site of approximately 35 individuals, assuming that the whole site is available and suitable as habitat which is unlikely given the results of the camera trapping. The estimate of 35 can therefore be seen as a maximum likely population for the site. Based on the number of observations from the camera traps, the minimum number of individuals potentially present at the site is estimated

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 42 at 12 individuals. The main impact on this species is likely to occur during the construction phase when noise and disturbance are likely to scare Mountain Reedbuck away from the areas where there is construction activity. However, as the site is large and the Reedbuck are not confined to any one area, they would be free to move away from the construction activity to other parts of the site. According to Furstenburg (2010), “Territories are permanent and vary in size from 18-32 ha. Alarmed animals may abandon the territory temporarily but return soon after the disturbance has vanished”. Based on the literature as well as personal observation, this species is likely to move away from construction activity, but is likely to return to the site during the operational phase as from my observations and the literature most ungulates do not appear to be fearful of turbines and are not likely to avoid the site once construction disturbance has ceased. As such, there is likely to be a transient impact on Reedbuck, but little long-term impact. It is also worth pointing out that for ungulates and herbivores in general, the construction phase is likely to cause some disturbance and disruption, but since livestock are not likely to be on the site during construction, this would improve habitat condition on-site for indigenous herbivores and particularly for nocturnal species, this would be favourable and is likely to at least partly offset the negative impacts of disturbance during this period.

Although no Riverine Rabbit have been recorded on the site, the high conservation status of this species requires that a cautious and considered approach is required for this species. Furthermore, while it may not be present on the site itself, this does not mean that there would be no potential impacts on Riverine Rabbits. If present, impact on the Riverine Rabbit would predominantly be from turbine noise, habitat loss, disturbance during construction and the potential for deaths from vehicle collisions during construction. A breakdown and discussion of the potential impacts of the development on Riverine Rabbits is provided below in Table 3.

Although numerous camera traps were located in the areas considered to represent the best habitat for Riverine Rabbits, no Riverine Rabbits were recorded in these areas, but many Cape Hares were observed. There appears to be some competition between these species and Riverine Rabbits are usually absent in areas with high Cape Hare density. Consequently, the high abundance of Cape Hare in these areas is further support of the likely absence of the Riverine Rabbit from these areas. The total extent of potential habitat in this area is less than 50ha and given that it is isolated from other extensive habitat patches, it seems unlikely that it would be able to support a self-sustaining population of Rabbits. Despite, the absence of Riverine Rabbits from these areas, a cautious approach has been implemented with regards to buffering these areas from development.

Given the fine-scale habitat mapping and buffering that has been conducted within the site, potential impacts on Riverine Rabbit habitat loss and disturbance will be reduced to acceptable levels. During operation, impacts are likely to be low and the main avenue of potential concern is noise generated by the turbines which would amount to habitat degradation within the affected areas for fauna affected by noise impacts. However, the impacts of turbine noise on fauna are not well-known and based on the available literature, these are idiosyncratic and not consistent between species. Although there are currently several reviews available in the literature around

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the impacts of turbine noise on birds, the degree to which this information can be directly transferred to a nocturnal mammal is debateable. Consequently, whether or not this impact would actually occur and its severity for Riverine Rabbits and other fauna are currently not well- defined and there remains some inevitable degree of uncertainty in this regard. A Fauna Monitoring Programme for fauna of potential concern has been proposed through discussion between the specialist the EWT as a way to provide useful information that can be used to guide likely further renewable energy development in this area and the Karoo more generally. This should be funded by the developer for five years, starting before the construction phase and extending for three years into the operational phase. The manner in which this funding should be spent, should be determined in collaboration with the EWT Drylands Programme who are active with Riverine Rabbit research, monitoring and habitat rehabilitation in the area. In principle, the funding could be directed towards focussed student research projects, or provide a contribution towards some of the activities EWT is busy with in the wider area, or to initiate new projects on the site itself. If Riverine Rabbits are found to be present on the site any time in the future, then it is strongly recommended that the impacts of the development on the rabbits present receive priority in the Faunal Monitoring Programme so that this information can be used to inform future development within the range of the Riverine Rabbit.

Table 6. Breakdown of potential impacts on Riverine Rabbits and the potential significance and mitigation and avoidance options that can be implemented to reduce potential impacts.

Potential Impact Source/Project Potential Significance and Mitigation Options Impact Components

The primary area of potential conflict in terms of habitat loss would be the areas of potential Riverine Rabbit The construction of roads, turbine habitat on the plateau. However, no Riverine Rabbits hard-stands, laydown areas etc. will have been observed on the plateau. As the drainage result in the destruction of currently lines and floodplains have been mapped as Very High Habitat Loss intact vegetation, including within sensitivity, no turbines would be located in these areas areas of potential Riverine Rabbit and the total development footprint in these areas would habitat. be low. As a result, the total potential extent of habitat loss is likely to be very low and the resulting impact from habitat loss would also be low.

The large amount of traffic during Roadkill is a significant source of mortality for Riverine construction will increase the Rabbits. As the public roads to the site go through probability of vehicle-related several areas of potential habitat, the increase in traffic mortality. This would potential be associated with construction would increase the Collisions with within the site as well as on the larger probability of roadkill. As Riverine Rabbit activity is vehicles public roads to the site such as the highest between dusk and dawn, traffic during these R381. During operation, this hours can be curtailed. In addition, speed limits in areas potential impact would be of potential conflict can be implemented as this reduces significantly reduced. collision risk.

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Construction activity will generate a lot of noise and disturbance which could impact Riverine Rabbits when Construction activity will result in this occurs in or near Riverine Rabbit habitat. As there noise and disturbance which may Disturbance are limited areas of potentially suitable Riverine Rabbit deter Riverine Rabbits from the on the plateau, this would be a localised impact. If there affected areas. are no Riverine Rabbits on the plateau, then this impact would be of minimal intensity.

Wind turbines generate noise within the audible range as well as low-frequency “infrasound”. Noise results in habitat degradation through reducing the ability of fauna to detect prey or predators through auditory cues. There are no peer-reviewed papers which have demonstrated a negative impact of infrasound on fauna. In addition, wind itself generates infrasound when it moves across the landscape which is likely to swamp any additional inputs generated by wind turbines. Similarly, noise generated by turbines is related to wind speed and During operation, the turbines will hence most noise occurs when there are high levels of Turbine Noise generate noise which may have a background ambient noise, with the result that the negative impact on Riverine Rabbits. potential additional contribution of turbine noise may be reduced. Although there is little mitigation possible for turbine noise, the potential Riverine Rabbit habitat on the plateau has been buffered by 300m, which would reduce the potential significance of this impact. If there are no Riverine Rabbits on the plateau, then there would be no impact in this area. However, there would still potentially be some impact on Riverine Rabbits on the adjacent plains, but given the distance between the turbines and areas where Rabbits are known to occur, this would be of low magnitude.

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Figure 13. Canids and Felids observed at the site include, clockwise from top left, Aardwolf, Caracal, Black-backed Jackal, African Wildcat, Cape Fox and Bat-eared Fox.

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Figure 14. Small carnivores present at the site include, from top left, Suricate, Yellow Mongoose, Striped Polecat, Water Mongoose, Common Genet and Cape Grey Mongoose.

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Figure 15. Rodents and Afrotheria present at the site include from top left, South African Ground Squirrel, Rock Hyrax, Aardvark and Cape Porcupine.

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Figure 16. Indigenous ungulates present at the site include, clockwise from top left Klipspringer, Mountain Reedbuck, Kudu, Steenbok and Springbok.

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Figure 17. Splitting hares… Hewitt's Red Rock Hare top left and the remaining images are all the Cape Hare illustrated from various camera locations and habitats across the site. No Riverine Rabbits were recorded by the camera traps.

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Reptiles Reptile diversity in the wider area is relatively high which can be ascribed to the diversity of habitats present, especially along the escarpment. Based on the current study as well as the Sungazer (2020) study, approximately 63 reptile species are known from the general region and may potentially occur within the study area, with 14 being of confirmed occurrence, 45 of probable occurrence and four of possible occurrence (Annex 4). Species of potential concern include the local endemic, Braack’s Pygmy Gecko and the Karoo Padloper. Braack’s Pygmy Gecko Goggia braacki is a Western Cape endemic with an extremely restricted distribution range. Most of its distribution is associated with a section of the Nuweveld Mountains range within the Karoo National Park. It is however not currently red-listed, but it can perhaps be regarded as the reptile icon for the Nuweveld/Beaufort West region. It has thus far, not been recorded from the Nuweveld Wind Farms study area, but it may possibly (not probably) be present within the wind farm area. The only threatened (Red Listed) reptile species in this region is the Karoo Padloper (EN). This small tortoise is seldom observed, even when specifically targeted during herpetofaunal surveys. They are associated with dolerite ridges and rocky outcrops of the southern Succulent and Nama Karoo biomes. Threats to this species include habitat degradation due to agricultural activities and overgrazing, and predation by the Pied Crows which in recent decades have expanded in distribution range. The habitat on site is considered broadly suitable for the Karoo Padloper and it is considered likely to be present. The development would however largely avoid the rocky shelter sites of this species with the result that direct habitat loss would be low. In addition, tortoises are one of the few species that have been specifically studied with regards to their responses to wind energy development and no significant negative impacts have been detected within population’s resident on wind farms (Agha et al. 2015, Lovich et al. 2011). Cloete’s Girdled Lizard ( Cordylus cloetei ) is currently a range-restricted species, but a recent genetics study (in prep.) has revealed that it is actually a synonym of Cordylus minor . As such it actually has a much wider distribution and it is no longer of special significance other than being a WC endemic (Annex 4).

In general, the major impacts on reptiles associated with the development would be disturbance and habitat loss during construction. However, there do not appear to be any species that would be especially affected. The most important areas for reptiles are likely to be the rocky outcrops and escarpment areas with an abundance of refuges and microhabitats. The footprint within these areas would be low and as such there do not appear to be any significant limitations or red-flag issues associated with reptiles and the development of the wind farm.

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Figure 18. Reptiles photographed during the site visits. From bottom left, Karroo Girdled Lizard, Ground Agama, Puff Adder, Leopard Tortoise and Karoo Tent Tortoise.

Amphibians

The diversity of amphibians in the study area is relatively low with only 12 species having being recorded in the area. Species observed at the site include the Karoo Toad, Clawed Toad and Poynton’s River Frog. There are no listed amphibian species known from the area although the Giant Bull Frog Pyxicephalus adspersus was previously listed as Near Threatened but has revised to Least Concern (Annex 3). This species is associated with temporary pans in the Karoo, Grassland and Savannah Biomes, but is not commonly recorded in the study area and its presence at the site is highly unlikely. Within the site, there are several drainage lines that would have temporary pools that can be used by toads and frogs for seasonal breeding purposes. In the south of the site, there is also a kloof with permanent pools used by Cape River Frogs and Clawed Toads. Impact to these habitats should be minimised as much as possible by adhering to the buffers provided. Given the localised nature of important amphibian habitats at the site as well as the generally arid nature of the site and the low overall abundance of amphibians, a significant long-term impact on amphibians is unlikely.

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Figure 19. Amphibians observed at the site include the Karoo Toad, top left and the Common Platanna, above and Poynton’s River Frog, left.

Butterflies All of the butterflies known from the area (Annex 4) have been assessed as being “Least Concern” in the most recent butterfly conservation assessments done in accordance with the IUCN Red Listing protocols (Mecenero et al. 2020, in press). Whilst none of these taxa are threatened, there are a few butterflies that are restricted range endemics recorded from the area and they could occur at the development site:

• Aloeides caledoni A rare low-density endemic confined to higher altitudes such as ridges and mountain tops. Known to occur in the Karoo National Park and on the Nuweveld mountains. Extent of occurrence > 43 000 km 2, but only known from a few places. Host plant is not known. Flight period is from October to mid-November. Probability of occurrence < 5%. • Chrysoritis beaufortia beaufortia A restricted range endemic which occurs at higher altitudes > 1 500m in the Nuweveld mountains. Extent of occurrence = c. 3000 km 2. Vegetation types = NKu 2 Upper Karoo Hardeveld and NKu 4 Eastern Upper Karoo. Host plants recorded as Dimorphotheca cuneata (Thunb.) or Osteospermum moniliferum (L.) (Heath et al. , 2008). Flight period is from October to mid-November. Probability of occurrence c. 5%.

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• Pseudonympha trimenii nieuwveldensis A restricted range endemic occurring at altitudes over 1 600 m in the Nuweveld mountains. Extent of occurrence = c. 2 000 km 2. Vegetation types = NKu 2 Upper Karoo Hardeveld and NKu 4 Eastern Upper Karoo. Host plant recorded as Tenaxia disticha (Schrad.) (was Merxmuellera ) (Pringle et al. , 1994). Flight period is from late September to early November. Probability of occurrence < 10%

As with other fauna, habitat loss and disturbance are potential threats to these endemic species, but with mitigation, these impacts can likely be reduced to acceptable levels. Butterflies may also be affected by turbine blades the associated turbulence. Based on the turbine specifications provided for the assessment, the closest approach of the blades to the ground is 25 m. The butterflies of concern which may be present do not normally fly more than 10 m from the ground so the risk of direct collisions with the turbine blades is extremely low. Grealey & Stephenson (2007) found that “there is no evidence to suggest that butterfly mortality is a concern at commissioned wind farm sites as a result of collisions with turbines”. There is no possibility that the power lines could cause any damage to the butterflies once operational, since the electrical conductors are high above the ground level, although there would be some habitat loss at construction.

The supplementary study by Edge (2020/ Annex 4) concludes that “The proposed Nuweveld Wind Farm development in the Great Karoo between Beaufort West and Loxton does not pose any danger to any currently Red Listed threatened butterflies (in the categories Critically Endangered, Endangered, or Vulnerable). However, there are three restricted range endemic butterflies which could occur at the site. It is recommended that a site visit be made during the butterfly’s flight period in the middle of October to establish if they occur at the development site and if so which part(s) of the site they occupy. In the unlikely event that there is a clash between the butterflies’ flying area(s) and the area to be disturbed during construction and operation of the wind farms, adjustments may have to be made to the layout.”

4 NUWEVELD WEST WEF SENSITIVITY ASSESSMENT

The sensitivity map for the Nuweveld West WEF area is depicted below in Figure 20. Overall, the site is considered generally favourable for development of the wind farm. Although there are some areas which should be excluded from development or in which the development footprint should be constrained, there are large tracts of the site that are considered low sensitivity and where development would have a low impact. The mapped no-go and high sensitivity areas have been used to inform the development layout as described in Table 7 below. Features considered unsuitable for the placement of turbines, buildings and substations (and associated battery facility) within the site include riparian areas of potential Riverine Rabbit habitat as well as the numerous minor drainage features distributed across the site more generally. In addition, there are also numerous steep slopes along the escarpment and rocky outcrops on the plateau deemed to be high sensitivity for turbines, buildings and substations (including battery facility). The majority of the site is however open plains, plateau or gentle slope habitats of medium and low sensitivity.

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Table 7. The sensitivity categories as illustrated in the ecological sensitivity map and the consequences and implications of this for the development.

Turbines & Buildings/Substations Sensitivity Roads & Electrical Infrastructure (and associated battery facility)

Roads and electrical infrastructure will need No turbines, battery facility or buildings to traverse these features, but this is subject Very High/ should be located in these areas. A No Go to the stipulated limits of acceptable change. failure to adhere to these requirements is Exceeding the limits of the acceptable seen as a fatal flaw. change is seen as a fatal flaw.

Limited, subject to the limits of acceptable Limited, subject to the limits of acceptable change. change. Exceeding the limits of acceptable change, is only acceptable to Exceeding the limits of acceptable change, is the degree that the cumulative footprint only acceptable to the degree that the within the high and very high sensitivity cumulative footprint within the high and very areas is within the specified summed High high sensitivity areas is within the specified limits across these classes. In other summed limits across these classes. In other words, exceeding the limits of acceptable words, exceeding the limits of acceptable change within this class is only change within this class is only acceptable if acceptable if the extent is made up by a the extent is made up by a shortfall in the shortfall in the footprint within the Very footprint within the Very High sensitivity High sensitivity areas. areas.

Development is little constrained and provided that to the total footprint within Development is little constrained and the medium and low sensitivity areas is provided that to the total footprint within the Medium within the overall limits of acceptable medium and low sensitivity areas is within the change across these classes, it is overall limits of acceptable change across To considered acceptable. Exceeding the these classes, it is considered acceptable. Low limits of acceptable change is Exceeding the limits of acceptable change is undesirable, but is not considered to undesirable, but is not considered to represent a fatal flaw as a basic principle, represent a fatal flaw as a basic principle, but but is considered in context and the is considered in context and the degree to degree to which these limits are which these limits are exceeded. exceeded.

Impacts on the Riverine Rabbit are a potential concern associated with the development. However, the camera trapping did not pick up any individuals of this species, despite the concentration of cameras within potentially suitable habitat. This suggests that it is unlikely that these areas support a population of this species. This is not too surprising given the degraded state of many of the larger drainage features of the site and the limited extent of good quality riparian habitat deemed to be of reasonable suitability for this species. Nevertheless, the high

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 55 threat status associated with this species demands a conservative approach and no turbines, buildings or substation (and associated battery facility) have been located within the Very High sensitivity potential Riverine Rabbit areas. With this avoidance in place, impacts on Riverine Rabbits are likely to be low and limited to minor impacts of low magnitude and considered acceptable, even if Rabbits are demonstrated to be present within these areas. Although Riverine Rabbits can be found outside of riparian habitats in the southern Cape, this does not appear to be case for the northern population and as such, its presence outside of these areas is seen as extremely unlikely.

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Figure 20 . Ecological sensitivity map for turbines, roads, cables, substation (including battery facility) and overhead lines for the Nuweveld West WEF area.

Ecological Sensitivity and Limits of Acceptable Change

In order to calculate whether the development falls within the limits of acceptable change, the footprint of the development was calculated based on the turbine, road and other specifications as described in Section 1.3. Table 3 below shows the development footprint of the three wind farms making up the Nuweveld Wind Energy Development within each sensitivity category. As per Table 1 of this assessment, none of the limits of acceptable change are exceeded or are close to the limits imposed on the development. Of greatest concern would be the potential impact on areas mapped as no-go areas for turbines and other infrastructure. As some roads and cabling must traverse these features, some inevitable loss within these areas will occur. The total extent of loss within the no-go areas across all three Nuweveld wind farms is 1.5ha which is well within the 0.5% stated limit of 4.57ha.

Table 8. The extent of the development footprint within each sensitivity category for each phase of the Nuweveld Wind Energy Development and combined for all phases. The total footprint within each sensitivity class falls within the set limits of acceptable change. Although the current study is only for the Nuweveld West WEF, the impacts were calculated across all projects as this firstly represents the worst-case scenario and secondly, this is important information when considering the cumulative impact of the whole Nuweveld development. Note that the footprint when totalled across the three projects does not add up to the total footprint as listed because some parts of each development are shared across projects.

Total Extent Acceptable Loss Footprint Extent (Ha) TOTAL IMPACT Sensitivity (Ha) % Ha EAST NORTH WEST Ha %

Ecology NoGo 914 0.5 4.57 0.49 1.07 0.99 1.51 0.17

Ecology High 5 937 1 59.37 5.00 11.66 2.89 16.74 0.28 Ecology 12 344 2 246.88 58.65 39.43 44.94 121.72 0.99 Medium Ecology Low 12 964 5 648.2 48.44 67.14 74.40 159.27 1.23

TOTAL: 32 159 112.58 119.30 123.22 299.24 0.93

Changes made from Pre-app Scoping Layout to Scoping Layout to address terrestrial ecology issues identified

The main change in the layout from the pre-application terrestrial ecology study is the reduction in the total number of potential turbine locations from 64 to 38. The final layout as assessed here, was derived through an iterative approach (including a screening phase, a pre-app Scoping and now Scoping phase) and numerous turbines have been relocated from their original

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 57 positions or dropped altogether from the original layout. This represents an important process within the planning phase that has significantly contributed to reducing the levels of potential conflict between the development and the sensitive ecological features of the site. As such, the final layout represents a partially mitigated layout in which unacceptable and very high impact turbines and other features have already been removed or relocated to less sensitive areas.

5 IMPACTS AND ISSUES IDENTIFICATION

5.1 IDENTIFICATION OF POTENTIAL IMPACTS

The development of the Nuweveld West WEF is likely to result in a variety of impacts, associated largely with the disturbance, loss and transformation of intact vegetation and faunal habitat during construction. During operation, the impacts would be reduced and restricted largely to potential noise impacts and occasional disturbance from operational activities. The following impacts are identified as the major impacts that are likely to be associated with the development of the Nuweveld West WEF.

Impact 1. Impacts on vegetation and listed or protected plant species The development would require vegetation clearing (which may entail blasting) for turbines, roads, underground cabling and substations. (and associated battery facility) . In addition, it is likely that the turbine foundations and some roads would require blasting which would generate dust and debris fallout near these locations. Apart from the direct loss of vegetation within the development footprint, listed and protected species are likely to be impacted. These impacts would occur during the construction phase of the development, with additional vegetation impacts during operation likely to be low. Although the abundance of plant species of concern appears to be relatively low, there are numerous provincially protected species present.

Impact 2. Direct Faunal Impacts Increased levels of noise, pollution, disturbance and human presence during construction will be detrimental to fauna. Sensitive and shy fauna are likely to move away from the area during the construction phase as a result of the noise and human activities present, while some slow- moving species would not be able to avoid the construction activities and might be killed if proper management and monitoring is not in place. Traffic at the site during all phases of the project would pose a risk of collisions with fauna. Slower types such as tortoises, snakes and certain mammals would be most susceptible and the impact would be largely concentrated to the construction phase when vehicle activity was high. Some mammals and reptiles would be vulnerable to illegal collection or poaching during the construction phase as a result of the large number of construction personnel that are likely to be present.

Impact 3. Impact on the Riverine Rabbit Although the Riverine Rabbit is not expected to occur within the development area, it is known to occur along the R381 which will be used to access the site. During construction, the increased

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 58 levels of traffic at the site would increase collision risk with rabbits, which is a known major cause of mortality for this species. Furthermore, the noise and disturbance associated with construction may deter rabbits from the affected areas where these are in close proximity to areas where Rabbits are present. During operation, impacts would be reduced, but noise from the turbines would potentially impact this species, resulting in local habitat degradation within and adjacent to the site.

Impact 4. Impact on the Mountain Reedbuck Due to the high concern associated with this species, it is assessed separately from the other fauna at the site. During construction, the increased levels of noise and disturbance at the site would potentially scare Mountain Reedbuck from the affected areas. During operation, impacts would likely be reduced, but noise from the turbines could potentially impact this species, resulting in local habitat degradation within the site, although this seems unlikely given the personal observation that other ungulates do not appear to avoid turbines to a significant degree once habituated to their presence.

Impact 5. Increased Erosion Risk The large amount of disturbance created during construction would leave the affected areas vulnerable to wind and water erosion. Some parts of the site are steep and specific mitigation and avoidance would be necessary to reduce this impact to acceptable levels. This impact is also of concern given the significance of the drainage lines in the area as Riverine Rabbit habitat and the consequent need to prevent and limit impact on these features.

Impact 6. Impacts on CBAs and broad-scale ecological processes There are some small CBAs within the site that would be potentially impacted by habitat loss associated with the development. Habitat loss within CBAs can reduce biodiversity, impact on the ecological functioning of the CBA and future conservation value of these areas. In the current case, the majority of CBAs within the site are designed to protect hydrological processes and are not areas of known high biodiversity. In addition, there is already an access road running through the two small CBAs that would be impacted by the main site access road and a road corridor has already been excluded from the mapped CBAs. The wind farm access road would be larger than the existing road, but the overall footprint within the CBAs would be very low. As a result, the potential impact of the development on CBA is likely to be low and is not considered to be of notable significance.

Impact 7. Cumulative Impacts The development of the Nuweveld West WEF would result in habitat loss and an increase in overall cumulative impacts on fauna and flora in the area. Current levels of transformation in the area resulting from wind farm development is low and the contribution of approximately ~161ha of additional habitat loss as a result of the Nuweveld West WEF is not considered highly significant. However, there are three other applications (Nuweveld East and North WEFs and Nuweveld Gridline) on the same or adjacent sites and the total cumulative impact from all the proposed developments would be ~338ha of direct permanent habitat loss and an additional

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 59 extent of indirect habitat degradation as a result of noise and other disturbance effects. At a more local level, it is important to note that the three Nuweveld Wind Farms fall well within the limits of the acceptable change set for the development and as such, are not likely to generate significant cumulative impacts on ecological processes within the greater wind farm area.

6 ASSESSMENT OF IMPACTS – NUWEVELD WEST WEF

A preliminary, summary assessment of the likely significance of each impact identified above is made below for the Nuweveld West WEF. Note that the assessment considers the wind farm associated impacts as well as those associated with the proposed Beaufort West N1 bypass road detailed in Annex 6).

6.1 CONSTRUCTION PHASE IMPACT 1. IMPACTS ON VEGETATION AND PLANT SPECIES OF CONSERVATION CONCERN

Project phase Construction Impact Impacts on vegetation and plant SCC Description of Impact on vegetation and plant SCC due to construction-phase habitat loss. impact Mitigatability Medium Mitigation exists and will notably reduce significance of impacts • Undertake a pre-construction walk through of the development footprint to refine the layout through micrositing of turbines, buildings, substation (and associated battery facility), access roads and internal roads where it impacts on SCC. • Adhere to the sensitivity maps and limits of acceptable change provided within this Potential assessment when determining the final layout of the WEF and associated infrastructure. mitigation • Existing roads or disturbance footprints should be used as far as possible and should especially be used through very high sensitive areas. Should access roads, internal cables and overhead lines traverse drainage lines and riparian areas which are classified as Very High sensitivity these should be microsited by a suitably qualified ecological and aquatic specialist before construction in that area starts to ensure any potential impacts are minimised Assessment Without mitigation With mitigation Nature Negative Negative Impact may be permanent, Impact may be permanent, Duration Permanent Permanent or in excess of 20 years or in excess of 20 years Extending across the site Extending across the site and Extent Local Local and to nearby settlements to nearby settlements Natural and/ or social Natural and/ or social Intensity Low functions and/ or processes Low functions and/ or processes are somewhat altered are somewhat altered Almost certain / It is most likely that the The impact may occur Probability Likely Highly probable impact will occur Substantive supportive Substantive supportive data Confidence High data exists to verify the High exists to verify the assessment assessment The affected environment The affected environment will not be able to recover will not be able to recover Reversibility Low Low from the impact - from the impact - permanently modified permanently modified The resource is damaged The resource is not damaged Resource Medium irreparably but is Low irreparably or is not scarce irreplaceability represented elsewhere Significance Moderate - negative Minor - negative

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Comment on While there is some scope for avoidance of sensitive species and habitats, some vegetation loss significance is an inevitable consequence of development that cannot be avoided. The contribution of the Nuweveld West Wind Farm to cumulative impacts on vegetation and Cumulative plant species of concern is considered low due to the current low levels of transformation in the impacts area and the relatively low total footprint of the development.

6.2 CONSTRUCTION PHASE IMPACT 2. DIRECT AND INDIRECT FAUNAL IMPACTS

Project phase Construction Impact Direct and indirect faunal impacts Description of Construction phase impact on fauna impact Mitigatability Medium Mitigation exists and will notably reduce significance of impacts • Adhere to the development restrictions placed on areas of Very High sensitivity. Where necessary, these areas include areas of high fauna importance. • All vehicles should adhere to a low speed limit on site. Heavy vehicles should be restricted to 30km/h and light vehicles to 40km/h. • Search and rescue for reptiles and other vulnerable species during construction, before areas of intact vegetation are cleared. Potential • Limiting access to the site and ensuring that construction staff and machinery remain within the mitigation demarcated construction areas during the construction phase. Environmental induction for all staff and contractors on-site. • Develop an open space management plan as part of the project EMPr. • The design should ensure that there are no electrical fencing around substations (and associated battery facility) or other features within 20cm of the ground as tortoises become stuck against such fences and are electrocuted to death. Assessment Without mitigation With mitigation Nature Negative Negative

impact will last between 1 impact will last between 1 and Duration Short term Short term and 5 years 5 years Extending across the site and Extending across the site and Extent Local Local to nearby settlements to nearby settlements Natural and/ or social Natural and/ or social Intensity High functions and/ or processes High functions and/ or processes are notably altered are notably altered There are sound scientific Certain / Probability reasons to expect that the Likely The impact may occur definite impact will definitely occur Substantive supportive data Substantive supportive data Confidence High exists to verify the High exists to verify the assessment assessment The affected environment The affected environmental will only recover from the Reversibility Medium High will be able to recover from impact with significant the impact intervention Resource The resource is not damaged The resource is not damaged Low Low irreplaceability irreparably or is not scarce irreparably or is not scarce Significance Moderate - negative Minor - negative

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Comment on While there is some scope for avoidance of sensitive habitats, some disturbance and habitat loss is significance an inevitable consequence of development that cannot be entirely avoided.

Cumulative Cumulative impacts on fauna are predicted to be relatively low as the area is still largely intact with impacts a typical fauna community for a farming area.

6.3 CONSTRUCTION PHASE IMPACT 3. CONSTRUCTION PHASE IMPACTS ON RIVERINE RABBITS

Project phase Construction Impact Construction phase impact on the Riverine Rabbit Description of Impacts on Riverine Rabbit as a result of construction phase activities, including vehicle collisions, impact disturbance and habitat loss. Mitigatability Medium Mitigation exists and will notably reduce significance of impacts Potential • All construction vehicles should adhere to a low speed limit (30km/h on site and 40km/h) in areas mitigation where Riverine Rabbits are likely to be active, both within the wind farm as well as on the public roads to the site. • During construction, driving between sunset and sunrise should be reduced as far possible as this is when Riverine Rabbits are most active and the risk of collisions is highest. • There should be a monitoring programme for Riverine Rabbit roadkill during construction that should be used to inform any additional mitigation and avoidance that should be implemented. Should rabbits be killed by traffic, then the traffic management to and from the site should be reviewed in collaboration with the EWT Drylands Programme, to identify additional mitigation and avoidance that should be implemented to further reduce roadkill. • No dogs should be allowed on site and precautions to ensure that there is poaching or other direct faunal disturbance on site should be implemented. • Where any new roads, cabling and/or overhead lines traverse areas mapped as High Riverine Rabbit habitat sensitivity, the route should be microsited by a suitably qualified ecological specialist before construction commences to ensure any potential impacts are minimised. Existing tracks through these areas should be used where present. • Funding must be allocated to a Fauna Monitoring and Conservation initiative. A minimum of R200 000 per year for five years should be allocated to fund this monitoring programme. The funding should be made available at least 6 months prior to construction and be available for at least three years during operation. (The manner in which the five years is structured can to some degree be negotiated, but it is suggested that it include at least 6 months of preconstruction monitoring that can be used as a baseline, and at least one year of construction phase monitoring and then at least three years post-construction). Also it is important to note that this funding is to be used for general faunal monitoring as well as Riverine Rabbits. Assessment Without mitigation With mitigation Nature Negative Negative Impact will last between 5 and 10 impact will last between Duration Medium term Short term years 1 and 5 years Extending across the site Extent Municipal area Impacts felt at a municipal level Local and to nearby settlements Natural and/ or social Natural and/ or social functions functions and/ or Intensity High and/ or processes are notably High processes are notably altered altered

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Almost certain It is most likely that the impact will Probability / Highly Likely The impact may occur occur probable Determination is based Substantive supportive data exists Confidence High Medium on common sense and to verify the assessment general knowledge The affected The affected environment will only environment will only Reversibility Medium recover from the impact with Medium recover from the impact significant intervention with significant intervention The resource is The resource is irreparably Resource irreparably damaged and High damaged and is not represented High irreplaceability is not represented elsewhere elsewhere Significance Moderate - negative Minor - negative Comment on With the suggested mitigation, impacts on Riverine Rabbit can be reduced to a low level, although significance some residual is likely to occur, this would not be likely to compromise the local population of Rabbits. Cumulative The development would contribute to cumulative impacts on Riverine Rabbits especially due to impacts vehicle collisions, but this would be transient and the overall contribution to cumulative impact would be low.

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6.4 CONSTRUCTION PHASE IMPACT 4. CONSTRUCTION PHASE IMPACTS ON MOUNTAIN REEDBUCK

Project phase Construction Impact Construction phase impact on the Mountain Reedbuck Description of Impacts on Mountain Reedbuck as a result of construction phase activities, including noise, impact disturbance and habitat loss. Mitigatability Medium Mitigation exists and will notably reduce significance of impacts Potential • There should be a camera-trap based monitoring programme for Mountain Reedbuck set up mitigation before and during construction and which should be used to understand the impact of wind farms on ungulates of conservation concern. • No dogs should be allowed on site and precautions to ensure that there is poaching or other direct faunal disturbance on site should be implemented. • Funding must be allocated to a Fauna Monitoring and Conservation initiative as detailed previously for the Riverine Rabbit. Assessment Without mitigation With mitigation Nature Negative Negative Impact will last between 5 and 10 impact will last between Duration Medium term Short term years 1 and 5 years Extending across the site Extent Municipal area Impacts felt at a municipal level Local and to nearby settlements Natural and/ or social Natural and/ or social functions functions and/ or Intensity High and/ or processes are notably High processes are notably altered altered Almost certain It is most likely that the impact will Probability / Highly Likely The impact may occur occur probable Determination is based Substantive supportive data exists Confidence High Medium on common sense and to verify the assessment general knowledge The affected The affected environment will only environment will only Reversibility Medium recover from the impact with Medium recover from the impact significant intervention with significant intervention The resource is The resource is irreparably Resource irreparably damaged and High damaged and is not represented High irreplaceability is not represented elsewhere elsewhere Significance Moderate - negative Minor - negative Comment on With the suggested mitigation, impacts on Mountain Reedbuck can be reduced to a low level, significance although some residual is likely to occur, this would not be likely to compromise the local population of Mountain Reedbuck. Cumulative The development would contribute to cumulative impacts Mountain Reedbuck, but this would be impacts transient and the overall contribution to cumulative impact would be low.

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6.5 CONSTRUCTION PHASE IMPACT 5. IMPACT ON CBA S

Project phase Construction Impact Impacts on Critical Biodiversity Areas Description of Construction phase impact on Critical Biodiversity Areas and ESAs. impact Mitigatability High Mitigation exists and will considerably reduce the significance of impacts • Existing roads or disturbance footprints should be used as far as possible. Should access roads, internal cables and overhead lines traverse drainage lines and riparian areas these should be microsited by a suitably qualified ecological and aquatic specialist before construction in that area starts to ensure any potential impacts are minimised • Minimise the development footprint as far as possible, which includes locating temporary-use areas such as construction camps and lay-down areas in low sensitivity or previously disturbed Potential areas. mitigation • Avoid impact to restricted and specialised habitats such as pans, wetlands and rock pavements. The final development footprint used in the EIA should be checked for such sensitive features in the field, such that there is a high degree of confidence that the final layout avoids such features so that significant changes to turbines or roads are not required at the preconstruction phase. • Minimise the development footprint near watercourses and other ecologically significant features. Assessment Without mitigation With mitigation Nature Negative Negative Long Impact will last between 10 and 15 Impact will last between 10 and 15 Duration Long term term years years Extending across the site and to Extending across the site and to Extent Local Local nearby settlements nearby settlements Natural and/ or social functions Natural and/ or social functions Intensity Low and/ or processes Very low and/ or processes are slightly are somewhat altered altered There are sound scientific reasons Probability Likely to expect that the impact will Likely The impact may occur definitely occur Substantive supportive data exists Substantive supportive data exists Confidence High High to verify the assessment to verify the assessment The affected environment will only The affected environment will only Reversibility Medium recover from the impact with Medium recover from the impact with significant intervention significant intervention Resource The resource is not damaged The resource is not damaged Low Low irreplaceability irreparably or is not scarce irreparably or is not scarce Significance Minor - negative Minor - negative The CBAs at the site were derived through desktop study and are not ground-truthed. The current field study indicates that many of these do not reflect known areas of high biodiversity or important Comment on ecological processes and no turbines are located within the CBAs. Although these areas are significance intended to protect hydrological processes, the development would not compromise these functions provided any features of actual significance that may be present are adequately buffered from development as has been done through the sensitivity mapping associated with this study. Cumulative As the total extent of CBAs within the site is very low, the potential for the Nuweveld West WEF to impacts contribute to cumulative impacts on CBAs is also seen as being low.

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6.6 OPERATIONAL PHASE IMPACT 1. IMPACTS ON FAUNA DURING OPERATION

Project phase Operation Impact Operational phase faunal impacts Description of Operational phase impacts on fauna impact Mitigatability Medium Mitigation exists and will notably reduce significance of impacts

• Adhere to the open space management plan which makes provision for the favourable management of the facility and the surrounding area for fauna. • Appropriate design of roads and other infrastructure to minimise faunal impacts and allow fauna Potential to pass over, through or underneath these features as appropriate. mitigation • A log should be kept detailing and fauna-related incidences or mortalities that occur on site, including roadkill, electrocutions etc. These should be reviewed annually and used to inform operational management and mitigation measures.

Assessment Without mitigation With mitigation Nature Negative Negative Impact will last Impact will last between 15 and 20 Duration On-going On-going between 15 and 20 years years Limited to the site Extending across the site and to Extent Local Limited and its immediate nearby settlements surroundings Natural and/ or social Natural and/ or social functions functions and/ or Intensity Moderate and/ or processes are moderately Low processes altered are somewhat altered Almost certain / It is most likely that the impact will Probability Likely The impact may occur Highly probable occur Substantive Substantive supportive data exists supportive data exists Confidence High High to verify the assessment to verify the assessment The affected The affected environment will only environmental will be Reversibility Medium recover from the impact with High able to recover from significant intervention the impact The resource is not Resource The resource is not damaged Low Low damaged irreparably irreplaceability irreparably or is not scarce or is not scarce Significance Moderate - negative Minor - negative

Comment on Habitat loss and disturbance will persist for the lifetime of the facility. The habitat could be partly significance restored thereafter.

Cumulative impacts on fauna are predicted to be low because there are no fauna species of high Cumulative conservation concern that are likely to be compromised by the development and habitat loss in impacts general would be low.

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6.7 OPERATIONAL PHASE IMPACT 2. IMPACTS ON RIVERINE RABBITS DURING OPERATION

Project phase Operation Impact Operational Phase impact on the Riverine Rabbit Description of There would potentially be impact on Riverine Rabbits at the site during operation due to impact operational activities as well as turbine noise. Mitigatability Low Mitigation does not exist; or mitigation will slightly reduce the significance of impacts Potential • The Fauna Monitoring Pogramme should utilise the operational period of the recommended mitigation funding to monitor the presence and activity of fauna on the site in relation to the preconstruction baseline. • All incidents involving Riverine Rabbits should be documented and reported to the local EWT field office in Loxton. If Rabbits are killed, the carcases should be collected and provided to EWT for the collection of DNA and other samples. Assessment Without mitigation With mitigation Nature Negative Negative Impact will last between 15 and 20 Impact will last between Duration On-going On-going years 15 and 20 years Extending across the site Extending across the site and to Extent Local Local and to nearby nearby settlements settlements Natural and/ or social Natural and/ or social functions functions and/ or Intensity Moderate and/ or processes are moderately Moderate processes are altered moderately altered The impact has occurred here or The impact has occurred Probability Probable elsewhere and could therefore Probable here or elsewhere and occur could therefore occur Determination is based on Determination is based Confidence Medium common sense and general Medium on common sense and knowledge general knowledge The affected The affected environmental will be environmental will be Reversibility High High able to recover from the impact able to recover from the impact The resource is The resource is irreparably Resource irreparably damaged and High damaged and is not represented High irreplaceability is not represented elsewhere elsewhere Significance Minor - negative Minor - negative Although this impact cannot be well-mitigated as it results from the operation of the wind farm, Comment on there is not a lot of suitable Riverine Rabbit habitat on the site with the result that a significant significance population is not likely to be present. As such, even if this impact occurs, its long-term significance is likely to be low. The development of the wind farm would contribute to cumulative impacts on Riverine Rabbits in Cumulative the area, but given the low significance of the site for Rabbits, the potential contribution is seen as impacts relatively low.

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6.8 OPERATIONAL PHASE IMPACT 3. IMPACTS ON MOUNTAIN REEDBUCK DURING OPERATION

Project phase Operation Impact Operational Phase impact on the Mountain Reedbuck Description of There would potentially be impact on Mountain Reedbuck at the site during operation due to impact operational activities as well as turbine noise. Low Mitigation does not exist; or mitigation will slightly reduce the significance of Mitigatability impacts Potential • The Fauna Monitoring Pogramme should utilise the operational period of the recommended mitigation funding to monitor the presence and activity of fauna such as Mountain Reedbuck on the site in relation to the preconstruction baseline. Assessment Without mitigation With mitigation Nature Negative Negative Impact will last between 15 and 20 Impact will last between Duration On-going On-going years 15 and 20 years Extending across the site Extending across the site and to Extent Local Local and to nearby nearby settlements settlements Natural and/ or social Natural and/ or social functions functions and/ or Intensity Moderate and/ or processes are moderately Moderate processes are altered moderately altered The impact has occurred here or The impact has occurred Probability Probable elsewhere and could therefore Probable here or elsewhere and occur could therefore occur Determination is based on Determination is based Confidence Medium common sense and general Medium on common sense and knowledge general knowledge The affected The affected environmental will be environmental will be Reversibility High High able to recover from the impact able to recover from the impact The resource is The resource is irreparably Resource irreparably damaged and High damaged and is not represented High irreplaceability is not represented elsewhere elsewhere Significance Minor - negative Minor - negative

Mountain Reedbuck are quite shy but are likely to become habituated to the presence and Comment on operation of the turbines. As such, even if this impact occurs, its long-term significance is likely to significance be low.

The development of the wind farm would contribute to cumulative impacts on Mountain Reedbuck Cumulative in the area, but the potential contribution is seen as relatively low as not all areas of suitable habitat impacts are likely to be affected.

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6.9 OPERATIONAL PHASE IMPACT 4. INCREASED SOIL EROSION RISK DURING OPERATION

Project phase Operation Impact Increased soil erosion risk Description of Soil erosion as a result of the disturbance created during construction impact Mitigatability High Mitigation exists and will considerably reduce the significance of impacts Potential • Disturbed areas near to drainage lines should receive priority in rehabilitation and operational mitigation phase monitoring. • There should be annual operational phase monitoring of erosion on site. Any erosion problems observed on-site should be rectified as soon as possible using the appropriate revegetation and erosion control works. Assessment Without mitigation With mitigation Nature Negative Negative Impact will last between 10 Impact will last between 5 Duration Long term Medium term and 15 years and 10 years Extending across the site Extending across the site and Extent Local Local and to nearby settlements to nearby settlements Natural and/ or social Natural and/ or social Intensity Moderate functions and/ or processes Low functions and/ or processes are moderately altered are somewhat altered The impact has occurred here Almost certain / It is most likely that the Probability Probable or elsewhere and could Highly probable impact will occur therefore occur Substantive supportive data Substantive supportive data Confidence High exists to verify the High exists to verify the assessment assessment The affected environment The affected environment will will only recover from the not be able to recover from Reversibility Medium Low impact with significant the impact - permanently intervention modified The resource is not Resource The resource is not damaged Low damaged irreparably or is Low irreplaceability irreparably or is not scarce not scarce Significance Minor - negative Minor - negative Comment on significance With mitigation, this impact can be well avoided, and erosion reduced to a low level. Cumulative Erosion would contribute to habitat degradation in the area. impacts

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6.10 DECOMMISSIONING PHASE IMPACT 1. FAUNAL IMPACTS DUE TO DECOMMISSIONING

Project phase Decommissioning Impact Faunal impacts due to decommissioning Description of Impact on fauna due to decommissioning impact Mitigatability High Mitigation exists and will considerably reduce the significance of impacts • Any potentially dangerous fauna such as snakes or fauna threatened by the decommissioning activities should be removed to a safe location prior to the commencement of decommissioning activities. • All hazardous materials should be stored in the appropriate manner to prevent contamination of the site. Any accidental chemical, fuel and oil spills that occur at the site should be cleaned up in the appropriate manner as related to the nature of the spill. Potential • All vehicles accessing the site should adhere to a low speed limit (40km/h max) to avoid mitigation collisions with susceptible species such as snakes and tortoises. • No excavated holes or trenches should be left open for extended periods as fauna may fall in become trapped. • All above-ground infrastructures should be removed from the site. Below-ground infrastructure such as cabling can be left in place if it does not pose a risk, as removal of such cables may generate additional disturbance and impact, however, this should be in accordance with the facilities’ decommissioning and recycling plan. Assessment Without mitigation With mitigation Nature Negative Negative impact will last between impact will last between 1 Duration Short term Short term 1 and 5 years and 5 years Extending across the site Extending across the site Extent Local and to nearby Local and to nearby settlements settlements Natural and/ or social Natural and/ or social functions and/ or functions and/ or Intensity Moderate Low processes are moderately processes altered are somewhat altered The impact has occurred Almost certain / It is most likely that the Probability Probable here or elsewhere and Highly probable impact will occur could therefore occur Substantive supportive Substantive supportive Confidence High data exists to verify the High data exists to verify the assessment assessment The affected The affected environmental will be environmental will be able Reversibility High High able to recover from the to recover from the impact impact The resource is damaged The resource is not Resource Medium irreparably but is Low damaged irreparably or is irreplaceability represented elsewhere not scarce Significance Minor - negative Minor - negative Comment on Decommissioning will be of short duration and no long-term impacts are likely. significance Cumulative Decommissioning will contribute towards cumulative impacts in the area, but this would be impacts transient and no long-term impacts from decommissioning are likely to occur.

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6.11 DECOMMISSIONING PHASE IMPACT 2. INCREASED SOIL EROSION RISK FOLLOWING DECOMMISSIONING

Project phase Decommissioning Impact Increased soil erosion risk Description of Soil erosion as a result of the disturbance created during decommissioning impact Mitigatability High Mitigation exists and will considerably reduce the significance of impacts Potential • Decommissioning disturbance within or near the drainage lines should be kept to a minimum mitigation and any disturbance in these areas should be rehabilitated as quickly as possible. • An erosion monitoring programme should be put in place for at least 3 years after decommissioning. Any problems observed should be rectified as soon as possible using the appropriate revegetation and erosion control works. Assessment Without mitigation With mitigation Nature Negative Negative Duration Impact will last between 10 Impact will last between 5 Long term Medium term and 15 years and 10 years Extent Extending across the site and Extending across the site and Local Local to nearby settlements to nearby settlements Intensity Natural and/ or social Natural and/ or social Moderate functions and/ or processes Low functions and/ or processes are moderately altered are somewhat altered Probability Almost certain The impact has occurred It is most likely that the / Highly Probable here or elsewhere and could impact will occur probable therefore occur Confidence Substantive supportive data Substantive supportive data High exists to verify the High exists to verify the assessment assessment Reversibility The affected environment The affected environment will only recover from the will not be able to recover Medium Low impact with significant from the impact - intervention permanently modified Resource The resource is not damaged The resource is not damaged Low Low irreplaceability irreparably or is not scarce irreparably or is not scarce Significance Minor - negative Minor - negative Comment on With mitigation, this impact can be well avoided and erosion reduced to a low level. significance Cumulative Erosion would contribute to habitat degradation in the area. impacts

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6.12 CUMULATIVE IMPACT 1. CUMULATIVE IMPACTS ON BROAD -SCALE ECOLOGICAL PROCESSES

Project phase Operation Impact Cumulative habitat loss and impact on broad -scale ecological processes Description of Cumulative impact on broad-scale ecological processes impact Mitigatability High Mitigation exists and will considerably reduce the significance of impacts • Adhere to the sensitivity maps and limits of acceptable change provided within this assessment Potential when determining the final layout of the WEFs and associated infrastructure. mitigation • Ensure that all the operational phase management plans are fully implemented and that the associated monitoring and feedback mechanisms to management are in place. Assessment Without mitigation With mitigation Nature Negative Negative Impact may be permanent, Impact may be permanent, Duration Permanent Permanent or in excess of 20 years or in excess of 20 years Impacts felt at a municipal Impacts felt at a municipal Extent Municipal area Municipal area level level Natural and/ or social Natural and/ or social Intensity Moderate functions and/ or processes Low functions and/ or processes are moderately altered are somewhat altered The impact has occurred Probability Likely The impact may occur Probable here or elsewhere and could therefore occur Substantive supportive data Substantive supportive data Confidence High exists to verify the High exists to verify the assessment assessment The affected environment The affected environment will not be able to recover will not be able to recover Reversibility Low Low from the impact - from the impact - permanently modified permanently modified The resource is damaged Resource The resource is not damaged Medium irreparably but is Low irreplaceability irreparably or is not scarce represented elsewhere Significance Moderate - negative Minor - negative Comment on With avoidance and mitigation, impact on ecological processes can be reduced to low levels. significance Cumulative Given the low current levels of transformation in the area, the contribution of the current impacts development to cumulative impact is considered low given its relatively low extent in relation to the surrounding landscape.

6.13 NO-GO ALTERNATIVE

Assuming that the project does not occur, the wind farm would not be built and the current land use would continue into the future. The area is currently used for extensive livestock and/or game farming which are considered to be largely compatible with biodiversity maintenance. Some species may be negatively affected by farming including many predators which are targeted due to their negative impact on livestock, while some species may also be vulnerable to habitat loss or degradation and may experience depressed populations within the farming landscape. It is however important to recognise that the development does not represent an alternative to extensive livestock farming, but rather an additional impact that may serve to compound some of the negative effects of the existing land use.

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Project phase No-Go Alternative Impact Impact on Terrestrial Ecology should the project not go ahead Description of The no-go alternative assumes the project does not go ahead impact High Mitigation exists and will considerably reduce the significance of Mitigatability impacts • Standard agricultural management practices remain in place and are actively Potential mitigation implemented by the local farming community. Assessment Without mitigation With mitigation Nature Negative Negative Impact may be Impact will last between Duration On-going permanent, or in excess of On-going 15 and 20 years 20 years Extending across the site Extending across the site Extent Local Local and to nearby and to nearby settlements settlements Natural and/ or social Natural and/ or social functions and/ or functions and/ or Intensity Low Very low processes are moderately processes are slightly altered altered There are sound scientific Certain / Probability reasons to expect that the Likely The impact may occur definite impact will definitely occur Substantive supportive Substantive supportive Confidence High data exists to verify the High data exists to verify the assessment asses sment The affected The affected environmental will be able environmental will be Reversibility High to recover from the High able to recover from the impact impact

The resource is not The resource is not Resource damaged irreparably or is Low Low damaged irreparably or irreplaceability not scarce is not scarce

Significance Minor - negative Negligible - negative Comment on The area is currently subjected to extensive livestock grazing which is seen as largely significance compatible with biodiversity maintenance. Farming will increase cumulative impacts on vulnerable species such as predators which Cumulative impacts are specifically persecuted or on habitat specialist species which may be vulnerable to habitat loss or degradation.

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6.14 SUMMARY ASSESSMENT

A summary of the impacts associated with the development of the Nuweveld West Wind Farm is provided below. There are no impacts associated with the development that cannot be mitigated to a low level. As such, there are not fatal flaws or high impacts associated with the development that would prevent it from proceeding.

Table 9. Summary impact assessment table for the Nuweveld West Wind Farm.

Project phase Impact Without Mitigation With Mitigation

Construction Impacts on vegetation and plant SCC Moderate - negative Minor - negative

Construction Direct and indirect faunal impacts Moderate - negative Minor - negative

Construction phase impact on the Riverine Construction Moderate - negative Minor - negative Rabbit

Construction phase impact on the Mountain Construction Moderate - negative Minor - negative Reedbuck

Construction Impacts on Critical Biodiversity Areas Minor - negative Minor - negative

Operation Operational Phase impact on fauna Moderate - negative Minor - negative

Operational Phase impact on the Riverine Operation Minor - negative Minor - negative Rabbit

Operational Phase impact on Mountain Operation Minor - negative Minor - negative Reedbuck

Operation Increased soil erosion risk Minor - negative Minor - negative

Cumulative habitat loss and impact on broad- All phases Moderate - negative Minor - negative scale ecological processes

Decommissioning Faunal impacts due to decommissioning Minor - negative Minor - negative

Decommissioning Increased soil erosion risk Minor - negative Minor - negative

7 CONCLUSION & RECOMMENDATIONS

Overall, the Nuweveld West site is considered generally favourable for development of the wind farm. Although there are some constrained areas where development should not occur, there are large tracts of the site that are considered low or medium sensitivity and where development would have a low impact. Although impacts on the Riverine Rabbit are a potential concern, its presence on the escarpment is doubtful based on the results of the camera trapping and the total extent of available habitat is low suggesting that it may be insufficient to support a viable population of rabbits. Nevertheless, the high threat status associated with this species demands a conservative approach and no turbines or buildings (incl. substation (and associated battery

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 74 facility)) should be located within the riparian areas or the Very High sensitivity buffer areas that have been implemented around these features. As the current layout does avoid these areas, long-term impacts on Riverine Rabbits are likely to be low. However, it is recommended that should the development go ahead, that funding is provided towards a Fauna Monitoring Programme, to monitor the impact of the development on Riverine Rabbits and other fauna at the site so that more can be learnt about the effect of wind farm developments on these species so as to inform future wind farm development in the Nuweveld and the wider Karoo. The purpose of the monitoring is not to directly inform or alter the operation of the current wind farm as a form of mitigation, the intention is rather that the opportunity is used to collect baseline information on the manner in which fauna react to the construction and operation of a wind farm so that this information can be used to reduce potential conflict between wind farms and fauna more generally in the karoo and especially in areas where these conflicts may be potentially of greater consequence.

The most significant impacts associated with the Nuweveld West WEF would occur during the construction phase as a result of disturbance and habitat loss. Long-term operational impacts would be lower and restricted to low-level operational disturbance and turbine noise effects. Although there are some tracts of CBA1 within the site that would be affected by the development, a review of the basis of these reveals that they are not irreplaceable and general mitigation and avoidance of sensitive features identified as part of this assessment would be effective at maintaining the ecological functioning of the site. As such, the potential impact of the development on CBAs is considered acceptable and low. In terms of cumulative impacts the area has experienced no impact from wind farm development to date with the result that the wider area is still largely intact and the contribution of the current development to cumulative impact would be minor.

The overall footprint of the development is well within the set limits of acceptable change and as such, there are no fatal flaws in this regard. There are no impacts associated with the development of the Nuweveld West WEF that cannot be mitigated to an acceptable level. As such, should all the proposed mitigation be implemented, this development is deemed acceptable from an ecological impact perspective. It is thus the reasoned opinion of the specialist that there the Nuweveld West WEF development should be allowed to proceed to the EIA phase.

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8 REFERENCES

Agha M, Lovich JE, Ennen JR, Augustine B, Arundel TR, Murphy M, Meyer-Wilkins K, Bjurlin C, Delaney D, Briggs J, Austin M, Madrak SV, Price SJ. 2015. Turbines and terrestrial vertebrates: variation in tortoise survivorship between a wind energy facility and an adjacent undisturbed wildland area in the Desert Southwest (USA). Environmental Management 56, 332–341.

Alexander, G. & Marais, J. 2007. A Guide to the Reptiles of Southern Africa. Struik Nature, Cape Town.

Branch W.R. 1998. Field guide to snakes and other reptiles of southern Africa. Struik, Cape Town.

Bates, M.F., Branch, W.R., Bauer, A.M., Burger, M., Marais, J., Alexander, G.J. & de Villiers, M. S. 2013. Atlas and Red List of the Reptiles of South Africa, Lesotho and Swaziland. Strelitzia 32. SANBI, Pretoria.

Department of Environmental Affairs and Tourism, 2007. National Environmental Management: Biodiversity Act, 2004 (Act 10 of 2004): Publication of lists of Critically Endangered, Endangered, Vulnerable and Protected Species. Government Gazette, Republic of South Africa.

Du Preez, L. & Carruthers, V. 2009. A Complete Guide to the Frogs of Southern Africa. Struik Nature., Cape Town.

Lovich JE, Ennen JR, Madrak S, Meyer K, Loughran C, Bjurlin C, Arundel T, Turner W, Jones C, Groenendaal GM. 2011 Effects of wind energy production on growth, demography, and survivorship of a desert tortoise (Gopherus agassizii) population in southern California with comparisons to natural populations. Herpetological Conservation and Biology 6, 161–174.

Minter LR, Burger M, Harrison JA, Braack HH, Bishop PJ & Kloepfer D (eds). 2004. Atlas and Red Data book of the frogs of South Africa, Lesotho and Swaziland . SI/MAB Series no. 9. Smithsonian Institution, Washington, D.C.

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

Nel, J.L., Murray, K.M., Maherry, A.M., Petersen, C.P., Roux, D.J., Driver, A., Hill, L., Van Deventer, H., Funke, N., Swartz, E.R., Smith-Adao, L.B., Mbona, N., Downsborough, L. and Nienaber, S. (2011). Technical Report for the National Freshwater Ecosystem Priority Areas project. WRC Report No. K5/1801.

Skinner, J.D. & Chimimba, C.T. 2005. The mammals of the Southern African Subregion. Cambridge University Press, Cambridge.

Taylor A, Avenant N, Schulze E, Viljoen P, Child MF. 2016. A conservation assessment of Redunca fulvorufula fulvorufula. In Child MF, Roxburgh L, Do Linh San E, Raimondo D,

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Davies-Mostert HT, editors. The Red List of Mammals of South Africa, Swaziland and Lesotho. South African National Biodiversity Institute and Endangered Wildlife Trust, South Africa

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9 ANNEX 1. LIST OF PLANT SPECIES

List of plant species recorded from the broad vicinity of the Nuweveld WEF site, based on the SANBI POSA database. Family Genus Species Rank Subspecies IUCN Status Asteraceae Euryops nodosus LC Malvaceae Hermannia alnifolia LC Poaceae Brachiaria marlothii LC Poaceae Helictotrichon hirtulum LC Asteraceae Gazania lichtensteinii LC Asteraceae Senecio hastatus LC Poaceae Echinochloa colona LC Aizoaceae Trianthema parvifolia var. parvifolia LC Fabaceae Indigofera meyeriana LC Fumariaceae Fumaria muralis subsp. muralis Malvaceae Hibiscus pusillus LC Asteraceae Felicia namaquana LC Asteraceae Pentzia tortuosa LC Amaranthaceae Salsola kali Asteraceae Helichrysum albertense DD Poaceae Enneapogon desvauxii LC Poaceae Sporobolus ioclados LC Amaranthaceae Chenopodium album Fabaceae Prosopis glandulosa var. glandulosa NE Oxalidaceae Oxalis obtusa LC Fabaceae Argyrolobium argenteum LC Asteraceae Sonchus asper subsp. asper Caryophyllaceae Spergularia sp. Poaceae Stipagrostis ciliata var. capensis LC Fabaceae Indigofera alternans var. alternans LC Aizoaceae Galenia pubescens LC Acanthaceae Justicia incana Asteraceae Eriocephalus microphyllus var. microphyllus LC Aizoaceae Chasmatophyllum stanleyi LC Asteraceae Gorteria alienata Lamiaceae Salvia disermas LC Asparagaceae Asparagus mucronatus LC Fabaceae Lessertia inflata LC Asteraceae Osteospermum scariosum var. scariosum NE Cyperaceae Cyperus longus var. tenuiflorus NE Poaceae Themeda triandra LC Apiaceae Annesorhiza filicaulis EN Potamogetonaceae Zannichellia palustris LC Santalaceae Thesium sonderianum DD Acanthaceae Barleria stimulans LC Scrophulariaceae Manulea karrooica LC Poaceae Tragus koelerioides LC

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Plantaginaceae Veronica persica NE Pteridaceae Cheilanthes hirta var. brevipilosa Poaceae Panicum maximum LC Scrophulariaceae Selago rigida LC Fabaceae Lessertia pauciflora Verbenaceae Chascanum pumilum LC Asparagaceae Asparagus laricinus LC Asteraceae Kleinia longiflora LC Poaceae Ehrharta dura LC Poaceae Tenaxia disticha Aizoaceae Malephora thunbergii LC Lobeliaceae Lobelia erinus LC Fabaceae Melolobium canescens LC Hyacinthaceae Veltheimia capensis LC Poaceae Cenchrus ciliaris LC Boraginaceae Heliotropium supinum Brassicaceae Sisymbrium burchellii var. burchellii LC Scrophulariaceae Selago albida LC Solanaceae Lycium oxycarpum LC Pteridaceae Pellaea calomelanos var. calomelanos LC Cyperaceae Isolepis setacea LC Fabaceae Indigofera alternans Asteraceae Crassothonna capensis LC Malvaceae Hermannia grandiflora LC Malvaceae Hermannia paucifolia LC Asteraceae Felicia lasiocarpa LC Asteraceae Berkheya spinosa LC Scrophulariaceae Selago saxatilis LC Cyperaceae Bulbostylis humilis LC Rubiaceae Kohautia caespitosa subsp. brachyloba LC Poaceae Helictotrichon sp. Grubbiaceae Grubbia rosmarinifolia subsp. rosmarinifolia NE Asteraceae Vellereophyton niveum LC Nyctaginaceae Boerhavia cordobensis Verbenaceae Chascanum pinnatifidum var. pinnatifidum LC Asteraceae Berkheya glabrata LC Melianthaceae Melianthus comosus LC Papaveraceae Papaver aculeatum LC Malvaceae Hermannia filifolia var. filifolia NE Poaceae Bromus catharticus NE Poaceae Eragrostis chloromelas LC Apocynaceae Microloma armatum var. armatum LC Poaceae Fingerhuthia sesleriiformis LC Asparagaceae Asparagus exuvialis forma exuvialis NE Asphodelaceae Bulbine lagopus LC Asteraceae Pentzia globosa LC Solanaceae Nicotiana glauca Aizoaceae Mesembryanthemum splendens subsp. pentagonum

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Asteraceae Felicia muricata subsp. muricata LC Solanaceae Withania somnifera LC Acanthaceae Blepharis mitrata LC Caryophyllaceae Spergularia media Thymelaeaceae Passerina obtusifolia LC Geraniaceae Pelargonium tragacanthoides LC Geraniaceae Pelargonium aridum LC Asteraceae Pegolettia retrofracta LC Campanulaceae Wahlenbergia cernua LC Polygalaceae Polygala leptophylla var. leptophylla LC Solanaceae Lycium schizocalyx LC Poaceae Melica racemosa LC Hyacinthaceae Ornithogalum juncifolium LC Anacardiaceae Searsia pyroides Asteraceae Ursinia nana subsp. nana LC Aizoaceae Ruschia intricata LC Poaceae Eragrostis lehmanniana var. lehmanniana LC Asteraceae Cirsium vulgare Fabaceae Indigofera exigua LC Aizoaceae Delosperma sp. Asteraceae Gazania krebsiana Aizoaceae Trichodiadema sp. Malvaceae Hermannia stipulacea LC Anacardiaceae Searsia pyroides var. pyroides LC Plantaginaceae Plantago lanceolata LC Poaceae Aristida diffusa subsp. diffusa LC Juncaceae Juncus punctorius LC Rubiaceae Anthospermum rigidum subsp. pumilum LC Portulacaceae Portulaca oleracea Anacardiaceae Searsia longispina LC Menispermaceae Cissampelos capensis LC Asparagaceae Asparagus racemosus LC Polygalaceae Polygala ephedroides LC Santalaceae Lacomucinaea lineata Poaceae Tragus racemosus LC Orchidaceae Eulophia hians var. nutans LC Hyacinthaceae Daubenya marginata LC Asteraceae Oedera spinescens Cyperaceae Cyperus bellus LC Asteraceae Gazania krebsiana subsp. serrulata LC Lamiaceae Lamium amplexicaule Scrophulariaceae Nemesia cynanchifolia LC Solanaceae Lycium hirsutum LC Geraniaceae Pelargonium abrotanifolium LC Asteraceae Helichrysum cerastioides var. cerastioides LC Juncaceae Juncus capensis LC Hyacinthaceae Ledebouria apertiflora LC Asteraceae Tragopogon dubius

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Asteraceae Helichrysum rugulosum LC Malvaceae Melhania rehmannii LC Geraniaceae Monsonia camdeboensis LC Aizoaceae Mesembryanthemum junceum Scrophulariaceae Nemesia sp. Asteraceae Pentzia quinquefida LC Apocynaceae Huernia thuretii LC Caryophyllaceae Polycarpon tetraphyllum Asteraceae Arctotis dimorphocarpa LC Amaranthaceae Salsola calluna LC Asteraceae Othonna eriocarpa LC Poaceae Enneapogon cenchroides LC Kewaceae Kewa salsoloides LC Aizoaceae Mesembryanthemum noctiflorum subsp. stramineum Geraniaceae Pelargonium minimum LC Juncaceae Juncus dregeanus subsp. dregeanus LC Aizoaceae Mesembryanthemum geniculiflorum Poaceae Tragus berteronianus LC Crassulaceae Crassula corallina subsp. corallina LC Boraginaceae Anchusa sp. Apocynaceae Huernia humilis LC Asteraceae Pentzia lanata LC Poaceae Lolium rigidum NE Cyperaceae Cyperus capensis LC Rubiaceae Nenax microphylla LC Pteridaceae Cheilanthes hirta var. hirta LC Aizoaceae Galenia africana LC Fabaceae Dichilus gracilis LC Lamiaceae Stachys cuneata LC Crassulaceae Adromischus maculatus LC Fabaceae Vachellia karroo LC Scrophulariaceae Chaenostoma archeri LC Asteraceae Senecio angustifolius LC Poaceae Cynodon dactylon LC Euphorbiaceae Euphorbia peplus NE Iridaceae Gladiolus permeabilis subsp. edulis LC Alliaceae Tulbaghia nutans LC Zygophyllaceae Roepera incrustata Amaranthaceae Salsola aphylla LC Orobanchaceae Harveya sp. Iridaceae Moraea unguiculata LC Leucobryaceae Campylopus introflexus Polygonaceae Rumex crispus Solanaceae Solanum burchellii LC Santalaceae Thesium junceum var. junceum LC Asteraceae Felicia ovata LC Lythraceae Nesaea anagalloides LC Asteraceae Gnaphalium confine LC

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Convolvulaceae Convolvulus dregeanus LC Aizoaceae Drosanthemum parvifolium LC Acanthaceae Justicia orchioides subsp. glabrata LC Brassicaceae Lepidium africanum subsp. africanum LC Scrophulariaceae Jamesbrittenia sp. Apiaceae Deverra denudata subsp. aphylla LC Malvaceae Hermannia pulchella LC Asteraceae Osteospermum calendulaceum LC Amaryllidaceae Gethyllis villosa LC Asteraceae Euryops lateriflorus LC Rutaceae Agathosma cerefolium LC Juncaceae Juncus oxycarpus LC Scrophulariaceae Selago acocksii LC Gentianaceae Sebaea natalensis LC Asphodelaceae Trachyandra karrooica LC Poaceae Melica decumbens LC Asteraceae Helichrysum pumilio subsp. pumilio LC Euphorbiaceae Euphorbia serpens NE Cyperaceae Cyperus marginatus LC Scrophulariaceae Chaenostoma halimifolium LC Aizoaceae Tetragonia arbuscula LC Aizoaceae Ruschia sp. Lamiaceae Stachys linearis LC Poaceae Eragrostis bicolor LC Geraniaceae Pelargonium glutinosum LC Lentibulariaceae Utricularia bisquamata LC Scrophulariaceae Buddleja glomerata LC Cyperaceae Schoenoxiphium sp. Aizoaceae Tetragonia spicata LC Solanaceae Solanum nigrum Acanthaceae Blepharis capensis LC Euphorbiaceae Euphorbia stellispina LC Scrophulariaceae Selago centralis LC Crassulaceae Crassula capitella subsp. thyrsiflora LC Crassulaceae Adromischus humilis LC Plantaginaceae Veronica anagallis-aquatica LC Asteraceae Helichrysum dregeanum LC Apiaceae Notobubon ferulaceum LC Asteraceae Cineraria vagans EN Scrophulariaceae Buddleja salviifolia LC Euphorbiaceae Euphorbia rhombifolia LC Aizoaceae Trichodiadema obliquum DD Scrophulariaceae Jamesbrittenia filicaulis LC Apocynaceae Huernia barbata subsp. barbata LC Polygonaceae Rumex lanceolatus LC Asteraceae Berkheya pinnatifida subsp. pinnatifida LC Amaryllidaceae Gethyllis longistyla LC Amaranthaceae Amaranthus schinzianus LC

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Geraniaceae Pelargonium pseudofumarioides LC Fabaceae Indigofera sessilifolia LC Malvaceae Anisodontea malvastroides LC Cyperaceae Ficinia ramosissima LC Asteraceae Arctotis microcephala LC Asteraceae Helichrysum lineare LC Santalaceae Viscum hoolei LC Malvaceae Hermannia coccocarpa LC Aizoaceae Mesembryanthemum stenandrum LC Apocynaceae Xysmalobium gomphocarpoides var. gomphocarpoides LC Solanaceae Lycium bosciifolium LC Poaceae Eragrostis procumbens LC Asteraceae Senecio reptans LC Lamiaceae Salvia stenophylla Aizoaceae Hereroa concava DD Aizoaceae Ruschia spinosa LC Asteraceae Vellereophyton dealbatum LC Boraginaceae Lobostemon stachydeus LC Lobeliaceae Lobelia thermalis LC Asteraceae Senecio striatifolius LC Apocynaceae Asclepias sp. Asteraceae Osteospermum scariosum var. integrifolium NE Hyacinthaceae Albuca suaveolens LC Boraginaceae Anchusa riparia LC Malvaceae Hermannia filifolia var. grandicalyx NE Asteraceae Ifloga glomerata LC Asphodelaceae Astroloba sp. Aizoaceae Tetragonia glauca LC Malvaceae Anisodontea scabrosa LC Solanaceae Lycium cinereum LC Asteraceae Felicia filifolia subsp. schaeferi LC Asteraceae Osteospermum spinescens LC Amaranthaceae Atriplex semibaccata Fabaceae Trifolium africanum var. africanum NE Juncaceae Juncus exsertus LC Asteraceae Gazania serrata LC Caryophyllaceae Pollichia campestris LC Asteraceae Pteronia adenocarpa LC Poaceae Fingerhuthia africana LC Hypoxidaceae Empodium gloriosum LC Poaceae Schismus barbatus LC Scrophulariaceae Zaluzianskya sp. Achariaceae Guthriea capensis LC Aizoaceae Galenia fruticosa LC Geraniaceae Pelargonium alternans subsp. alternans LC Asphodelaceae Bulbine sp. Poaceae Hyparrhenia hirta LC Scrophulariaceae Chaenostoma sp.

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Aizoaceae Galenia secunda LC Caryophyllaceae Silene burchellii subsp. modesta LC Malvaceae Hermannia cuneifolia var. glabrescens LC Asteraceae Athanasia microcephala LC Asteraceae Gazania krebsiana subsp. arctotoides LC Asteraceae Cineraria lobata subsp. lobata LC Aizoaceae Galenia glandulifera LC Molluginaceae Pharnaceum confertum var. brachyphyllum LC Ruscaceae Eriospermum corymbosum LC Cyperaceae Isolepis expallescens VU Asteraceae Senecio articulatus Rubiaceae Kohautia cynanchica LC Asteraceae Tarchonanthus minor LC Asteraceae Helichrysum zeyheri LC Poaceae Festuca scabra LC Asteraceae Helichrysum pentzioides LC Iridaceae Moraea sp. Euphorbiaceae Euphorbia hypogaea LC Oxalidaceae Oxalis pes -caprae var. pes -caprae LC Asteraceae Leysera tenella LC Poaceae Sorghum sp. Scrophulariaceae Cromidon decumbens LC Asteraceae Geigeria obtusifolia LC Crassulaceae Cotyledon cuneata LC Asteraceae Felicia filifolia subsp. filifolia LC Malvaceae Hermannia cuneifolia var. cuneifolia LC Asteraceae Cotula microglossa LC Poaceae Eragrostis obtusa LC Asteraceae Senecio asperulus LC Asteraceae Senecio sp. Fabaceae Lessertia frutescens subsp. microphylla LC Asteraceae Oedera oppositifolia Fabaceae Melolobium candicans LC Fabaceae Melolobium obcordatum LC Asteraceae Oncosiphon grandiflorus LC Ebenaceae Diospyros lycioides subsp. lycioides LC Asteraceae Senecio burchellii LC Asteraceae Garuleum bipinnatum LC Malvaceae Hermannia vestita LC Aizoaceae Pleiospilos compactus subsp. canus LC Hyacinthaceae Drimia anomala LC Poaceae Aristida diffusa subsp. burkei LC Solanaceae Solanum retroflexum LC Poaceae Stipagrostis obtusa LC Asteraceae Lactuca inermis LC Anacardiaceae Searsia undulata LC Peraceae Clutia sp. Apocynaceae Duvalia maculata LC

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Asteraceae Symphyotrichum squamatum Asteraceae Chrysocoma obtusata LC Aizoaceae Drosanthemum floribundum LC Brassicaceae Erucastrum strigosum LC Euphorbiaceae Euphorbia inaequilatera LC Aizoaceae Trichodiadema intonsum LC Geraniaceae Pelargonium ramosissimum LC Lamiaceae Stachys rugosa LC Linaceae Linum thunbergii LC Scrophulariaceae Chaenostoma macrosiphon LC Capparaceae Cadaba aphylla LC Scrophulariaceae Chaenostoma pauciflorum LC Asteraceae Oncosiphon piluliferus LC Amaranthaceae Chenopodium schraderianum Pedaliaceae Sesamum capense LC Scrophulariaceae Selago gracilis LC Asteraceae Crassothonna protecta LC Asteraceae Senecio cordifolius LC Asteraceae Euryops anthemoides subsp. anthemoides LC Asphodelaceae Kniphofia uvaria LC Rutaceae Ruta graveolens Boraginaceae Amsinckia menziesii Apocynaceae Schizoglossum bidens subsp. atrorubens LC Asteraceae Athanasia linifolia LC Asparagaceae Asparagus capensis var. capensis LC Asteraceae Senecio cotyledonis LC Asteraceae Cineraria mollis LC Asteraceae Senecio achilleifolius LC Solanaceae Solanum capense LC Poaceae Cymbopogon dieterlenii LC Amaranthaceae Dysphania carinata Asteraceae Berkheya carlinifolia Fabaceae Indigofera sp. Pteridaceae Pellaea rufa LC Asteraceae Arctotis perfoliata LC Asteraceae Mantisalca salmantica Plumbaginaceae Limonium sinuatum subsp. sinuatum Hyacinthaceae Ornithogalum flexuosum LC Dipsacaceae Scabiosa columbaria LC Aizoaceae Drosanthemum lique LC Cyperaceae Afroscirpoides dioeca Brassicaceae Sisymbrium capense LC Asteraceae Osteospermum sinuatum Acanthaceae Acanthopsis hoffmannseggiana DD Iridaceae Moraea miniata LC Crassulaceae Crassula pubescens subsp. pubescens LC Malvaceae Hermannia burkei LC Asteraceae Cuspidia cernua subsp. annua LC

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Crassulaceae Crassula subaphylla var. subaphylla LC Acanthaceae Justicia spartioides Asteraceae Eriocephalus eximius LC Asteraceae Euryops imbricatus LC Scrophulariaceae Gomphostigma virgatum LC Malvaceae Hermannia sp. Cucurbitaceae Cucumis africanus LC Asteraceae Cineraria aspera LC Campanulaceae Wahlenbergia capillacea subsp. capillacea LC Apiaceae Notobubon laevigatum LC Asteraceae Euryops empetrifolius LC Scrophulariaceae Aptosimum procumbens LC Poaceae Stipagrostis namaquensis LC Brassicaceae Heliophila sp. Asparagaceae Asparagus striatus LC Anacardiaceae Searsia lancea LC Geraniaceae Pelargonium nervifolium LC Hyacinthaceae Massonia echinata LC Asteraceae Pentzia punctata LC Geraniaceae Pelargonium griseum LC Apiaceae Berula thunbergii LC Aizoaceae Mesembryanthemum oubergense LC Gisekiaceae Gisekia pharnaceoides Asteraceae Pteronia staehelinoides LC Scrophulariaceae Diascia sp. Oxalidaceae Oxalis heterophylla LC Scrophulariaceae Manulea chrysantha LC Asphodelaceae Trachyandra acocksii LC Asteraceae Chrysocoma ciliata LC Caryophyllaceae Dianthus namaensis var. dinteri LC Asteraceae Conyza scabrida Scrophulariaceae Cromidon sp. Asteraceae Geigeria filifolia LC Asteraceae Chrysocoma sp. Poaceae Enneapogon scaber LC Juncaceae Juncus rigidus LC Asteraceae Troglophyton capillaceum subsp. capillaceum LC Lycopodiaceae Lycopodium clavatum LC Malvaceae Hermannia erodioides LC Poaceae Digitaria argyrograpta LC Aizoaceae Stomatium sp. Convolvulaceae Convolvulus sagittatus LC Peraceae Clutia thunbergii LC Malvaceae Anisodontea sp. Crassulaceae Crassula rupestris subsp. rupestris LC Hyacinthaceae Albuca exuviata LC Asteraceae Lasiopogon glomerulatus LC Asteraceae Helichrysum lucilioides LC

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Zygophyllaceae Augea capensis LC Loranthaceae Moquiniella rubra LC Aizoaceae Trichodiadema barbatum LC Asteraceae Oedera humilis Amaranthaceae Suaeda inflata LC Poaceae Eragrostis homomalla LC Poaceae Bromus pectinatus LC Poaceae Digitaria sanguinalis NE Poaceae Eragrostis cilianensis LC Aizoaceae Galenia pallens DD Aizoaceae Tetragonia fruticosa LC Asparagaceae Asparagus burchellii LC Asteraceae Curio hallianus LC Anacampserotaceae Anacampseros ustulata LC Santalaceae Thesium disciflorum LC Polygalaceae Muraltia macrocarpa LC Poaceae Eragrostis curvula LC Poaceae Hordeum capense LC Asparagaceae Asparagus retrofractus LC Aizoaceae Aizoon glinoides LC Scrophulariaceae Hebenstretia glaucescens LC Asteraceae Senecio incomptus LC Aizoaceae Ruschia pauciflora DD Asteraceae Osteospermum leptolobum LC Asteraceae Eriocephalus microcephalus LC Poaceae Ehrharta erecta var. erecta LC Solanaceae Lycium horridum LC Aizoaceae Pleiospilos compactus subsp. compactus LC Anacardiaceae Searsia burchellii LC Asteraceae Eriocephalus brevifolius LC Asteraceae Pentzia incana LC Iridaceae Tritonia karooica LC Fabaceae Lotononis carnosa subsp. carnosa LC Ophioglossaceae Ophioglossum polyphyllum var. polyphyllum LC Geraniaceae Geranium dregei LC Asteraceae Pseudognaphalium undulatum LC Urticaceae Urtica urens Poaceae Ehrharta calycina LC Brassicaceae Heliophila suavissima LC Colchicaceae Ornithoglossum dinteri LC Scrophulariaceae Chaenostoma revolutum LC Asteraceae Phymaspermum aciculare LC Hyacinthaceae Dipcadi ciliare LC Poaceae Sporobolus fimbriatus LC Polygalaceae Polygala sp. Iridaceae Babiana bainesii LC Amaranthaceae Kyphocarpa angustifolia LC Aizoaceae Malephora purpureo -crocea LC

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Aizoaceae Tetragonia sarcophylla LC Amaranthaceae Suaeda fruticosa LC Asteraceae Senecio madagascariensis LC Malvaceae Grewia robusta LC Scrophulariaceae Selago sp. Asteraceae Dimorphotheca cuneata LC Asphodelaceae Aloe grandidentata LC Asteraceae Othonna furcata LC Asteraceae Euryops oligoglossus subsp. oligoglossus LC Campanulaceae Wahlenbergia nodosa LC Malvaceae Hermannia desertorum LC Malvaceae Anisodontea capensis LC Colchicaceae Colchicum melanthoides Anacampserotaceae Anacampseros albidiflora LC Scrophulariaceae Diascia capsularis LC Scrophulariaceae Selago magnakarooica LC Hyacinthaceae Drimia sp. Ranunculaceae Clematis brachiata LC Thymelaeaceae Passerina corymbosa LC Amaranthaceae Bassia salsoloides LC Asteraceae Eriocephalus tenuifolius LC Asteraceae Pseudognaphalium luteoalbum LC Fabaceae Lotononis azureoides LC Scrophulariaceae Jamesbrittenia tysonii LC Geraniaceae Erodium cicutarium Geraniaceae Monsonia crassicaulis LC Poaceae Cymbopogon prolixus LC Hyacinthaceae Albuca prasina Poaceae Tricholaena capensis subsp. capensis LC Thymelaeaceae Lasiosiphon deserticola LC Araliaceae Cussonia paniculata subsp. paniculata LC Asteraceae Sonchus tenerrimus LC Crassulaceae Crassula natans var. minus LC Asteraceae Dicerothamnus rhinocerotis Aizoaceae Mesembryanthemum tetragonum Malvaceae Anisodontea triloba LC Ricciaceae Riccia albovestita Asteraceae Helichrysum trilineatum LC Achariaceae Kiggelaria africana LC Limeaceae Limeum aethiopicum var. intermedium NE Asteraceae Pteronia membranacea LC Scrophulariaceae Aptosimum spinescens LC Fabaceae Aspalathus acicularis subsp. acicularis LC Zygophyllaceae Roepera foetida Asteraceae Geigeria ornativa subsp. ornativa LC Molluginaceae Pharnaceum detonsum LC Brassicaceae Heliophila minima LC Poaceae Chaetobromus involucratus subsp. dregeanus LC

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Aizoaceae Mesembryanthemum sp. Asteraceae Phymaspermum thymelaeoides Malvaceae Abutilon sonneratianum LC Amaranthaceae Atriplex lindleyi subsp. inflata Polygonaceae Polygonum aviculare Scrophulariaceae Nemesia fruticans LC Poaceae Eragrostis mexicana subsp. virescens NE Brassicaceae Lepidium englerianum Bignoniaceae Rhigozum obovatum LC Crassulaceae Adromischus hemisphaericus LC Oxalidaceae Oxalis setosa DD Poaceae Pennisetum sphacelatum LC Asteraceae Oedera glandulosa Zygophyllaceae Roepera lichtensteiniana Asteraceae Euryops oligoglossus subsp. racemosus LC Asteraceae Phymaspermum parvifolium LC Iridaceae Lapeirousia plicata subsp. foliosa Crassulaceae Crassula montana subsp. quadrangularis LC Euphorbiaceae Euphorbia spartaria LC Scrophulariaceae Peliostomum leucorrhizum LC Poaceae Pentameris airoides subsp. airoides LC Amaranthaceae Atriplex nummularia subsp. nummularia Asteraceae Euryops subcarnosus subsp. vulgaris LC Asphodelaceae Aloe claviflora LC Geraniaceae Pelargonium senecioides LC Aizoaceae Mestoklema tuberosum LC Apocynaceae Duvalia angustiloba LC Rubiaceae Anthospermum dregei subsp. dregei LC Poaceae Sporobolus tenellus LC Polygalaceae Polygala hottentotta LC Scrophulariaceae Limosella grandiflora LC Asparagaceae Asparagus aethiopicus LC Aizoaceae Galenia sarcophylla LC Bryaceae Bryum alpinum Fabaceae Melilotus indicus NE Apocynaceae Gomphocarpus filiformis LC Asteraceae Felicia hirsuta LC Aizoaceae Stomatium suaveolens LC Poaceae Tribolium purpureum LC Asphodelaceae Haworthiopsis fasciata Poaceae Hordeum murinum subsp. glaucum NE Crassulaceae Crassula tetragona subsp. tetragona LC Cucurbitaceae Cucumis zeyheri LC Scrophulariaceae Diascia alonsooides LC Crassulaceae Crassula natans Iridaceae Romulea atrandra var. esterhuyseniae LC Euphorbiaceae Euphorbia sp. Aizoaceae Mesembryanthemum coriarium

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Fabaceae Lotononis pungens LC Poaceae Phragmites australis LC Funariaceae Funaria hygrometrica Fabaceae Argyrolobium sp. Plantaginaceae Plantago major Asteraceae Eriocephalus ericoides subsp. ericoides LC Zygophyllaceae Tetraena chrysopteron Ebenaceae Diospyros austro -africana var. austro -africana LC Boraginaceae Trichodesma africanum LC Fabaceae Lessertia frutescens subsp. frutescens LC Loranthaceae Septulina glauca LC Colchicaceae Colchicum burkei LC Cyperaceae Pseudoschoenus inanis LC Asteraceae Amellus tridactylus subsp. olivaceus LC Fabaceae Listia heterophylla LC Celastraceae Gymnosporia buxifolia LC Asteraceae Arctotis leiocarpa LC Scrophulariaceae Selago geniculata LC Aspleniaceae Asplenium cordatum LC Asteraceae Leysera gnaphalodes LC Asphodelaceae Astroloba congesta LC Cyperaceae Cyperus laevigatus LC Caryophyllaceae Silene undulata subsp. undulata LC Aizoaceae Drosanthemum subcompressum LC Zygophyllaceae Tetraena microcarpa Crassulaceae Crassula garibina subsp. glabra LC Euphorbiaceae Euphorbia clavarioides LC Poaceae Ehrharta delicatula LC Asteraceae Berkheya sp. Asteraceae Macledium spinosum LC Asteraceae Cineraria lobata subsp. lasiocaulis LC Pteridaceae Cheilanthes induta LC Gentianaceae Chironia palustris subsp. palustris LC Caryophyllaceae Silene burchellii subsp. pilosellifolia Apiaceae Conium chaerophylloides LC Hyacinthaceae Albuca virens subsp. arida LC Asparagaceae Asparagus suaveolens LC Urticaceae Forsskaolea candida LC Fabaceae Aspalathus aciphylla LC Brassicaceae Heliophila trifurca LC Asteraceae Helichrysum rosum var. arcuatum LC Asteraceae Eriocephalus decussatus LC Salicaceae Salix mucronata subsp. mucronata LC Asteraceae Berkheya spinosissima subsp. spinosissima LC Apocynaceae Carissa bispinosa LC Brassicaceae Lepidium desertorum LC Aizoaceae Mestoklema arboriforme LC Poaceae Tetrachne dregei LC

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Caryophyllaceae Dianthus micropetalus LC Fabaceae Indigofera heterophylla LC Poaceae Digitaria eriantha LC Ranunculaceae Ranunculus multifidus LC Malvaceae Malva parviflora var. parviflora Apiaceae Apium graveolens Hyacinthaceae Ledebouria revoluta LC Alliaceae Tulbaghia leucantha LC Colchicaceae Ornithoglossum undulatum LC Bignoniaceae Rhigozum trichotomum LC Gisekiaceae Gisekia pharnaceoides var. pharnaceoides LC Poaceae Agrostis lachnantha var. lachnantha LC Brassicaceae Heliophila crithmifolia LC Asteraceae Pteronia glaucescens LC Asteraceae Euryops abrotanifolius LC Fabaceae Lotononis falcata LC Poaceae Pentameris aristifolia LC Euphorbiaceae Euphorbia mauritanica LC Amaranthaceae Sericocoma avolans LC Asteraceae Hertia cluytiifolia LC Potamogetonaceae Potamogeton pusillus LC Euphorbiaceae Ricinus communis var. communis NE Fabaceae Indigastrum niveum Malvaceae Hermannia spinosa LC Cyperaceae Cyperus usitatus LC Solanaceae Solanum tomentosum Lamiaceae Ballota africana LC Pteridaceae Cheilanthes eckloniana LC Malvaceae Hermannia abrotanoides LC Asteraceae Senecio pinnulatus LC Malvaceae Radyera urens LC Salicaceae Populus nigra var. italica Aizoaceae Drosanthemum hispidum LC Aizoaceae Mesembryanthemum nodiflorum LC Poaceae Polypogon monspeliensis NE Malvaceae Hermannia althaeifolia LC Apiaceae Heteromorpha arborescens var. arborescens LC Poaceae Lolium perenne NE Crassulaceae Crassula corallina subsp. macrorrhiza LC Asphodelaceae Haworthia semiviva LC Apiaceae Chamarea longipedicellata LC Malvaceae Hermannia pulverata LC Lamiaceae Mentha longifolia subsp. capensis LC Colchicaceae Colchicum asteroides LC Iridaceae Moraea ciliata LC Poaceae Panicum sp. Rosaceae Rubus ludwigii subsp. ludwigii LC Hyacinthaceae Dipcadi viride LC

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Hyacinthaceae Drimia intricata LC Pteridaceae Adiantum capillus-veneris LC Aizoaceae Trichodiadema densum LC Asteraceae Centaurea melitensis Malvaceae Hermannia linearifolia LC Aizoaceae Plinthus cryptocarpus LC Poaceae Setaria verticillata LC Geraniaceae Pelargonium articulatum LC Scrophulariaceae Jamesbrittenia atropurpurea subsp. atropurpurea LC Fabaceae Lotononis caerulescens LC Asteraceae Pteronia glauca LC Poaceae Heteropogon contortus LC Amaranthaceae Amaranthus deflexus Zygophyllaceae Tribulus terrestris LC Fabaceae Medicago sativa NE Ebenaceae Diospyros austro-africana var. microphylla LC Geraniaceae Monsonia salmoniflora LC Rubiaceae Galium capense subsp. capense LC Scrophulariaceae Jamesbrittenia atropurpurea Scrophulariaceae Selago divaricata LC Asteraceae Pteronia paniculata LC Santalaceae Viscum rotundifolium LC Aizoaceae Mesembryanthemum emarcidum Lamiaceae Teucrium trifidum LC Hyacinthaceae Albuca sp. Hyacinthaceae Drimia platyphylla LC Asteraceae Caputia tomentosa LC Asteraceae Othonna pavonia LC Asteraceae Senecio niveus LC Scrophulariaceae Nemesia linearis LC Oleaceae Menodora juncea LC Aizoaceae Chasmatophyllum maninum DD Scrophulariaceae Aptosimum indivisum LC Apocynaceae Stapelia grandiflora var. grandiflora LC Colchicaceae Colchicum albomarginatum LC Crassulaceae Cotyledon papillaris LC Asphodelaceae Bulbine frutescens LC Ebenaceae Euclea crispa subsp. ovata LC Asteraceae Cotula coronopifolia LC Fabaceae Lotononis rabenaviana LC Asteraceae Pentzia sp. Poaceae Sporobolus fourcadii LC Aizoaceae Plinthus karooicus LC Apocynaceae Gomphocarpus fruticosus subsp. fruticosus LC Aizoaceae Trichodiadema setuliferum LC Asteraceae Cichorium intybus subsp. intybus Colchicaceae Colchicum striatum LC Thymelaeaceae Gnidia meyeri LC

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Asteraceae Pteronia viscosa LC Scrophulariaceae Chaenostoma rotundifolium LC Cyperaceae Fuirena coerulescens LC Geraniaceae Pelargonium odoratissimum LC Amaranthaceae Atriplex vestita var. appendiculata LC Poaceae Setaria sphacelata var. torta LC Poaceae Lolium multiflorum NE Euphorbiaceae Euphorbia cylindrica LC Malvaceae Hermannia comosa LC Asteraceae Felicia rogersii LC Aizoaceae Drosanthemum archeri LC Asphodelaceae Gonialoe variegata LC Limeaceae Limeum aethiopicum var. aethiopicum NE Crassulaceae Crassula muscosa var. muscosa NE Scrophulariaceae Gomphostigma incomptum LC Oxalidaceae Oxalis psilopoda LC Poaceae Aristida adscensionis LC Asteraceae Eriocephalus spinescens LC Aizoaceae Mesembryanthemum crystallinum LC Poaceae Cymbopogon nardus LC Boraginaceae Lappula heteracantha Crassulaceae Crassula deltoidea LC Geraniaceae Pelargonium multicaule subsp. multicaule LC Ranunculaceae Ranunculus trichophyllus LC Aizoaceae Stomatium villetii LC Malvaceae Hermannia bicolor LC Lamiaceae Salvia verbenaca LC Hypoxidaceae Empodium elongatum LC Cucurbitaceae Cucumis myriocarpus subsp. leptodermis LC Asteraceae Rhynchopsidium sessiliflorum LC Urticaceae Urtica dioica Hyacinthaceae Albuca glandulosa LC Cyperaceae Isolepis karroica LC Crassulaceae Cotyledon orbiculata var. oblonga LC Aizoaceae Galenia squamulosa LC Polygalaceae Polygala ericaefolia LC Polygalaceae Polygala asbestina LC Aizoaceae Drosanthemum sp. Asteraceae Pteronia glomerata LC Asteraceae Osteospermum microphyllum LC Asteraceae Eriocephalus sp. Santalaceae Viscum continuum LC Ditrichaceae Ceratodon purpureus subsp. stenocarpus Cucurbitaceae Citrullus lanatus LC Asteraceae Lasiopogon muscoides LC Poaceae Paspalum dilatatum NE Asteraceae Dicoma capensis LC Poaceae Cynodon incompletus LC

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Scrophulariaceae Zaluzianskya venusta LC Poaceae Brachypodium bolusii LC Fabaceae Lessertia annularis LC Poaceae Leptochloa fusca LC Caryophyllaceae Cerastium capense LC Asphodelaceae Haworthia marumiana var. marumiana NE Caryophyllaceae Silene undulata Lobeliaceae Lobelia dregeana LC Poaceae Oropetium capense LC Asteraceae Eumorphia corymbosa LC

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10 ANNEX 2. LIST OF MAMMALS

List of mammals which are likely to occur in the broad vicinity of the Nuweveld WEF study area. Records are based on the MammalMap Database from the ADU (http://mammalmap.adu.org.za), while conservation status is from the IUCN Red Lists 2016. Species in bold are those confirmed present or observed at the site.

Family Scientific name Common name Red list Records

Bathyergidae Cryptomys hottentotus Southern African Mole-rat Least Concern 3 Bovidae Antidorcas marsupialis Springbok Least Concern 978 Bovidae Oreotragus oreotragus Klipspringer Least Concern 503 Bovidae Pelea capreolus Vaal Rhebok Near Threatened 357 Bovidae Raphicerus campestris Steenbok Least Concern 76 Bovidae Redunca fulvorufula Mountain Reedbuck Near Threatened 91 Bovidae Sylvicapra capra Common Duiker Least Concern 18 Bovidae Tragelaphus strepsiceros Greater Kudu Least Concern 624 Canidae Canis mesomelas Black-backed Jackal Least Concern 51 Canidae Otocyon megalotis Bat-eared Fox Least Concern 12 Canidae Vulpes chama Cape Fox Least Concern 4 Cercopithecidae Chlorocebus pygerythrus Vervet Monkey Least Concern 1 Cercopithecidae Papio ursinus Chacma Baboon Least Concern 57 Chrysochloridae Chlorotalpa sclateri Sclater's Golden Mole Least Concern 14 Felidae Caracal caracal Caracal Least Concern 2 Felidae Felis nigripes Black-footed Cat Vulnerable 17 Felidae Felis silvestris Wildcat Least Concern 3 Spectacled African Gliridae Graphiurus ocularis Least Concern 1 Dormouse Herpestidae Atilax paludinosus Marsh Mongoose Least Concern 2 Herpestidae Cynictis penicillata Yellow Mongoose Least Concern 6 Herpestidae Herpestes pulverulentus Cape Gray Mongoose Least Concern 7 Herpestidae Suricata suricatta Meerkat Least Concern 5 Hyaenidae Hyaena brunnea Brown Hyena Near Threatened 2 Hyaenidae Proteles cristata Aardwolf Least Concern 4 Hystricidae Hystrix africaeaustralis Cape Porcupine Least Concern 4 Leporidae Bunolagus monticularis Riverine Rabbit Critically Endangered 11 Leporidae Lepus capensis Cape Hare Least Concern 2 Leporidae Lepus saxatilis Scrub Hare Least Concern 3 Macroscelides Macroscelididae Short-eared Elephant Shrew Least Concern 6 proboscideus Muridae Aethomys granti Grant's Rock Mouse Least Concern 2 Muridae Aethomys namaquensis Namaqua Rock Mouse Least Concern 29

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Muridae Desmodillus auricularis Cape Short-tailed Gerbil Least Concern 2 Muridae Gerbilliscus paeba Paeba Hairy-footed Gerbil Least Concern 13 Muridae Mastomys coucha Southern African Mastomys Least Concern 1 Muridae Mastomys natalensis Natal Mastomys Least Concern 6 Muridae Otomys unisulcatus Karoo Bush Rat Least Concern 12 Muridae Parotomys brantsii Brants's Whistling Rat Least Concern 2 Muridae Rhabdomys pumilio Xeric Four-striped Grass Rat Least Concern 51 Mustelidae Ictonyx striatus Striped Polecat Least Concern 3 Mustelidae Mellivora capensis Honey Badger Least Concern 3 Large -eared African Desert Nesomyidae Malacothrix typica Least Concern 2 Mouse Nesomyidae Petromyscus collinus Pygmy Rock Mouse Least Concern 2 Southern African Pouched Nesomyidae Saccostomus campestris Least Concern 15 Mouse Orycteropodidae Orycteropus afer Aardvark Least Concern 3 Procaviidae Procavia capensis Cape Rock Hyrax Least Concern 13 South African Ground Sciuridae Xerus inauris Least Concern 1 Squirrel Soricidae Myosorex varius Forest Shrew Least Concern 13 Viverridae Genetta genetta Common Genet Least Concern 2

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11 ANNEX 3. SUPPLEMENTARY HERPETOFAUNA STUDY BY SUNGAZER FAUNAL SURVEYS

NUWEVELD WIND FARMS: A herpetofaunal synopsis

Environmental consultant : Zutari South Africa

Client : Red Cap Energy Report compiled by : Marius Burger, trading as Sungazer Faunal Surveys Postal address: 6 Putter Street, Lakeside 7945 Phone: 083 231 7452 Email: [email protected]

Version 1: September 2020

Figure 1: An adult Karoo Girdled Lizard ( Karusasaurus polyzonus ) observed within the Nuweveld Wind Farms study area (see details in: https://www.inaturalist.org/observations/57006449 ). Its IUCN Red List status = Least Concern.

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Contents

1 ABBREVIATIONS ------99

2 EXECUTIVE SUMMARY ------100

3 INTRODUCTION AND STUDY AREA ------102

4 TERMS OF REFERENCE ------102

5 STUDY APPROACH AND METHODS ------103 5.1 Site visits ------103 5.2 Site visit limitations ------103 5.3 Other relevant studies ------103 5.4 Species checklists ------103 5.5 Species of conservation concern (SCC) ------104

6 RESULTS: GENERAL SITE DESCRIPTION AND HABITAT DIVERSITY ------104

7 RESULTS: REPTILE AND AMPHIBIAN LOCALITY RECORDS ------109

8 RESULTS: CHECKLISTS AND SPECIES OF CONSERVATION CONCERN ------111 8.1 Reptile species richness ------111 8.2 Reptile endemism ------111 8.3 Reptile species of conservation concern ------112 8.4 Amphibian species richness ------117 8.5 Amphibian endemism ------117 8.6 Amphibian species of conservation concern ------117

9 CONCLUSIONS AND RECOMMENDATIONS ------119 9.1 Herpetofaunal species richness, endemism and conservation status ------119 9.2 Recommendations in the context of the Nuweveld Wind Farms project ------120 9.3 In conclusion ------120

10 REFERENCES ------121

11 APPENDIX 1: OBSERVATIONS OF THE 2020 SURVEY ------123

12 APPENDIX 2: TAXONOMIC NOTES AND INTRODUCED SPECIES ------124

13 APPENDIX 3: DECLARATION OF INDEPENDENCE ------127

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ABBREVIATIONS

ADU Animal Demography Unit CBA Critical Biodiversity Areas EN Endangered IUCN International Union for Conservation of Nature LC Least Concern NC Northern Cape NE Not Evaluated NFEPA National Freshwater Ecosystem Priority Areas NT Near Threatened SA Southern Africa (including South Africa, Eswatini and Lesotho) SANBI South African Biodiversity Institute SAFAP South African Frog Atlas Project SARCA Southern African Reptile Conservation Assessment SCC Species of conservation concern WEF Wind Energy Facility

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EXECUTIVE SUMMARY

Introduction The following report is in the context of a development proposal by Red Cap Energy to erect three wind farms in the Nuweveld region about 65 km north of Beaufort West. The EIA process is being managed by Zutari South Africa , with Simon Todd of 3Foxes Biodiversity Solutions conducting the terrestrial biodiversity studies. The results of the various field surveys were written up as three separate fauna and flora specialist impact assessment reports (Todd 2020a-c). It was subsequently decided to expand on Todd’s herpetofaunal assessments by appointing a herpetologist (Marius Burger, trading as Sungazer Faunal Surveys ) to provide additional insights. This was done as a precautionary measure due to the occurrence of a few regional range-restricted reptile species that occur in the general region of the proposed development site.

Terms of reference The general aims of this supplementary herpetofaunal assessment were as follow: • Visit the site to assess the geography and habitat diversity in the context of the herpetofaunal communities that may be present there. • Compile a synopsis to integrate the information obtained during the site visit and from other resources (e.g. databases, literature). The emphasis of the herpetofaunal synopsis will be on species presence/absence checklists, habitat associations, species of conservation concern and levels of endemism.

Study approach The site was visited over a period of two days (18 & 19 August 2020), accompanied by Todd who pointed out the most pertinent habitat features. Active searching was conducted at a number of sites. The bulk of the species presence/absence information was obtained by means of literature and electronic database sources.

Habitat diversity The Nuweveld Wind Farms study area is a combination of karroid plains and valleys, rock outcrops, drainage lines and seasonal water courses and pans. These varied botanical, geological and wetland attributes make for a landscape which is diverse in habitat types that in turn supports a diverse reptile fauna.

Reptiles A total of about 63 reptile species are known from the general region and may potentially occur within the Nuweveld Wind Farms study area, with the occurrence of 14 of these having been confirmed from the site itself. This is a relatively high reptile species richness compared to other regions of the Karoo. Almost half of the reptile species in this region are either entirely endemic to South Africa (including Lesotho and Eswatini), or they are near-endemics. One species, i.e. Braack’s Pygmy Gecko is a Western Cape endemic with an extremely restricted distribution range. Most of its distribution is associated with a section of the Nuweveld Mountains range within the Karoo National Park. It is not currently known from the Nuweveld Wind Farms study area, but it may possible occur there. It is not a Red List species. The conservation status 62 of the 63 reptile species are listed as being of Least Concern. The only Red List species is the Karoo Padloper which is Endangered. Although not yet recorded from the study area, it is likely to occur there.

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Amphibians A total of about 11 amphibian species are known from the general region and may potentially occur within the Nuweveld Wind Farms study area, with the occurrence of three of these having been confirmed from the site itself. As is to be expected for an arid region, the amphibian species richness is rather low when compared to the subtropical regions of South Africa. About half (6 of 11 = 55%) of the amphibian species in this region are southern African endemics or near-endemics. There are no provincial endemics, but the distribution of the Karoo Caco is mostly restricted to the Western Cape and Northern Cape provinces. The conservation status of all 11 amphibian species are listed as being of Least Concern.

Conclusions Due to the presence of only one Red List reptile species in this region, the herpetofauna of the study area does not present significant constraints in the context of the proposed Nuweveld Wind Farms development intentions. The overall environmental impact of this project can be adequately mitigated to be of minimal significance to the resident herpetofaunal communities. Turbine positions and other development footprints must not overlap with or impact on the most important and most sensitive habitats in the landscape, i.e. avoid placements in wetlands (of any type), prominent rocky outcrops, rock pavements and escarpment areas. Use instead, as far as is generally feasible, habitats and areas that are well represented in the landscape, e.g. extensive sandy plains or gravel or rock-strewn plains with karroid shrubs. This would equate to a low impact scenario that will not significantly hamper the long-term ecological viability of the local herpetofaunal communities. The above considerations generally mirror the findings and recommendations (including associated sensitivity mapping) that were expressed in the terrestrial biodiversity reports (Todd 2020a-c).

Based on the findings of the Todd (2020) reports plus that of the current synopsis, the herpetofauna of the study area does not present significant constraints in the context of the proposed Nuweveld Wind Farms development intentions.

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11.1 INTRODUCTION AND STUDY AREA

The Nuweveld Wind Farms study area is situated about 65 km north of Beaufort West in the Western Cape Province (Figure 2). The site is about 35,000 ha in extent and is earmarked for the development of three Wind Energy Facilities (WEF). The EIA process is being managed by Zutari South Africa , for the developer Red Cap Energy . Simon Todd of 3Foxes Biodiversity Solutions was appointed to conduct the terrestrial biodiversity studies. In doing this he has visited the site on four occasions during 2019/20 to survey the vegetation and faunal communities, the results of which were written up as three separate specialist impact assessment reports (Todd 2020a-c). It was subsequently decided to expand on the reptile and amphibian components of these reports, to obtain a more comprehensive impression of the herpetofauna in the context of the proposed Nuweveld Wind Farms project. This was done as a precautionary measure because of the occurrence of a few regional range-restricted reptile species that is known from the general region. A herpetologist (Marius Burger, trading as Sungazer Faunal Surveys ) was appointed in August 2020 to visit the site with Todd. The following report provides a herpetofaunal synopsis of this survey results, including data gleaned from other sources.

Figure 2: The approximate location of the Nuweveld Wind Farms study area (black polygon) in relation to the general region. The southern boundary of the site is about 50 km north of Beaufort West.

11.2 TERMS OF REFERENCE

The general aims of the supplementary herpetofaunal assessment were as follow: • Visit the site to check on the geography and general habitat diversity of the site, so that inferences and projections can be made regarding the potential herpetofaunal communities that may be present there. • Compile a synopsis to integrate the information obtained during the site visit and from other sources (e.g. databases, literature). The emphasis of the herpetofaunal synopsis will be on species presence/absence checklists, habitat associations, species of conservation concern and endemicity, so that the site can be evaluated in terms of its importance for this faunal group. This synopsis will

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not include an impact assessment component, but potential issues in this regard will be pointed out and this study will be used by Todd to undertake the impact assessment component.

11.3 STUDY APPROACH AND METHODS

Site visits The Nuweveld Wind Farms study area was visited over a period of two days (18 & 19 August 2020), accompanied by Todd who pointed out the most pertinent habitat features and sensitive areas. The area was explored along some of the roads to gain an overall impression of the habitat diversity. Active searches for reptiles and amphibians were conducted at a number of sites (see Figure 12).

Site visit limitations • The August 2020 survey period of two days is too short to conduct a detailed herpetofaunal baseline study. However, the main aim of this supplementary survey was for the herpetologist to familiarise himself with the habitat features of the site, so that inferences can be made regarding the species of reptiles and amphibians that may potentially occur there. In this sense the site visit duration was adequate and no additional surveying is deemed necessary. • August is not a good time of the year herpetofaunal surveys in this region. It is generally too dry and thus this period does not coincide with the peak of frog breeding activities, and it is generally rather cold and thus not favourable for observing reptile activity. Nevertheless, some non-breeding frog observations were made, and the two survey days were sunny and warm enough for some of the diurnal lizards to be observed. Once again, the primary aim of the August 2020 survey was to assess the habitat diversity in the context of the herpetofauna that may potentially occur in this area. The ample literature and database sources of various other herpetofaunal surveys in the region are sufficient to make near accurate predictions (>90% accuracy) of the species composition for the Nuweveld Wind Farms site.

Other relevant studies The bulk of the species presence/absence information was obtained by means of literature and electronic database sources, and from the records obtained during the 2019/20 terrestrial biodiversity studies (Todd 2020a-c). An important new data source is the Karoo BioGaps Project that provided about 1800 records of reptiles and amphibians from various Karoo localities that were surveyed during the period 2016 to 2019 (see Figures 14 and 15).

Species checklists The various site visits (i.e. Todd 2019/20 and the August 2020 survey) provided a number of records for confirmed species occurrence. These were then supplemented with records obtained from literature, database or other data sources in order to compile more comprehensive species checklists. The bulk of the species records from the Nuweveld Wind Farms study area were obtained from the following sources:

• Various published literature and unpublished reports (see the References section). • ReptileMAP: http://vmus.adu.org.za/ . An online data source of the FitzPatrick Institute of African Ornithology (previously ADU).

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• FrogMAP: http://vmus.adu.org.za/ : http://vmus.adu.org.za/ . An online data source of the FitzPatrick Institute of African Ornithology (previously ADU). • iNaturalist: https://www.inaturalist.org/home . An online data source (see Figure 13). • SANBI: Karoo BioGaps Project: https://www.sanbi.org/karoo-biogaps-project/ . A dataset of records from Karoo localities that were surveyed during 2016 to 2019. The survey results of this project is not yet in the public domain (see Figures 14 and 15). • SANBI: A re-assessment of the conservation status of southern African reptiles: This is a project that is currently in progress. It is based on a dataset of about 190,000 reptile records which include data from several of the most important museum collections and a wide variety of transcribed literature records. A subset of this data was extracted (scrutinised and cleaned) for the Nuweveld Wind Farms project (see Figures 14 and 15).

The species checklists for reptiles and amphibians are presented in Tables 1 and 2. These refer to binomial taxa only, with instances of subspecies and various taxonomic changes being summarised in Appendix 2. The likelihood of species occurrence were scored as follow: Possible occurrence (1), probable occurrence (2) and confirmed occurrence (3). The confirmed occurrence records were obtained during the four 2019/20 terrestrial biodiversity surveys (Todd 2020a-c) and the August 2020 survey (Appendix 1, Table 3).

Species of conservation concern (SCC) The most relevant source for species conservation status is the IUCN Red List of Threatened Species (http://www.iucnredlist.org/ ), as per the most recent updates. It is the most appropriate and up to date source for the conservation status of South African amphibians. However, the IUCN database is not yet up to date for South African reptiles, with many species currently remaining as Not Evaluated (NE). For such species the listings of SARCA (Southern African Reptile Conservation Assessment; Bates et al. 2014) are used to tentatively fill the gaps where global IUCN assessments are currently lacking. The relevant IUCN categories of threat are as follow: • Extinct (EX) – No known individuals remaining. • Extinct in the Wild (EW) – Known only to survive in captivity, or as a naturalised population outside its historic range. • Critically Endangered (CR) – Extremely high risk of becoming extinct in the wild. • Endangered (EN) – Very high risk of becoming extinct in the wild. • Vulnerable (VU) – High risk of becoming extinct in the wild. • Near Threatened (NT) – Likely to become threatened in the near future. • Least Concern (LC) – Does not qualify for a category of threat. Widespread and abundant taxa are included in this category. • Data Deficient (DD) – Not enough data to make an assessment of its risk of extinction. • Not Evaluated (NE) – Has not yet been evaluated against the IUCN criteria.

11.4 RESULTS : GENERAL SITE DESCRIPTION AND HABITAT DIVERSITY

The terrestrial biodiversity studies reports (Todd 202a-c) that were compiled for the Nuweveld Wind Farms project included sections that described the site’s geology, wetlands, and vegetation and plant communities. It also provided details on the representation of Critical Biodiversity Areas (CBA), National Freshwater Ecosystem Priority Areas (NFEPA), and a description of broad-scaled processes within the

Nuweveld North WEF – Fauna & Flora Specialist Scoping Study 104 study area. These descriptions and assessments are not repeated here in the herpetofaunal synopsis, other than making brief references to the most important aspects.

From a herpetofaunal perspective, the Nuweveld Wind Farms study area has the following generalised features that influence reptile and amphibian diversity and composition: • Climate: It is an arid region, with annual rainfall ranging from <100 to about 500 mm (average about 245 mm). Rainfall is predominantly during summer months. In general terms it is a warm region that is favourable to reptiles. Temperatures can reach highs of almost 40°C on summer days, but the region can also receive snow during the winter. • Vegetation: The area is characterised by karroid vegetation (i.e. low shrubs and grasses; Figure 7), with the primary groups being categorised as Eastern Upper Karoo and Upper Karoo Hardeveld (for more details consult the Todd 2020a-c reports). Due to the almost complete lack of indigenous trees, arboreal species (e.g. Boomslang) are generally absent from the region. One exception is the Eastern Cape Dwarf chameleon that sometimes frequents bush-clumps or large karroid shrubs. • Geology: Many reptiles are substrate specialists, and some are specifically associated with soft or sandy substrates (fossorial and terrestrial species), gravel plains (terrestrial species), or rocky outcrops (rupicolous species). The prevalence of significant rock features, e.g. dolerite (Figure 5), sandstone and mudstone (shale; Figure 6) outcrops in this region has had an important influence on shaping the reptile species richness that is currently present here. Whereas the karroid plains provide the bulk of the terrestrial habitat, the rocky outcrops make provision for rupicolous species. These outcrops are in the landscape are like mini-inselbergs that accommodates species that would otherwise have been absent from here. Valleys with differing solar aspects and altitudinal ranges also add to the mosaic of environmental parameters that influence the distribution and stratification of the herpetofauna. • Wetlands: Watercourses and drainage lines within the karroid landscape serve as important wetland features for amphibians to use as breeding habitat (Figure 8). Most watercourses of the Nuweveld Wind Farms study area are dry for part of the year, but some do hold pools of water for most or all of the year (Figure 9). These pools serve as year-round habitat for species like Poynton’s River Frog and the aquatic African Clawed Frog (aka Common Platanna). Several endorheic (without outflow) pans are present within the Nuweveld Wind Farms study area (Figure 10). The pans were completely dry during the August 2020 survey, but it is possible that some of these might be utilised by Giant Bull Frogs during seasons with good rainfall. The watercourses and pans are also utilised by terrapins when these are seasonally flooded.

Figure 3: Terrestrial reptile species are also Figure 4: Rock pavements provide habitat for influenced by substrate variation, with species specialised plant species such as associated dwarf

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composition differences being evident between succulents and geophytes. Although no reptile sandy, gravel and rock-strewn plains. Fossorial species are specifically associated with these rock species are particular in their choice of substrate. pavements, several species utilise this terrain.

Figure 5: Dolerite outcrops are often inhabited by Figure 6: A shale (mudstone) outcrop provides a suite of rock-living reptiles, usually lizards but different conditions for rupicolous reptiles than also snakes. Some of these rupicolous reptiles are do dolerite formations, and thus certain species absolutely reliant on these rocky outcrops for will favour specific rock types. their occurrence within a particular landscape.

Figure 7: A landscape scene from within the Nuweveld Wind Farms study area. The mosaic of open sandy and gravel plains, rocky outcrops and valleys provides diverse habitat conditions that promotes a diverse reptile fauna. Many reptile species (especially lizards) are substrate specialists, and thus reptile species richness tends to be positively correlated with geological diversity.

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Figure 8 : Watercourses and drainage lines within the karroid landscape serve as important wetland features for amphibians to use as breeding habitat (dots show a mix of reptile and amphibian records).

Figure 9 : Most watercourses of the Nuweveld Wind Farms study area are dry for part of the year, but some do hold pools of water for most or all of the year.

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Figure 10 : Several endorheic pans are present within the Nuweveld Wind Farms study area. The pans were completely dry during the August 2020 survey (yellow dots mark reptile observation sightings and orange line is the route walked).

Figure 11 : One o f several endorheic pans within the Nuweveld Wind Farms study area. It is possible that some of these might be utilised by Giant Bull Frogs during seasons with good rainfall, but this is purely speculation at this stage.

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11.5 RESULTS : REPTILE AND AMPHIBIAN LOCALITY RECORDS

A total of only 16 reptile and amphibian observations were made during the two-day survey in August 2020 (Appendix 1, Table 3). These are comprised of five lizard and two frog species. The localities for this survey were plotted on a map (Figure 12). Some of these observations were submitted as iNaturalist photo records. Additional observations were made during the 2019/20 terrestrial biodiversity studies (Todd 2020a-c) and, although these were not plotted on the various maps, they were incorporated in the species checklists (Tables 1 and 2).

The bulk of the existing knowledge of the herpetofauna of the Nuweveld/Beaufort West region are contained in the various datasets that were consulted for this synopsis. Collectively these served as a voluminous database for projecting the potential reptile and amphibian species compositions of the Nuweveld Wind Farms study area. Records from iNaturalist that are specifically within the Karoo BioGaps Project study area were plotted on a map (Figure 13), and all the reptile and amphibian records of the combined datasets were plotted on two maps (Figures 14 and 15). These maps reflect the relatively good geographical coverage and species representation in this region, which formed the basis for this herpetofaunal synopsis.

Figure 12: Herpetofaunal records within a 25 km radius of the Nuweveld Wind Farms study area (black polygon). The red dots are a mix of reptile and amphibian records from the SANBI dataset and other data sources. The orange dots are reptile and amphibian records from the Karoo BioGaps Project dataset. The yellow dots are reptile and amphibian records of the August 2020 survey. Note that the reptile and amphibian records of Todd’s 2019/20 surveys are not plotted here. The orange tracks show the areas visited by Burger and Todd during the August 2020 survey.

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Figure 13: Reptile and amphibian records (orange squares) from iNaturalist that pertain specifically to the Karoo BioGaps Project study area, as per submissions made by the general public (aka citizen scientists). The records that were obtained specifically during the SANBI Karoo BioGaps Project field surveys are not plotted here (but see Figures 14 and 15). A cluster of records that corresponds with the Karoo National Park is evident to the west and north-west of Beaufort West.

Figure 14: Reptile records in th e general region of Beaufort West and the Nuweveld Wind Farms study area (black polygon). The red dots are reptile records from the SANBI reptile conservation status dataset. The orange dots are reptile records from the SANBI Karoo BioGaps Project dataset. The yellow dots are reptile records of the August 2020 survey. Note that the reptile records of Todd’s 2019/20 surveys are not plotted here.

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Figure 15: Amphibian records in the general region of Beaufort West and the Nuweveld Wind Farms study area (black polygon). The red dots are amphibian records from mixed datasets. The orange dots are amphibian records from the SANBI Karoo BioGaps Project dataset. The yellow dots are amphibian records of the August 2020 survey. Note that the amphibian records of Todd’s 2019/20 surveys are not plotted here.

11.6 RESULTS : CHECKLISTS AND SPECIES OF CONSERVATION CONCERN

Reptile species richness A checklist of reptiles that are known from or may potentially occur within the boundaries of the Nuweveld Wind Farms study area is presented in Table 1. A total of about 63 reptile species are known from the general region and may potentially occur within the study area, with 14 being of confirmed occurrence (Burger 2020; Todd 2020a-c), 45 of probable occurrence and four of possible occurrence. This is a relatively high reptile species richness (see Figure 17) compared to other regions of the Karoo. Part of the reason for this is the region’s striking geological (including altitudinal) diversity, and probably also to a certain extent because of sampling bias whereby researches tend to focus sampling efforts in exciting places like the Karoo National Park (e.g. Branch and Braack 1989).

Reptile endemism Almost half (30 of 63 = 48%) of the reptile species in this region are either entirely endemic to South Africa (including Lesotho and Eswatini), or they are near-SA endemics (90 +% of distribution is in SA). One species, i.e. Braack’s Pygmy Gecko ( Goggia braacki ) is a WC endemic with an extremely restricted distribution range. Most of its distribution is associated with a section of the Nuweveld Mountains range within the Karoo National Park (see Figure 16). It is not a threatened species, but it can perhaps be regarded as the reptile icon for the Nuweveld/Beaufort West region. It is not currently known from the Nuweveld Wind Farms study area, but it may possibly (not probably) occur there.

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Reptile species of conservation concern

Not Evaluated (NE): The conservation status of a substantial portion of southern African reptiles has yet to be officially assessed by the IUCN, and these are currently listed as NE. In terms of the potential reptile fauna of the Nuweveld Wind Farms study area, 26 of the 63 species are currently NE. Efforts are currently underway (by SANBI) to compile global IUCN Red List assessments for all southern African reptiles. In the meantime, the national SARCA listings (Bates et al. 2014) should serve as an interim measure of conservation status for these species. Least Concern (LC): 62 of the 63 Nuweveld Wind Farms study area reptile species are listed as being of LC, either as per the global IUCN (2020) listings or the SARCA (Bates et al. 2014) listings. Endangered (EN): Only one of the 63 Nuweveld Wind Farms study area reptile species is listed as threatened. This is the Karoo Padloper ( Chersobius boulengeri ) which is listed as EN (Figure 16). Although not yet recorded from the study area, it is likely to occur there.

Figure 16 : Records of three noteworthy species of reptiles in the context of the Nuweveld Wind Farms study area (black polygon). The Karoo Padloper ( Chersobius boulengeri ) is an Endangered species that may potentially occur within the study area. Cloete’s Girdled Lizard ( Cordylus cloetei ) is currently a range-restricted species, but a recent genetics study (in prep.) has revealed that it is actually a synonym of Cordylus minor . As such it actually has a much wider distribution and it is no longer of special significance other than being a WC endemic. Braack’s Pygmy Gecko ( Goggia braacki ) has a highly restricted distribution range (the blue dots show full extent of known records). Although this species was previously listed as being Near Threatened (Bates et al. 2014), its current IUCN Red List status is Least Concern. No records are known from within the Nuweveld Wind Farms study area, but its occurrence there is possible.

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Table 1: A checklist of reptiles that are known from or may potentially occur within the Nuweveld Wind Farms study area. Conservation status is according to global (IUCN 2020) and national (SA; Bates et al. 2014) listings. The following categories are relevant: Not Evaluated (NE), Least Concern (LC), Near Threatened (NT) and Endangered (EN). Levels of endemism are as follow: Endemic or near-endemic to South Africa, Lesotho and Swaziland (SA), or to the Western Cape (WC). Scoring for likelihood of occurrence: Possible occurrence (1), probable occurrence (2) and confirmed occurrence (3). The confirmed occurrence records were obtained during site visits by faunal specialist Simon Todd (2019/20) and herpetologist Marius Burger (2020). Scientific name Common name IUCN/SA Endemism Occur Notes on the probability of occurrence TESTUDINES Tortoises and terrapins Pelomedusidae Side-necked terrapins Pelomedusa galeata South African Helmeted Terrapin LC/NE SA 3 Confirmed occurrence: Todd 2020 Testudinidae Tortoises Chersina angulata Angulate Tortoise LC/LC Near-SA 3 Confirmed occurrence: Todd 2020 Chersobius boulengeri Karoo Padloper EN /NT SA 2 Known from the general region Homopus femoralis Greater Padloper LC/LC SA 3 Confirmed occurrence: ReptileMAP Psammobates tentorius Tent Tortoise LC/LC 0 3 Confirmed occurrence: Todd 2020; ReptileMAP Stigmochelys pardalis Leopard Tortoise LC/LC 0 3 Confirmed occurrence: Todd 2020; ReptileMAP SAURIA Lizards Agamidae Agamid lizards Agama aculeata Common Ground Agama NE/LC 0 3 Confirmed occurrence: Todd 2020 Agama atra Southern Rock Agama LC/LC Near-SA 3 Confirmed occurrence: Burger 2020; Todd 2020 Chamaeleonidae Chameleons Bradypodion ventrale Eastern Cape Dwarf Chameleon LC/LC SA 2 Known from the general region Chamaeleo namaquensis Namaqua Chameleon LC/LC 0 2 Known from the general region Cordylidae Cordylid lizards Cordylus cloetei Cloete’s Girdled Lizard LC/LC SA 2 Known from the general region Cordylus cordylus Cape Girdled Lizard LC/LC SA 2 Known from the general region Karusasaurus polyzonus Karoo Girdled Lizard LC/LC Near-SA 3 Confirmed occurrence: Burger 2020; Todd 2020 Pseudocordylus microlepidotus Cape Crag Lizard LC/LC SA 2 Known from the general region

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Table 1 (continued): Scientific name Common name IUCN/SA Endemism Occur Notes on the probability of occurrence Gekkonidae Geckos Chondrodactylus angulifer Giant Ground Gecko LC/LC 0 2 Known from the general region Chondrodactylus bibronii Bibron’s Gecko LC/LC 0 3 Confirmed occurrence: Burger 2020 Goggia braacki Braack’s Pygmy Gecko LC/ NT WC 1 Known from the general region Pachydactylus capensis Cape Gecko NE/LC 0 2 Known from the general region Pachydactylus geitje Ocellated Gecko LC/LC SA 2 Known from the general region Pachydactylus kladaroderma Thin-skinned Gecko LC/LC SA 2 Known from the general region Pachydactylus latirostris Quartz Gecko NE/LC 0 1 Known from the general region Pachydactylus maculatus Spotted Gecko LC/LC Near-SA 2 Known from the general region Pachydactylus mariquensis Common Banded Gecko NE/LC SA 2 Known from the general region Pachydactylus oculatus Golden Spotted Gecko LC/LC SA 2 Known from the general region Pachydactylus purcelli Purcell’s Gecko NE/LC 0 2 Known from the general region Ptenopus garrulus Spotted Barking Gecko NE/LC 0 2 Known from the general region Gerrhosauridae Plated lizards Cordylosaurus subtessellatus Dwarf Plated Lizard LC/LC 0 2 Known from the general region Gerrhosaurus typicus Karoo Plated Lizard LC/LC SA 2 Known from the general region Tetradactylus tetradactylus Cape Long-tailed Seps LC/LC SA 2 Known from the general region Lacertidae Lacertid lizards Meroles suborbitalis Spotted Desert Lizard NE/LC 0 2 Known from the general region Nucras livida Karoo Sandveld Lizard LC/LC SA 2 Known from the general region Pedioplanis burchelli Burchell's Sand Lizard LC/LC SA 2 Known from the general region Pedioplanis laticeps Karoo Sand Lizard LC/LC SA 2 Known from the general region Pedioplanis lineoocellata Common Sand Lizard NE/LC 0 3 Confirmed occurrence: Todd 2020 Pedioplanis namaquensis Namaqua Sand Lizard NE/LC 0 2 Known from the general region

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Table 1 (continued): Scientific name Common name IUCN/SA Endemism Occur Notes on the probability of occurrence Scincidae Skinks Acontias cf. lineatus Striped Legless Skink NE/LC 0 1 Known from the general region Acontias orientalis Eastern Cape Legless Skink LC/LC SA 2 Known from the general region Trachylepis capensis Cape Skink NE/LC 0 2 Confirmed occurrence: Todd 2020 Trachylepis homalocephala Red-sided Skink LC/LC SA 2 Known from the general region Trachylepis occidentalis Western Three-striped Skink NE/LC 0 2 Known from the general region Trachylepis sulcata Western Rock Skink NE/LC 0 3 Confirmed occurrence: Burger 2020; Todd 2020 Trachylepis variegata Variegated Rock Skink NE/LC 0 3 Confirmed occurrence: Burger 2020; Todd 2020 Varanidae Monitor Lizards Varanus albigularis Southern Rock Monitor NE/LC 0 3 Confirmed occurrence: Todd 2020 SERPENTES Snakes Typhlopidae Blind snakes Rhinotyphlops lalandei Delalande's Beaked Blind Snake NE/LC 0 2 Known from the general region Lamprophiidae Lamprophiid snakes Boaedon capensis Brown House Snake NE/LC 0 2 Known from the general region Duberria lutrix Common Slug-eater LC/LC SA 2 Known from the general region Homoroselaps lacteus Spotted Harlequin Snake LC/LC SA 1 Known from the general region Lamprophis aurora Aurora House Snake LC/LC SA 2 Known from the general region Lamprophis fiskii Fisk's House Snake LC/LC SA 2 Known from the general region Lamprophis guttatus Spotted Rock Snake LC/LC Near-SA 2 Known from the general region Prosymna sundevallii Sundevall's Shovel-snout LC/LC Near-SA 2 Known from the general region Psammophis crucifer Cross-marked Grass Snake LC/LC 0 2 Known from the general region Psammophis notostictus Karoo Whip Snake NE/LC 0 2 Known from the general region Psammophylax rhombeatus Spotted Skaapsteker NE/LC 0 2 Known from the general region Pseudaspis cana Mole Snake NE/LC 0 2 Known from the general region

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Table 1 (continued): Scientific name Common name IUCN/SA Endemism Occur Notes on the probability of occurrence Colubridae Colubrid snakes Crotaphopeltis hotamboeia Herald Snake NE/LC 0 2 Known from the general region Dasypeltis scabra Rhombic Egg-eater NE/LC 0 2 Known from the general region Dipsina multimaculata Dwarf Beaked Snake LC/LC 0 2 Known from the general region Elapidae Cobras, mambas & allies Aspidelaps lubricus Coral Shield Cobra NE/LC 0 2 Known from the general region Hemachatus haemachatus Rinkhals LC/LC SA 2 Known from the general region Naja nivea Cape Cobra NE/LC 0 2 Known from the general region Viperidae Adders & vipers Bitis arietans Puff Adder NE/LC 0 3 Confirmed occurrence: Todd 2020 Bitis caudalis Horned Adder NE/LC 0 2 Known from the general region

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Amphibian species richness A checklist of amphibians that are known from or may potentially occur within the boundaries of the Nuweveld Wind Farms study area is presented in Table 2. A total of about 11 amphibian species are known from the general region and may potentially occur within the study area, with three being of confirmed occurrence (Burger 2020; Todd 2020a-c), seven of probable occurrence and one of possible occurrence. As is to be expected for an arid region, the amphibian species richness is rather low when compared to the subtropical regions of SA where >50 frog species may occur within a 25 km radius (see Figure 17).

Amphibian endemism About half (6 of 11 = 55%) of the amphibian species in this region are either entirely endemic to South Africa (including Lesotho and Eswatini), or they are near-SA endemics (90 +% of distribution is in SA). There are no provincial endemics, but the distribution of the Karoo Caco ( Cacosternum karooicum ) is mostly restricted to the WC with a slight overlap into the NC.

Amphibian species of conservation concern Least Concern (LC): All 11 of the amphibian species that may potentially occur within the Nuweveld Wind Farms study are listed as being of LC (IUCN 2020). The Giant Bull Frog ( Pyxicephalus adspersus ) used to be listed as Near Threatened (NT; Minter et al. 2005), but its conservation status was subsequently re- assessed and it is now listed as being of LC (IUCN 2020).

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Table 2: A checklist of amphibians that are known from or may potentially occur within the Nuweveld Wind Farms study area. Conservation status is according to the global IUCN 2020 listing. The following categories are relevant: Least Concern (LC). Levels of endemism are as follow: Endemic or near-endemic to South Africa, Lesotho and Swaziland (SA), or to the Western Cape (WC). Scoring for likelihood of occurrence: Possible occurrence (1), probable occurrence (2) and confirmed occurrence (3). The confirmed occurrence records were obtained during site visits by faunal specialist Simon Todd (2019/20) and herpetologist Marius Burger (2020). Scientific name Common name SA Endemism Occur Notes on the probability of occurrence ANURA Frogs Bufonidae Toads Poyntonophrynus vertebralis Southern Pygmy Toad LC SA 2 Known from the general region Sclerophrys capensis Raucous Toad LC SA 2 Known from the general region Vandijkophrynus gariepensis Karoo Toad LC Near-SA 3 Confirmed occurrence: Burger 2020; Todd 2020 Hyperoliidae Reed frogs and relatives Kassina senegalensis Bubbling Kassina LC 0 1 Known from the general region Pipidae Pipid frogs Xenopus laevis African Clawed Frog LC 0 3 Confirmed occurrence: Todd 2020 Pyxicephalidae Pyxicephalid frogs Amietia poyntoni Poynton’s River Frog LC 0 3 Confirmed occurrence: Burger 2020; Todd 2020 Cacosternum boettgeri Common Caco LC 0 2 Known from the general region Cacosternum karooicum Karoo Caco LC SA 2 Known from the general region Pyxicephalus adspersus Giant Bull Frog LC 0 2 Known from the general region Strongylopus grayii Clicking Stream Frog LC SA 2 Known from the general region Tomopterna tandyi Tandy’s Sand Frog LC SA 2 Known from the general region

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11.7 CONCLUSIONS AND RECOMMENDATIONS

Herpetofaunal species richness, endemism and conservation status The Branch and Braack (1989) herpetofaunal assessment of the Karoo National Park used the following title: “ Reptiles and amphibians of the Karoo National Park: A surprising diversity ”. Indeed, the recorded reptile species richness of the Nuweveld/Beaufort West region is above average for the Great Karoo (see Figure 17), with about 63 species (Table 1) known from the region. The proportion of reptile endemism is impressive but normal for arid regions of South Africa, with 48% of the species being endemic or nearly endemic to southern Africa. One Western Cape endemic occurs here, i.e. Braack’s Pygmy Gecko that inhabits rocky terrain of the Nuweveld Mountains range within the Karoo National Park. The only threatened (Red List) reptile species in this region is the Karoo Padloper (EN). This small tortoise is seldom observed, even when specifically targeted during herpetofaunal surveys. They are associated with dolerite ridges and rocky outcrops of the southern Succulent and Nama Karoo biomes. Threats to this species include habitat degradation due to agricultural activities and overgrazing, and predation by the Pied Crows which in recent decades have expanded in distribution range.

In contrast to the relatively high reptile species richness, the recorded amphibian species richness is much lower. Only about 11 frog species are associated with this region (Table 2), but this is normal to slightly above average for arid areas of South Africa. About half (55%) of the amphibian species in this region are endemic or nearly endemic to southern Africa. None of the species are Red Listed (i.e. all are of LC).

Figure 17: A comparison of reptile (left) and amphibian (right) species richness maps showing a relatively high reptile richness in the region of the Karoo National Park (red circle). This is not typical for the Karoo in general. In contrast, the same area shows a low (but normal) frog species richness. Maps were generated from ReptileMAP and FrogMAP.

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Recommendations in the context of the Nuweveld Wind Farms project • The selection of turbine positions must be done so that these do not overlap with or impact on the most important and most sensitive habitats in the landscape, i.e. avoid placements in wetlands (of any type), prominent rocky outcrops, rock pavements and escarpment areas. Rather use, as far as is generally feasible, habitats and areas that are well represented in the landscape, e.g. extensive sandy plains or gravel or rock-strewn plains with karroid shrubs. Of these the sandy substrate habitat is the least sensitive and it is well represented in the landscape and thus it is the preferred terrain for WEF development footprints. The gravel and rock-strewn plains are more important (thus more sensitive), but these habitat types are rather abundant within the landscape and thus a degree of impact is deemed acceptable. The above considerations are the most important in the context of minimising negative impacts on herpetofaunal communities, and these generally mirror the findings and recommendations (including associated sensitivity mapping) that were expressed in the terrestrial biodiversity reports (Todd 2020a-c). • The above considerations should also be applied when constructing new roads and upgrading existing roads. The layout design of these routes must also target the more homogenous plains habitat and try to avoid the most sensitive habitat types and minimise the instances where drainage have to be crossed. Again, these considerations mirror the findings and recommendation that were expressed in the terrestrial biodiversity reports (Todd 2020a-c). • For the rest of impact mitigation measures, refer to the guidelines and recommendations for the faunal and botanical groups as per the terrestrial biodiversity reports (Todd 2020a-c).

In Conclusion The terrestrial biodiversity reports (Todd 2020a-c) that were compiled for the three proposed Nuweveld WEFs also included assessments of the reptile and amphibian communities of this region. The supplementary survey (August 2020) added a few more on-site records, and this herpetofaunal synopsis report incorporated significant data sources that allowed for a more thorough understanding of the region’s herpetofauna. Although the terms of reference for this synopsis do not include an impact assessment component, the synopsis does provide a more-than-adequate baseline for the assessment of the proposed WEF developments. In this regard I conclude that the environmental impacts that are associated with the three WEF development proposals are of low significance in terms of the long-term ecological viability of the existing herpetofaunal communities in this region. The main reasons for this are: • With the exception of the Karoo Padloper which is EN, the conservation status of all (73 of 74) other reptiles and amphibians is LC. • The study area is relatively large (± 35,000 ha). • The study area contains large areas of medium or low sensitivity terrain (as per Todd 20202-c) on which the development footprints can be concentrated. • The total proposed development footprint is very small (i.e. 1% of the total study area). • The terrestrial biodiversity reports (Todd 2020a-c) provide recommendations based on the mapping of sensitive zones, to guide the placement of development footprints. • These reports also include impact assessment components that provide mitigation measures to reduce or limit negative development impacts.

In conclusion: Based on the findings of the Todd (2020) reports plus that of the current synopsis, the herpetofauna of the study area does not present significant constraints in the context of the proposed Nuweveld Wind Farms development intentions.

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11.8 REFERENCES

Bates, M.F., Branch, W.R., Bauer, A.M., Burger, M., Marais, J., Alexander, G.J. and De Villiers, M.S. (eds). 2014. Atlas and Red List of the Reptiles of South Africa, Lesotho and Swaziland . Suricata 1. South African National Biodiversity Institute, Pretoria. Bauer, A.M. and Branch, W.R. 2003 [2001]. The herpetofauna of the Richtersveld National Park and the adjacent northern Richtersveld, Northern Cape Province, Republic of South Africa. Herpetological Natural History 8: 111–160. Bauer, A.M., Good, D.A. and Branch, W.R. 1997. The taxonomy of the Southern African leaf-toed geckos (Squamata: Gekkonidae), with a review of Old World Phyllodactylus and the description of five new genera. Proceedings of the California Academy of Sciences 49(14): 447–497. Boycott, R.C., De Villiers, A.L. and Scott, E. 2002. A new species of Cacosternum Boulenger, 1887 (Anura: Ranidae) from the Karoo region of South Africa. Journal of Herpetology 36(3): 333–341. Branch, W.R. and Braack, H.H. 1989. Reptiles and amphibians of the Karoo National Park: A surprising diversity. Journal of the Herpetological Association of Africa 36(1): 26–35. Branch, W.R. and Braack, H.H. 1990. Another reptile translocation to a national park. Koedoe 33(1): 112. Broadley, D.G. and Baldwin, A.S. 2006. Taxonomy, natural history, and zoogeography of the southern African Shield Cobras, Genus Aspidelaps (Serpentes: Elapidae). Herpetological Natural History 9(2): 163–176. Channing, A., Dehling, J.M., Lötters, S. and Ernst, R. 2016. Species boundaries and taxonomy of the African river frogs (Amphibia: Pyxicephalidae: Amietia ). Zootaxa 4155: 1–76. Edwards, S. 2013. Patterns and processes of adaptation in lacertid lizards to environments in southern Africa. Ph.D. dissertation, University of Stellenbosch, Stellenbosch. Edwards, S., Conradie, W., Kelly, C. and Greenbaum, E. 2019. Phylogenetic relationships in the slug- eater snakes, Duberria (Lamprophiidae). Abstract in: 14th Conference of the Herpetological Association of Africa, 9–13 September 2019. Cape St. Francis, Eastern Cape, South Africa. African Herp News 72: 59. Engelbrecht, H.M., Van Niekerk, A., Heideman, N.J.L. and Daniels, S.R. 2013. Tracking the impact of Pliocene/Pleistocene sea level and climatic oscillations on the cladogenesis of the Cape legless skink, Acontias meleagris species complex, in South Africa. Journal of Biogeography 40: 492–506. FitzSimons, V.F.M. 1935. Notes on a collection of reptiles and amphibians made in the southern Kalahari, Bushmanland and Great and Little Namaqualand. Annals of the Transvaal Museum 15: 519– 550. Fritz, U., Branch, W.R., Hofmeyr, M.D., Maran, J., Prokop, H., Schleicher, A., Široký, P., Stuckas, H., Vargas-Ramírez, M., Vences, M. and Hundsdörfer, A.K. 2011. Molecular phylogeny of African hinged and helmeted terrapins (Testudines: Pelomedusidae: Pelusios and Pelomedusa ). Zoologica Scripta 40: 115–125. Fritz, U., Kehlmaier, C., Mazuch, T., Hofmeyr, M.D., du Preez, L., Vamberger, M. and Vörös, J. 2015. Important new records of Pelomedusa species for South Africa and Ethiopia. Vertebrate Zoology 65: 383–389.

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Fritz, U., Petzold, A., Kehlmaier, C., Kindler, C., Campbell, P., Hofmeyr, M.D. and Branch, W.R. 2014. Disentangling the Pelomedusa complex using type specimens and historical DNA (Testudines: Pelomedusidae). Zootaxa 3795: 501–522. Good, D.A., Bauer, A.M. and Branch, W.R. 1996. A new species of Phyllodactylus (Squamata: Gekkonidae) from the Karoo National Park, South Africa. African Journal of Herpetology 45(2): 49–58. Hofmeyr, M.D., Vamberger, M., Branch, W.R. Schleicher, A. and Daniels, S.R. 2016. Tortoise (Reptilia, Testudinidae) radiations in Southern Africa from the Eocene to the present. Zoologica Scripta 46: 389– 400. Hofmeyr, M.D. and Branch, W.R. 2018. The padloper’s tortuous path (Chelonia: Testudinidae): Two genera, not one. African Journal of Herpetology 67(2): 99–112. Kulenkampff, K., Van Zyl, F., Klaus, S. and Daniels, S.R. 2019. Molecular evidence for cryptic species in the common slug eating snake Duberria lutrix lutrix (Squamata, Lamprophiidae) from South Africa. ZooKeys 838: 133–154. Minter L.R., Burger M., Harrison J.A., Braack H.H., Bishop P.J. and Kloepfer D., (eds). 2004. Atlas and Red Data Book of the Frogs of South Africa, Lesotho and Swaziland. SI/MAB Series #9. Smithsonian Institution, Washington, DC, 360 pp. Portik, D.[M.], Bauer, A.M. and Jackman, T.R. 2010. The phylogenetic affinities of Trachylepis sulcata nigra and the intraspecific evolution of coastal melanism in the western rock skink. African Zoology 45: 147–159. Portik, D.M., Bauer, A.M. and Jackman, T.R. 2011. Bridging the gap: western rock skinks ( Trachylepis sulcata ) have a short history in South Africa. Molecular Ecology 20: 1744–1758. Rebelo A.D., Bates M.F., Burger M., Branch W.R. and Conradie W. 2019. Range expansion of the Common Dwarf Gecko, Lygodactylus capensis : South Africa’s most successful reptile invader. Herpetology Notes 12: 643–650. Stanley, E.L., Bauer, A.M., Jackman, T.R., Branch, W.R. and Mouton P. Le Fras N. 2011. Between a rock and a hard polytomy: Rapid radiation in the rupicolous girdled lizard (Squamata: Cordylidae). Molecular Phylogenetics and Evolution 58(1): 53–70. Todd, S. 2020a. Fauna & flora specialist impact assessment: Nuweveld North Wind Energy Facility. 3Foxes Biodiversity Solutions report compiled for Zutari South Africa – April 2020. Todd, S. 2020b. Fauna & flora specialist impact assessment: Nuweveld West Wind Energy Facility. 3Foxes Biodiversity Solutions report compiled for Zutari South Africa – June 2020. Todd, S. 2020c. Fauna & flora specialist impact assessment: Nuweveld East Wind Energy Facility. 3Foxes Biodiversity Solutions report compiled for Zutari South Africa – June 2020. Vamberger, M., Hofmeyr, M.D., Ihlow, F. and Fritz, U. 12018. In quest of contact: phylogeography of helmeted terrapins ( Pelomedusa galeata , P. subrufa sensu stricto ). PeerJ 6:e4901. Vargas-Ramírez, M., Petzold A. and Fritz U. 2016. Distribution modelling and conservation assessment for helmeted terrapins ( Pelomedusa spp.). Salamandra 52: 306–316.

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11.9 APPENDIX 1: OBSERVATIONS OF THE 2020 SURVEY

Table 3: Details of the reptile and amphibian observations made during the August 2020 survey of the Nuweveld Wind Farms study area. English name Date Latitude Longitude iNaturalist Notes Poynton's River Frog 2020/08/18 -31.839871 22.369519 x1 adult & few tadpoles Bibron's Gecko 2020/08/18 -31.839372 22.368946 x1 adult in crack on rocky outcrop

Bibron's Gecko 2020/08/18 -31.839083 22.368222 https://www.inaturalist.org/observations/56881117 x5 adults in crack on rocky outcrop Karoo Toad 2020/08/18 -31.769939 22.450802 Dead tadpoles in dried pool in riverbed

Karoo Girdled Lizard 2020/08/19 -31.816722 22.470667 https://www.inaturalist.org/observations/57006449 x1 adult on rocks

Western Rock Skink 2020/08/19 -31.822389 22.465361 https://www.inaturalist.org/observations/57006658 x1 male and x1 female on rocks

Variegated Skink 2020/08/19 -31.824361 22.467056 https://www.inaturalist.org/observations/57006961 x1 adult on rocks Southern Rock Agama 2020/08/19 -31.823194 22.467333 x1 juvenile in rock crack Southern Rock Agama 2020/08/19 -31.822362 22.466498 x1 adult in rock crack Karoo Girdled Lizard 2020/08/19 -31.822029 22.466194 x2 adults in rock crack

Western Rock Skink 2020/08/19 -31.821111 22.464667 https://www.inaturalist.org/observations/57007629 x1 adult female on rocks

Western Rock Skink 2020/08/19 -31.818806 22.464639 https://www.inaturalist.org/observations/57007813 x1 adult male on rocks Variegated Skink 2020/08/19 -31.818806 22.464639 x1 adult on rocks

Karoo Girdled Lizard 2020/08/19 -31.817056 22.467917 https://www.inaturalist.org/observations/57008052 x1 adult on rocks

Variegated Skink 2020/08/19 -31.816778 22.472778 https://www.inaturalist.org/observations/57008276 x1 adult on rocks

Variegated Skink 2020/08/19 -31.873194 22.453389 https://www.inaturalist.org/observations/57008540 x1 adult on rocks

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11.10 APPENDIX 2: TAXONOMIC NOTES AND INTRODUCED SPECIES

This section provides brief statements on recent and forthcoming taxonomic changes. The checklists (Tables 1 and 2) refer to binomial taxa only, and some of the instances of subspecies are explained here to provide clarity. Two records of alien (translocated) reptiles have been recorded from the Karoo National Park. These are discussed at the end of this section. These species were omitted from the reptile species checklist (Table 1) because they are not regarded as being part of the region’s natural herpetofauna.

TAXONOMIC NOTES South African Helmeted Terrapin ( Pelomedusa galeata ): For years the genus Pelomedusa was regarded as being monotypic, consisting of only the one wide-spread species P. subrufa . However, recent molecular and morphological investigations concluded that P. subrufa is in fact comprised of a species complex of at least 11 cryptic species (e.g. Fritz et al. 2011, 2014, 2015; Vamberger et al. 2018; Vargas-Ramírez et al. 2016). Two of these are known to occur in South Africa, with records of P. galeata known from the Beaufort West region (including from the Nuweveld Wind Farms study area; Todd 2020a-c). Karoo Padloper ( Chersobius boulengeri ): Previously treated as a member of the genus Homopus , but recently transferred to the genus Chersobius (Hofmeyr et al. 2016, 2018). Tent Tortoise ( Psammobates tentorius ): There has been much confusion regarding the taxonomic status of the currently recognised three subspecies of Psammobates tentorius due to considerable colour and morphological variation and partially sympatric ranges. A recent phylogenetic study of southern African tortoise radiations indicates that P. tentorius consists of four deeply divergent lineages (Hofmeyr et al. 2016). According to the SANBI reptile dataset, both P. t. tentorius and P. t. veroxii have been recorded from the Beauport West region, with P. t. veroxii specifically from within the Nuweveld Wind Farms study area. Common Ground Agama ( Agama aculeata ): Two subspecies of Agama aculeata are currently recognised, with the nominate form A. a. aculeata occurring in the Beaufort West region. The taxonomic status of this species complex requires further investigation. Historical records of A. hispida and A. anchietae from the Beaufort West region are seemingly erroneous. Eastern Cape Dwarf Chameleon ( Bradypodion ventrale ): This taxon was previously referred to as Bradypodion karroicum (e.g. Branch and Braack 1989). Cloete’s Girdled Lizard ( Cordylus cloetei ): This lizard is one of the range-restricted herpetological novelties of the Beaufort West region (see Figure 16). However, a preliminary phylogenetic analysis of the Cordylus minor complex suggests that C. cloetei is not a valid species and that it should be synonymised with C. minor (K.A. Tolley unpubl. data 2020). Karoo Girdled Lizard ( Karusasaurus polyzonus ): This taxon was previously referred to as Cordylus polyzonus (e.g. Branch and Braack 1989), but the genus Cordylus was subsequently split into several genera (Stanley et al. 2011). Cape Crag Lizard (Pseudocordylus microlepidotus ): Three subspecies are currently recognised in Pseudocordylus microlepidotus , with the P. m. namaquensis form occurring in the Beauport West region. A preliminary phylogenetic analysis of this complex suggests that the three subspecies are not valid, and that P. microlepidotus should be split into two separate species (K.A. Tolley unpubl. data 2020). If this happens, then the Karoo taxon will be P. namaquensis . Giant Ground Gecko ( Chondrodactylus angulifer ): Two subspecies of Chondrodactylus angulifer are currently recognised, with the nominate form C. a. angulifer occurring in the Beaufort West region. However, the two subspecies do not appear to be genetically distinct (A.M. Bauer pers. comm. 2019) 124

and the two forms are sympatric in parts of the range (Bauer and Branch 2003 [2001]). This situation calls the validity of the subspecies into question. Braack’s Pygmy Gecko ( Goggia braacki ): This taxon was previously referred to as Phylodactylus lineatus (e.g. Branch and Braack 1989), but it was later shown to be taxonomically distinct and described as a new species (Good et al. 1996; see also Bauer et al. 1997). Spotted Barking Gecko ( Ptenopus garrulus ): Trinomials have been used since FitzSimons (1935) treated Ptenopus maculatus as a subspecies of P. garrulus . A phylogenetic study of this wide-ranging species may reveal intraspecific diversity and cryptic species. The taxon in the Beaufort West region is P. garrulus maculatus . Cape Long-tailed Seps ( Tetradactylus tetradactylus ): Tetradactylus bilineatus has been treated as a subspecies (Loveridge 1942, FitzSimons 1943) and as a junior synonym (Branch 1990) of T. tetradactylus . A preliminary phylogeny suggests that T. bilineatus from along the Great Escarpment and eastern Karoo are genetically differentiated at the species level (Conradie unpubl. data 2020). Common Sand Lizard (Pedioplanis lineoocellata ): Three subspecies are currently recognized in Pedioplanis lineoocellata , with the form P. l. pulchella having been recorded from within the Nuweveld Wind Farms study area (Todd 2020a-c). The distribution ranges of these subspecies overlap (Bates et al . 2014), and they generally lack diagnostic morphological differentiation (Edwards 2013). Sampling from multiple localities across the range of the subspecies suggests that while there is some genetic structuring, it does not match the geographic pattern of occurrence of the subspecies. Thus there appears to be little support for the currently-recognised subspecies (Edwards 2013). Striped Legless Skink ( Acontias lineatus ): A survey of the Karoo National Park (Branch and Braack 1989) reported on a single record of a legless skink that was tentatively identified as Acontias cf. lineatus . This specimen is significantly out of range for the species and requires additional taxonomic investigation. Eastern Cape Legless Skink ( Acontias orientalis ): The taxonomy of the Acontias meleagris complex is problematic because of confusion around colour morphs that do not correspond to the species level phylogenetic results. Specimens from the Beaufort West region were usually identified as A. meleagris , but it should instead be referred to as A. orientalis as per the findings of Engelbrecht et al. (2013). Western Rock Skink ( Trachylepis sulcata ): Two poorly defined subspecies of Trachylepis sulcata are currently recognised (Portik et al. 2010, 2011), with the nominate form T. s. sulcata having been recorded from within the Nuweveld Wind Farms study area (Burger 2020 survey; Todd 2020a-c). A phylogenetic analysis comparing populations throughout their distribution ranges is needed to resolve subspecies status. Southern Rock Monitor ( Varanus albigularis ): Three subspecies are currently recognised in Varanus albigularis , with the nominate form ( V. a. albigularis ) having been recorded from within the Nuweveld Wind Farms study area (Todd 2020a-c). A phylogenetic analysis comparing populations throughout their distribution ranges is needed to resolve subspecies status. Common Slug-eater (Duberria lutrix): Molecular phylogenetic studies suggest that most of the five recognized subspecies, represent distinct species (Broadley and Blaylock 2013). There is also cryptic diversity within D. l. lutrix which may represent different species (Kulenkampff et al. 2019, Edwards et al. 2019). The nominate form D. l. lutrix is known to occur in the Beaufort West region. Coral Shield Cobra ( Aspidelaps lubricus ): Two subspecies of Aspidelaps lubricus are currently recognised (Broadley and Baldwin 2006), with the nominate form A. l. lubricus likely to occur within the Nuweveld Wind Farms study area. A phylogenetic analysis comparing populations throughout their distribution ranges is needed to resolve subspecies status.

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Karoo Toad ( Vandijkophrynus gariepensis ): Two subspecies of Vandijkophrynus gariepensis are currently recognised, with the nominate form V. g. gariepensis having been recorded from within the Nuweveld Wind Farms study area (Burger 2020 survey; Todd 2020a-c). A phylogenetic analysis comparing populations throughout their distribution ranges is needed to resolve subspecies status. Poynton’s River Frog ( Amietia poyntoni ): Based on a recent revision of the genus Amietia (Channing et al. 2016), it would appear as though Amietia poyntoni (and not A. fuscigula ) is the species that occurs in the Beaufort West region. Specimens were observed within the Nuweveld Wind Farms study area (Burger 2020 survey; Todd 2020a-c). Karoo Caco ( Cacosternum karooicum ): This taxon was previously referred to as Cacosternum namaquense (e.g. Branch and Braack 1989), but it was later shown to be taxonomically distinct and described as a new species (Boycott et al. 2002). Tandy’s Sand Frog ( Tomopterna tandyi ): This is a cryptic species that is difficult to distinguish from Tomopterna delalandii . Specimens from the Beaufort West region was historically usually identified as T. delalandii (e.g. Branch and Braack 1989), but molecular analyses of specimens collected during the SANBI Karoo BioGaps Project only found T. tandyi . It seems likely that this is in fact the only species that occurs in this region, but additional sampling is needed to determine if T. delalandii also occurs here.

INTRODUCED SPECIES Jones’ Girdled Lizard ( Cordylus jonesii ): An incidence was recorded of a lizard (at the time referred to as Cordylus tropidostemum jonesi ) that was translocated from the Kruger National Park to the Karoo National park by means of a truckload of wood (Branch and Braack 1990). No further observations of this species have been noted at the Karoo National Park since 1989 when this incident occurred, and thus it seems as though an extralimital population did not manage to establish. Common Dwarf Gecko ( Lygodactylus capensis ): A single specimen was observed at a campsite in the Karoo National Park in 2006 (see Rebelo et al. 2019). This species has a reputation of being “ South Africa’s most successful reptile invader ”. Although no additional records of this species have been noted from there since, it may potentially manage to establish an extralimital population in this region.

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11.11 APPENDIX 3: DECLARATION OF INDEPENDENCE

I hereby declare that I have no conflicts of interest related to the work of this report. Specifically, I declare that I have no personal financial interests in the property and/or development being assessed in this report, and that I have no personal or financial connections to the relevant property owners, developers, planners, financiers or consultants of the development, other than fair remuneration. I declare that the opinions expressed in this report are my own and a true reflection of my professional expertise.

CV OF SPECIALIST CONSULTANT (abridged) Mr Marius Burger holds a National Diploma in Nature Conservation with Cape Technicon and worked as a research assistant with Eastern Cape Nature Conservation (1987-1997). Subsequently he took up employment with the Animal Demography Unit (ADU, University of Cape Town) as National Coordinator of the Southern African Frog Atlas Project (1997-2003) and as Project Herpetologist of the Southern African Reptile Conservation Assessment (2005-2009). Burger’s EIA activities as a faunal specialist started in 1996. He established a sole-proprietor business Sungazer Faunal Surveys in 1988 and has since participated in about 100 different projects in collaboration with a variety of EIA consultancies. His achievements as a faunal specialist are summarised below: • Member of IUCN SSC Snake and Lizard Red List Authority 2017-2020: 2017 – present. • Member of South African Frog Re-assessment Group (SA-FRoG): 2013 – present. • Member of Herpetological Association of Africa: 1988 – present. • Extraordinary Lecturer with the Unit for Environmental Sciences and Management, North-West University: 2015 – present. • Research collaborator with FLORA FAUNA & MAN, Ecological Services Ltd.: 2011 – present. • Research Collaborator with the Smithsonian Institute: 2002 – 2004. • Research Collaborator with the South African Museum: 2000 – 2002. • Country liaison for the journal Amphibian and Reptile Conservation : 2000 – 2004. • Chairman of the Port Elizabeth Herpetological Club: 1992 – 1996. • Compiled about 130 specialist and EIA reports for various consultancies and projects. • Published about 120 scientific, semi-scientific and popular articles, and authored/edited three books and 34 chapters/accounts in books. • Presented 50 papers/posters at national/international symposia.

M. Burger – trading as Sungazer Faunal Surveys September 2020

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12 ANNEX 4. BUTTERFLY SPECIALIST ASSESSMENT

Dave Edge & Associates

BUTTERFLY SENSITIVITY STUDY

NUWEVELD WIND FARM PROJECT

WESTERN CAPE PROVINCE

Prepared for : Prepared by : Lance Blaine Red Cap Nuweveld North (Pty) Ltd Unit B2 Mainstream Centre

Main Road David Alan Edge Hout Bay Dave Edge & Associates 7806 P O Box 2586, Knysna, 6570 Tel: 044 3810014 Cell: 074 5807288 email: [email protected]

Date of issue : 28 July 2020

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CREDENTIALS OF THE CONSULTANT

Contact details :

Dr David Alan Edge Dave Edge & Associates 81 Tulbagh Street Brenton-on-Sea Knysna 6570

Tel no: 044 3810014 Cell no: 074 5807288 Email: [email protected]

Expertise

• Qualifications: BSc (Zoology & Botany) UNISA; BSc (Hons) (Environmental Science) North-West University; MSc (Environmental Science) North-West University; PhD (Environmental Science) North- West University.

• Experience: Lepidopterist and ecologist with over 60 years’ experience studying butterflies. Has conducted numerous specialist butterfly surveys in terms of NEMA.

• Publications/ conferences: 34 scientific papers published in peer reviewed journals, and has presented papers at a number of national and international conferences.

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Conditions pertaining to this report

The content of this report is based on the author’s best scientific and professional knowledge as well as available information. Dave Edge & Associates reserve the right to modify the report in any way deemed fit should new, relevant or previously unavailable or undisclosed information become known to the author from on-going research or further work in this field, or pertaining to this investigation, and will inform Red Cap accordingly.

This report must not be altered or added to without the prior written consent of the author. This also refers to electronic copies of the report, which are supplied for the purposes of inclusion as part of other reports, including main reports. Similarly, any recommendations, statements or conclusions drawn from or based on this report must make reference to this report. If these form part of a main report relating to this investigation or report, this report must be included in its entirety as an appendix or separate section to the main report.

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NATIONAL LEGISLATION AND REGULATIONS GOVERNING THIS REPORT

The ‘specialist report’ compiled will be added as an appendix to and will inform the terrestrial ecology impact assessment undertaken in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended, and the Environmental Impact Assessment Regulations, 2014 (as amended).

DECLARATION BY THE INDEPENDENT PERSON WHO COMPILED THIS REPORT

I, David Alan Edge , as the appointed independent specialist hereby declare/ affirm the correctness of the information provided or to be provided as part of the application and that I:

• act as an independent specialist in this application, and other than fair remuneration for work performed in connection with this application in terms of the NEMA, the Environmental Impact Assessment Regulations, 2014 and any specific environmental management Act, have no business, financial, personal or other interest in the development proposal or application and that there are no circumstances that may compromise my objectivity;

• have disclosed, to the applicant, EAP and the competent authority, any material information that have or may have the potential to influence the decision of the competent authority, whether such information is favourable to the applicant or not; and am aware that a false declaration is an offence in terms of Regulation 48 of the EIA regulations, 2014 (as amended);

• am fully aware of and meet the responsibilities of a specialist in terms of NEMA, the Environmental Impact Assessment Regulations, 2014 (specifically in terms of Regulation 13 and Appendix 2 of GN No. R. 982) and any specific environmental management Act, and that failure to comply with these requirements may constitute an offence in terms of Regulation 48 of the EIA regulations, 2014 (as amended).

Signature of the Specialist:

______

David Alan Edge Representing: Dave Edge & Associates

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1. Introduction

Red Cap Energy (Pty) Ltd (Red Cap) is proposing three wind energy facilities (wind farms) approximately 65km north of Beaufort West and 30km south of Loxton along the R381 in the Beaufort West Local and Central Karoo District Municipalities, in the Western Cape.

In addition, Red Cap is also proposing the development of an approximately ~120km of 132kV or 400kV (132/400kV) transmission line (gridline) which will connect the proposed wind farms to the Eskom Droërivier Substation located south west of Beaufort West (gridline to be placed within an identified corridor). Collectively these are referred to as the Nuweveld Wind Farm Projects, comprising of Nuweveld North Wind Farm, Nuweveld West Wind Farm, Nuweveld East Wind Farm and the Nuweveld Gridline. A locality plan depicting the four project localities is shown in Figure 1 below. The total area being considered for all three wind farms is about 35 000 ha of which only about 1% will be permanently impacted and a further c. 1% temporarily impacted (total about 2% impacted permanently and temporarily) by the wind farm development (all infrastructure).

Red Cap have appointed Aurecon South Africa (Pty) Ltd (Aurecon) as the independent Environmental Assessment Practitioner (EAP) to facilitate the requisite Environmental Impact Assessment (EIA) process through which Environmental Authorisation (EA) for the proposed development, must be sought.

Figure 1 – Overview map of the Nuweveld Wind Farm projects, showing quarter degree grid squares. 133

2. Terms of reference of the Consultant

Dave Edge & Associates was appointed on 24 July 2020 by Lance Blaine, Managing Director of Red Cap, to carry out the following scope of work: 1. To assess the likelihood of the butterfly Pseudonympha trimenii nieuwveldensis occurring at the site. 2. To advise whether there are any other locally endemic, rare or threatened (ERT) butterflies occurring in the area that need to be taken into account. 3. Assess the potential for butterflies to collide with the wind turbines, the habitat loss risk and any other risk due to the wind farm that may impact the butterflies. 4. With regards to the habitat description, liaise with Mr. Simon Todd who has done extensive field work and vegetation mapping of the area to get input on the habitat/ plant species important to the butterfly. 5. Advise whether the proposed power line (which will be either a 132kV or a 400kV line and will be up to about 120km long) will have any significant impact on the butterflies. 6. Advise if any specific site investigations will be required, and if so the earliest you would be available to perform such investigations (when the butterflies are flying).

Information provided by Red Cap: 1. Summary of the North wind farm Pre-application Scoping report (typical for all three wind farms). 2. Summary of the grid pre-application Scoping Report 3. The terrestrial ecological specialist reports for all three wind farms and the grid 4. Kmz file showing the boundaries of each of the wind farms and the proposed locations of the wind turbines. 5. Kmz file showing the corridor in which the grid line will be constructed.

3. Methodology

3.1 Butterfly occurrence probabilities

Butterfly occurrence records from the quarter degree grid squares (QDGS) shown in Figure 1 were extracted from the LepiMap Virtual Museum database and the results of the Karoo BioGaps project (Edge & Mecenero, 2019). The data obtained was summarised on a spreadsheet, with any locally endemic, rare or threatened (ERT) butterflies identified, along with their host plants (if known).

3.2 Vegetation

The vegetation types at the site were investigated with reference to Mucina & Rutherford (2006) and Todd (2020). The vegetation types used by the butterflies occurring in the area were obtained from Mecenero et al. (2013), and butterfly host plants were obtained from various literature sources.

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3.3 Potential impact on butterfly populations

There are three types of threats to which butterflies could be exposed to as a result of the wind farm project:

o Loss of habitat that would be temporary (during construction) or permanent (during ongoing operations). Statistics were made available by Red Cap.

o Alteration or degradation of the habitat through direct and indirect impacts.

Physical damage to butterflies caused by collision with the moving parts of the wind turbines or from wake turbulence. Another source of injury could be the electrical power lines through collision.

3.4 Site visit

From the information obtained in steps 3.1 and 3.2 it was possible to estimate the probability of any of the ERT butterflies occurring at the site. This enabled the specialist to determine whether a site visit was required to verify the occurrence and exact location of any of the ERT butterflies at the site.

4. Results

4.1 Butterfly occurrence probabilities

The Nuweveld Wind Farm development is situated in the QDGSs 3122CB, 3122CD, 3122DC, 3222BA and 3222BC. Table 1 shows the actual occurrence records in these QDGSs and the surrounding ones. There are no records for the QGDSs that are not listed in Table 1. All of the butterflies that are listed in Table 1 have been assessed as being “Least Concern” in the most recent butterfly conservation assessments done in accordance with the IUCN Red Listing protocols (Mecenero et al. 2020, in press). Whilst none of these taxa are threatened, there are a few butterflies that are restricted range endemics recorded from the area and they could occur at the development site:

Aloeides caledoni A rare low density endemic confined to higher altitudes such as ridges and mountain tops. Known to occur in the Karoo National Park and on the Nuweveld mountains. Extent of occurrence > 43 000 km 2, but only known from a few places. Host plant is not known. Flight period is from October to mid-November. Probability of occurrence < 5%.

Chrysoritis beaufortia beaufortia A restricted range endemic which occurs at higher altitudes > 1 500m in the Nuweveld mountains. Extent of occurrence = c. 3000 km 2. Vegetation types = NKu 2 Upper Karoo Hardeveld and NKu 4 Eastern Upper Karoo. Host plants recorded as Dimorphotheca cuneata (Thunb.) or Osteospermum moniliferum (L.) (Heath et al. , 2008). Flight period is from October to mid-November. Probability of occurrence c. 5%.

Pseudonympha trimenii nieuwveldensis A restricted range endemic occurring at altitudes over 1 600 m in the Nuweveld mountains. Extent of occurrence = c. 2 000 km 2. Vegetation 135

types = NKu 2 Upper Karoo Hardeveld and NKu 4 Eastern Upper Karoo. Host plant recorded as Tenaxia disticha (Schrad.) (was Merxmuellera ) (Pringle et al. , 1994). Flight period is from late September to early November. Probability of occurrence < 10%

4.2 Vegetation

The vegetation of the wind farms and the gridline was described and mapped by Todd (2020) (Figure 2). The vegetation at the wind farm sites is mainly NKu 4 Eastern Upper Karoo (Mucina & Rutherford, 2006), with patches of NKu 2 Upper Karoo Hardeveld on dolerites sills and ridges. There are also areas of AZi 6 South Karoo Riviere in the drainage lines with riparian vegetation and smaller areas of endorheic pans and rock pavements. The gridline site has similar elements but also has areas of NKl 1 Gamka Karoo closer to Beaufort West (Figure 3).

The plant species list provided by Todd (2020) includes Tenaxia disticha , Dimorphotheca cuneata and several species of Osteospermum. This has been used in the estimate of the probability of occurrence in 4.1 above.

Figure 2 – Vegetation types for the Nuweveld wind farms

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Figure 3 – Vegetation types for the gridline

4.3 Potential impact on butterfly populations

Habitat loss

The overall area occupied by the wind farms will be 35 000 hectares (350 km 2). Red Cap have advised that during construction less than 2% of the total ground area would be disturbed (around 500 hectares), and after rehabilitation of such disturbed areas less than 1% of the ground area would be permanently transformed (around 250 hectares). Fragmentation of the habitat can also have detrimental effects, depending on where the butterfly colonies are situated.

Alteration/ degradation of the remaining habitat

Strict environmental policies need to be in place to prevent employees, contractors and visitors from driving off the authorised roads and causing damage to the natural habitat. Vegetation is sparse and can easily be damaged by vehicles, and then it takes a very long time to recover. Otherwise the policies described by Todd (2020) also need to be stringently implemented.

Damage to butterflies caused by the wind turbines or power lines

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It is understood that the elevation of the wind turbine blades is such that the closest approach of the blades to the ground is 25 m. The ERT butterflies do not normally fly more than 10 m from the ground so the risk of their colliding with the turbine blades is extremely small. Also they are accustomed to living in areas where there are high winds, so wind turbulence should not affect them much, even though the tips of the blades are moving at over 200 km/ hr. These conclusions were supported by Grealey & Stephenson (2007), who concluded that “there is no evidence to suggest that butterfly mortality is a concern at commissioned wind farm sites as a result of collisions with turbines”. There is no possibility that the power lines could cause any damage to the butterflies once operational, since the electrical conductors are high above the ground level.

4.4 Site visit

Although the probability of finding any of the three identified ERT butterflies on the site is quite small, it is not zero. It is prudent in such circumstances to apply the precautionary principle (McGarvey, 2007), and make certain that they do not occur.

The best time to make a site visit would be around the middle of October, when all three of the ERT butterflies are known to be flying at other sites.

5. Conclusions

The proposed Nuweveld Wind Farm development in the Great Karoo between Beaufort West and Loxton does not pose any danger to any currently Red Listed threatened butterflies (in the categories Critically Endangered, Endangered, or Vulnerable). However, there are three restricted range endemic butterflies which could occur at the site. It is recommended that a site visit be made during the butterfly’s flight period in the middle of October to establish if they occur at the development site and if so which part(s) of the site they occupy. In the unlikely event that there is a clash between the butterflies’ flying area(s) and the area to be disturbed during construction and operation of the wind farms, adjustments may have to be made to the layout.

6. Acknowledgements

Simon Todd is thanked for providing his reports on this project and for the use of his figures.

7. References

Edge, D.A. & Mecenero, S. 2019. Karoo BioGaps project – butterfly survey results and their interpretation. Metamorphosis 30(1) : 58–68.

Grealey, J. & Stephenson, D.J. 2007. Effects of wind turbine operation on butterflies. North American Windpower 4(1) February 2007.

Heath, A., McLeod, L., Kalisewska, Z.A., Fisher, C.W.S. & Cornwall, M. 2008. Field notes including a summary of trophic and ant-associates for the butterfly genera Chrysoritis

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Butler, Aloeides Hübner and Thestor Hübner (Lepidoptera: Lycaenidae) from South Africa. Metamorphosis 19(3) : 127–148.

McGarvey, D.J. 2007. Merging Precaution with Sound Science under the Endangered Species Act 2007. BioScience 57(1) : 65–70.

Mecenero, S., Ball, J.B., Edge, D.A., Hamer, M.L., Henning, G.A., Krüger, M., Pringle, E.L., Terblanche, R.F., Williams, M.C. 2013. Conservation Assessment of butterflies of South Africa, Lesotho and Swaziland – Red List and atlas. Saftronics (Pty.) Ltd, Johannesburg & Animal Demography Unit, University of Cape Town.

Mecenero, S., Edge, D.A., Staude, H.S., Coetzer, B.H., Coetzer, A.J., Raimondo, D.C. & Williams, M.C. 2020. Outcomes of the Southern African Lepidoptera Conservation Assessment (SALCA). Metamorphosis 31 : in press.

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

Pringle, E.L.L., Henning, G.A. & Ball, J.B. (Eds.) 1994. Pennington’s butterflies of southern Africa. 2nd edition. Struik Winchester, Cape Town.

Todd, S. 2020. Fauna & flora specialist impact assessment: Nuweveld North wind energy facility. Unpublished report produced for Aurecon South Africa (Pty) Ltd.

Todd, S. 2020. Fauna & flora specialist impact assessment: Nuweveld grid connection and associated infrastructure. Unpublished report produced for Aurecon South Africa (Pty) Ltd.

D.A. Edge Dave Edge & Associates 28 July 2020

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TABLE 1

Butterfly taxa occurring in the same quarter degree grid squares (QDGS) as the Nuweveld Wind Farm project and the immediately surrounding QDGSs. The QDGS with no records have been excluded. 1 = occurrence.

Note: Where part of the scientific name is abbreviated to just the first letter it is a repeat of the word following. QDGS ► 3122CB 3122CD 3122DD 3222AB 3222AC 3222AD 3222BA 3222BB 3222BC 3222BD ALL Butterfly families (bold) and taxa Hesperiidae Gomalia e. elma 1 1 Spialia a. agylla 1 1 1 Spialia ferax 1 1 1 1 Lycaenidae Aloeides caledoni 1 1 1 Aloeides d. damarensis 1 1 1 1 1 Aloeides depicta 1 1 1 Aloeides kaplani 1 1 Aloeides macmasteri 1 1 1 Aloeides p. pallida 1 1 1 Aloeides pierus 1 1 1 Aloeides vansoni 1 1 1 Anthene a. amarah 1 1 1 Argyraspodes argyraspis 1 1 1 1 1 Azanus jesous 1 1 1 1 Azanus moriqua 1 1 Azanus ubaldus 1 1 1 1 1 1 Cacyreus f. fracta 1 1 Cacyreus marshalli 1 1 Chrysoritis b. beaufortia 1 1 1 1 1 Chrysoritis chrysaor 1 1 1 1 1 1 Chrysoritis midas 1 1 1 1 1 Chrysoritis pan lysander 1 1 1 Crudaria leroma 1 1 1 1 1 Deudorix antalus 1 1 Eicochrysops m. messapus 1 1 1 1 Lampides boeticus 1 1 1 Leptomyrina lara 1 1 1 1 1 Leptotes p. pirithous 1 1 1 1 1 Lycaena clarki 1 1 Oraidium barberae 1 1 Stugeta b. bowkeri 1 1 Tylopaedia s. sardonyx 1 1 1 1 Zizeeria k. knysna 1 1 1 Nymphalidae Acraea horta 1 1 Cassionympha detecta 1 1 1 Danaus chrysippus orientis 1 1 1 1 Hypolimnas misippus 1 1 1 Junonia hierta cebrene 1 1 1 Junonia o. oenone 1 1

LAKE MICHELLE PHASE 8: Western Leopard Toad considerations (December 2017) 1

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Pseudonympha southeyi wykehami 1 1 1 Pseudonympha trimenii nieuwveldensis 1 1 1 Stygionympha irrorata 1 1 1 1 1 1 Stygionympha robertsoni 1 1 1 Tarsocera fulvina 1 1 1 1 Torynesis magna 1 1 1 1 Vanessa cardui 1 1 1 1 1 1 Ypthima asterope hereroica 1 1 Papilionidae Papilio d. demodocus 1 1 1 1 1 1 Pieridae Belenois aurota 1 1 1 1 1 Catopsilia florella 1 1 1 1 1 Colias e. electo 1 1 1 Colotis antevippe gavisa 1 1 Colotis euippe omphale 1 1 1 1 Pinacopteryx e. eriphia 1 1 Pontia h. helice 1 1 1 1 1 TOTAL TAXA 2 2 1 21 4 40 29 6 33 1 54

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13 ANNEX 5. DEA SCREENING TOOL SITE VERIFICATION REPORT

DEA Site verification report – Terrestrial Ecology

Government Notice No. 320, dated 20 March 2020, includes the requirement that an Initial Site Sensitivity Verification Report must be produced for a development footprint. As per Section 2.3, the outcome of the Initial Site Verification must be recorded in the form of a report that-

(a) Confirms or disputes the current use of the land and environmental sensitivity as identified by the national web based environmental screening tool;

(b) Contains a motivation and evidence of either the verified or different use of the land and environmental sensitivity;

(c) Is submitted together with the relevant reports prepared in accordance with the requirements of the Environmental Impact Assessment Regulations.

This report has been produced specifically to consider the terrestrial biodiversity, animal species and plant species themes and addresses the content requirements of (a) and (b) above. The report will be appended to the respective specialist study included in the Scoping and EIA Reports produced for the projects.

Site sensitivity based on the terrestrial biodiversity, plant species and animal species themes included in the Screening Tool and specialist assessment

Based on the DEA Screening Tool, the Animal Species, Plant Species and Combined Terrestrial sensitivity maps are illustrated below in Figure 1, Figure 2 and Figure 3 respectively. According to the Animal Species theme, the site is largely Medium sensitivity with some areas of High Sensitivity. The areas of High Animal Theme sensitivity are due to the presence of Riverine Rabbits, Bunolagus moniticularis and Verreauxii’s Eagle Aquila verreauxii , while the Medium sensitivity areas are due to the presence of the Karoo Padloper Chersobius boulengeri and the modelled presence of the Riverine Rabbits, Bunolagus moniticularis . In terms of the plant species theme, areas of low sensitivity have been identified within or near the site. This is best explained by the low number of historical plant records from this area. The Terrestrial Biodiversity Combined Sensitivity reflects the CBAs of the area and the drainage systems.

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Figure 1. DEA Screening Tool outcome for the Animal Species theme for the whole study area.

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Figure 2. DEA Screening Tool outcome for the Plant Species theme for the whole study area and surrounds.

Figure 3. DEA Screening Tool outcome for the combined Terrestrial Biodiversity Sensitivity theme for the whole study area and surrounds.

The verification site visit took place over two days on 13 and 14 May 2019. The site visit included a helicopter flight across the wind farm area as well as ground surveys across the site. During the site visit, various potentially sensitive areas within the wind farms were verified and checked in the field. This included various pans, rocky outcrops and drainage features that were observed following the overhead flight or from satellite imagery of the site. Several additional follow-up site visits were subsequently conducted to better characterise the fauna and flora of the site.

An ecological sensitivity map of the site was produced by integrating the results of the site visits with the available ecological and biodiversity information in the literature and various spatial databases. Mapped sensitive features such as wetlands, drainage lines, rocky hills and pans were collated and buffered where appropriate to comply with legislative requirements or ecological considerations. Additional sensitive areas were then identified based on the result of fieldwork and from the satellite imagery of the site and delineated. All the different layers created were then merged to create a single coverage. In Figure 4, the sensitivity map produced is overlain with the extent of the DEA Screening Tool’s very high sensitivity layer (shown in the blue border) as well the Beaufort West Spatial Plan (2017), showing the extent of the CBA 1 in the area.

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Figure 4. Environmental sensitivity map produced by the terrestrial specialist

Motivation of the outcomes of the sensitivity map and key conclusions

The following conclusions can be made, based on the map included in Figure 4:

• There is a relatively large degree of congruence between the Animal Species theme sensitivity map and the sensitivity mapping conducted as part of the current study. This is due mainly to the mapping of steep slopes as sensitive features under both maps.

• The congruence between the Terrestrial Biodiversity Combined Theme and the current sensitivity map is somewhat lower as the Terrestrial Biodiversity Combined Theme represents the CBAs of the site as well as the 1:50 000 drainge features which are relatively coarsely mapped compared to the detailed mapping conducted for the current study. Based on the limited outputs of the DEA Screening Tool , it is clear that there is actually very little underlying information available for the area to properly inform such spatial planning. This is a caveat associated with the DEA Screening Tool, and the results for areas with very little baseline information must always be interpreted with caution as there is a high risk that important biodiversity features present in these areas have not been identified by the Screening Tool. In terms of the current site, it is clear that at the site-scale there are numerous sensitive features present including drainage lines, pans, steep slopes and rocky outcrops. The extensive, CBA in the southeast of the site, which

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comes out in the Screening Tool as the large Very High sensitivity area, consists of mumerous features of different sensitivity ranging from Low Sensitivty through to Very High Sensitivity. At a broad level, there is some agreement that this area is generally quite sensitive, but the current map provides a much more detailed and nuanced picture of the observed sensitivities. Within the Karoo, where the majority of the landscape is still intact, there are often numerous areas where conservation targets for the dominant vegetation types can be met. As such, the CBAs in the Karoo can reflect either the presence of actual features of concern, or may represent broader corridors resulting from the best-design principles inherent in the CBA mapping process. The implication of this for the current mapping is that the DEA Screening Tool and the on-site verified mapping are illustrating slightly different things. The DEA Screening Tool in this case is reflecting the CBA map for the area which is showing an area with numerous features of conservation concern and where the CBA has been expanded as part of the optimal design to cover the adjacent areas as well as the features of concern. The on-site mapping reflects only the actual features of concern as observed and cannot easily replicate the broader vegetation-type commitments to conservation inherent in the biodiversity spatial plans.

• In terms of the animal species theme, the DEA Screening Tool identifies only two terrestrial species of concern for the area. This being the Riverine Rabbit and Karoo Padloper. The current study includes the Riverine Rabbit Bunolagus monticularis (CR), Black-footed Cat Felis nigripes (VU), Grey Rhebok Pelea capreolus (NT), Mountain Reedbuck Redunca fulvorufula (EN), Brown Hyena Hyaena brunnea (NT), Karoo Padloper Chersobius boulengeri and Giant Bull Frog Pyxicephalus adspersus as being potentially present. Of these, the Riverine Rabbit is known to occur immediately adjacent to the site but has not been recorded from the within the development area, while the Mountain Reedbuck can be confirmed present. The remaining species are unlikely to be present on the site as the habitat is deemed largely unsuitable for these species.

Given that the DEA Screening Tool identified High sensitivity areas within the Animal Species Theme and Very High for the Terrestrial Biodiversity Combined Theme, the tool triggers the associated detailed assessment protocols of the fauna and biodiversity features present as detailed in Annex 7 and Annex 8 and a compliance statement for the plant species theme. Although the specialist identified additional species and areas of high sensitivity within the site, this does not substantially alter the required protocols as the DEA Screening Tool had already indicated that the highest level of assessment is required.

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14 ANNEX 6. BEAUFORT WEST BYPASS

As the Beaufort West Bypass is some distance from the wind farm, this component of the development cannot be easily mapped within the same maps as the wind farm. Consequently, this component of the development has been mapped on its own here and the basic baseline features present in this area described and its contribution towards the overall impact of the Nuweveld West Wind Farm discussed.

Vegetation Types The Beaufort West bypass is restricted to the Gamka Karoo vegetation type. The Gamka Karoo vegetation type has a total extent of 20 324 km 2 and occurs in the large basin bounded by the Nuweveld Mountains in the north and northwest and the Swartberg and adjacent Cape Fold Mountains in the south. Gamka Karoo is classified as Least Threatened and less than 1% has been transformed (Mucina & Rutherford 2006). The vegetation type is however poorly protected as less than 2% falls within formal protected areas compared to the target of 16%. Gamka Karoo is characterised by irregular to slightly undulating plains covered in dwarf spiny shrubland dominated by karoo dwarf shrubs, with occasional low trees. Dense stands of perennial bunchgrasses cover broad sandy bottomlands. Geology consists of mudstones and sandstones of the Beaufort Group with some Ecca shales supporting very shallow and stony soils of the Glenrosa and Mispah forms, typical of the Fc land type. It is regarded as one of the most arid units of the Nama-Karoo Biome, with rainfall varying from 100mm in some areas in the rain shadow of the Cape Fold Mountains to about 240mm against the great escarpment. Although this is generally considered to represent a low sensitivity vegetation type, it is typically dissected by drainage features which increase the general sensitivity of these areas. Common and typical species include Rhigozum obovatum , Pentzia incana , Eriocephalus ericoides , Stipagrostis obtusa , Asparagus capensis , Zygophyllum lichtensteinii , Monechma incanum , Chrysocoma ciliata , Felicia muricata , Pteronia mucronata , Pteronia staehelinoides , Rosenia glandulosa , Indigofera sessilifolia , Hermannia spinosa , Drosanthemum lique , Eragrostis obtusa , Fingerhuthia africana and Lycium cinereum . The abundance of species of concern within this vegetation type is generally low, although there are often a variety of protected species present including Ammocharis coranica , Aloe broomii and Aloe claviflora .

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Figure 1. Vegetation map for the Beaufort West bypass, illustrating that the route is restricted to the Gamka Karoo vegetation type.

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Critical Biodiversity Areas

The CBA map for the Beaufort West bypass road area is illustrated below in Figure 2. There is a small section of CBA at the start of the bypass, near to the entrance to the Karoo National Park, which is also a conspicuous feature of the site. This area has been designated CBA status due to its potential sutiability as Mountain Zebra habitat and its high sensitivity rating in the Shale Gas SEA. However, these features would not be significantly impacted by the bypass as this area is not likely to become available as Mountain Zebra habitat given its’ proximity to the urban edge. The bypass is therefore not seen as likely to generate a significant impact on the affected CBAs and more importantly on the underlying ecological processes which charaerise the affected area. The majority of the bypass route is however classified as an Ecological Support Area. These areas are often designed to buffer more important features such as the Karoo National Park or water resource areas from impact. Provided that the bypass is properly constructed with the appropriate erosion control features present, then it is not likely to compromise any of these goals.

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Figure 2. Extract of the Western Cape Biodiversity Spatial Plan for the Beaufort West bypass, showing the Karoo National Park west of the route and the small CBA where the bypass leaves the N1 in the south.

Beaufort West Bypass Sensitivity Analysis

The sensitivity map for the bypass route is illustrated below in Figure 3. Large tracts of the route have been classified as low sensitivity as there is already a gravel track present along large sections of the proposed route and there are also large areas of disturbed ground near to the town where is an old quarry. The only sensitive features of the route are some minor drainage features in the north of the route and with the proper road construction, impact on these features would be minimal. Overall, the impact of the bypass would be low as the area is already significantly disturbed and there are no features of high significance that would be affected by the bypass.

Sensitivity High Medium Low

Figure 3. Ecological sensitivity map of the Beaufort West bypass road. Large tracts of the route have already been disturbed and there is already a gravel track along the majority of the route.

Conclusions & Recommendations – Beaufort West Bypass

There are no significant ecological features along the bypass road and additional habitat loss resulting from road construction would be low as the affected area is already significantly disturbed from previous disturbance. The proximity of the bypass to the Karoo National Park is a potential concern, but as alluded to above, the existing disturbance and proximity of the route to Beaufort West, indicates that additional habitat loss and disturbance associated with the

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construction and operation of the bypass would be low and no noticeable impact on the National park is likely.

There are no significant biodiversity features along the bypass route and the contribution of the bypass to impact associated with the Nuweveld West Wind Farm would be minimal. 15 ANNEX 7. CRITERIA FOR THE ASSESSMENT AND REPORTING OF IMPACTS ON TERRESTRIAL ANIMAL SPECIES FOR ACTIVITIES REQUIRING ENVIRONMENTAL AUTHORISATION

The table below provides the Protocol for the Assessment and Reporting of Environmental Impacts on Terrestrial Animal Species – as published in the Government Gazette no. 42946 (2020).

Very High Sensitivity RATING – for 1. General Information terrestrial animal species 1.1 An applicant, intending to undertake an activity as identified in the 1. Critical habitat for range restricted scope of this protocol on a site identified as being of “very high”, species of conservation concern that “high” or “medium” sensitivity for terrestrial animal species on the have a global range of less than 10 km 2. national web based environmental screening tool must submit a 2. Species of conservation concern Terrestrial Animal Species Impact Assessment Report. listed on the IUCN Red List of 1.2 However, where the information gathered from the initial site Threatened Species 1 or South Africa’s sensitivity verification identified in section 2 of this protocol or the National Red List website 2 as Critically specialist assessment differs from the designation of “very high”, Endangered, Endangered or Vulnerable “high”, or “medium” terrestrial animal species sensitivity from the according to the IUCN Red List 3.1. national web based environmental screening tool and it is found to Categories and Criteria or listed as be of a “low” sensitivity, then a Terrestrial Animal Species Impact Nationally Rare. These areas are Assessment is not required. irreplaceable in terms of species of 1.3 Should paragraph 1.2 apply, a Terrestrial Animal Species conservation concern. Compliance Statement must be submitted. An environmental assessment practitioner or a suitably qualified taxon relevant HIGH SENSITIVITY RATING – specialist, registered with the South African National Council for for terrestrial animal species Natural Scientific Professionals (SACNASP), must append to the Terrestrial Animal Species Compliance Statement a motivation 1. Confirmed habitat for species of and evidence (e.g. photographs) of the different terrestrial animal conservation concern. species sensitivity. 2. Species of conservation concern listed on the IUCN Red List of 2. Terrestrial Animal Species Impact Assessment Threatened Species or South Africa’s National Red List website as Critically 2.1 The assessment must be undertaken by a suitably qualified taxon Endangered, Endangered or Vulnerable relevant SACNASP registered specialist aligned with the taxa according the IUCN Red List 3.1. identified in the report generated from the national web based Categories and Criteria. These areas environmental screening tool on the site being submitted as the are unsuitable for development due to a preferred development site. very likely impact on species of 2.2 The Terrestrial Animal Species Impact Assessment must include conservation concern. the results of a site assessment undertaken on the preferred development site. MEDIUM SENSITIVITY RATING 2.3 The Terrestrial Animal Species Impact Assessment must be – for terrestrial animal species undertaken in accordance with the Species Environmental Assessment Best Practice Guidelines3 and must identify the 1. Suspected habitat for species of following: conservation concern based either on 2.3.1 The species of conservation concern which were found on there being records for this species site; collected in the past prior to 2002 or 2.3.2 The distribution, location, viability (ability to survive and being a natural area included in a reproduce in future) and detailed description of population habitat suitability model.

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2. Species of conservation concern size of the species of conservation concern identified on the listed on the IUCN Red List of preferred development site; Threatened Species or South Africa’s 2.3.3 The nature and the extent of the potential impact of the National Red List website as Critically proposed development on the species of conservation Endangered, Endangered or Vulnerable concern on the proposed development site; according to the IUCN Red List 3.1. 2.3.4 The importance of the conservation of the population of the Categories and Criteria. species of special concern identified on the proposed development site based on information available in national and international databases including the IUCN Red List of Threatened Species, South African Red List of Species, and/or other relevant databases; 2.3.5 The potential impact of the proposed development on the habitat of the species of conservation concern; 2.3.6 Any dynamic ecological processes occurring within the site and its surrounds that might be disrupted by the proposed development and resulting impact on the identified species of conservation concern; for example, fires in fire-prone systems; 2.3.7 Any potential impact of ecological connectivity (on site, and in relation to the broader landscape) and resulting impact on the identified species of conservation concern; 2.3.8 Buffer distances as per the Species Environmental Assessment Best Practice Guidelines used for the population of each species of conservation concern; 2.3.9 The likelihood of other threatened species, undescribed species or highly localised endemics, migratory species, or species of conservation concern, occurring in the vicinity; and 2.3.10 Identify any alternative development footprints within the preferred development site which would be of “low” sensitivity as identified by the national web based environmental screening tool and verified through the initial site sensitivity verification.

3. The findings of the Terrestrial Animal Species Impact Assessment must be written up in a Terrestrial Animal Species Impact Assessment Report.

This report must include as a minimum the following information:

3.1. Contact details and curriculum vitae of the specialist including SACNASP registration number and fields of expertise; 3.2. A signed statement of independence by the specialist; 3.3. Duration, date and season of the site investigation and the relevance of the season to the outcome of the assessment; 3.4. A description of the methodology used to undertake the impact assessment and site inspection, including equipment and modelling used where relevant; 3.5. A description of the assumptions made and any uncertainties or gaps in knowledge or data as well as a statement of the timing and intensity of site inspection observations; 3.6. Areas not suitable for development, to be avoided during construction and operation where relevant; 3.7. Additional environmental impacts expected from the proposed development based on those already evident on the site and a discussion on the cumulative impacts; and 3.8. Impact management actions and impact management outcomes proposed by the specialist for inclusion in the Environmental Management Programme (EMPr); 3.9. A reasoned opinion, based on the findings of the specialist assessment, regarding the acceptability or not of the proposed

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development and if the proposed development should receive approval or not, and any conditions to which the opinion is subjected; 3.10. A motivation must be provided if there were development footprints identified as per paragraph 2.3.10 above that were identified as having a “low” terrestrial animal species sensitivity and were not considered appropriate.

4. The findings of the Terrestrial Animal Impact Assessment must be incorporated into the Basic Assessment Report (BAR) or the Environmental Impact Assessment Report (EIAR), including the mitigation and monitoring measures as identified, which must be incorporated into the EMPr. A signed copy of the assessment must be appended to the BAR or EIAR.

LOW SENSITIVITY RATING – for 1. General Information terrestrial animal species 1.1 An applicant, intending to undertake an activity as identified in the 1. Areas where no natural habitat scope of this protocol, on a site identified as being of “low remains. sensitivity” for terrestrial animal species on the national web based 2. Natural areas where there is no environmental screening tool must submit a Terrestrial Animal suspected occurrence of species of Species Compliance Statement, unless conservation concern. 1.1.1 the information gathered from the initial site sensitivity verification identified in section 2 of this protocol differs from that identified as having a “low” terrestrial animal species sensitivity by the national web based environmental screening tool and it is found to be of a “very high” “high” and/or “medium” sensitivity.

1.2 Should 1.1.1 apply, a Terrestrial Animal Species Impact Assessment is to be undertaken and a report should be prepared in accordance with the requirements of a Terrestrial Animal Impact Assessment.

2. Terrestrial Animal Species Compliance Statement

2.1 The Terrestrial Animal Species Compliance Statement must be prepared by a suitably qualified, taxon relevant SACNASP registered specialist, on the site being submitted as the preferred development site and must verify: 2.1.1 That the site is of “low” sensitivity for terrestrial animal species; and 2.1.2 Whether or not the proposed development will have any impact on the terrestrial animal species.

3. The Terrestrial Animal Species Compliance Statement, must contain, as a minimum, the following information:

3.1 Contact details and curriculum vitae of the specialist including SACNASP registration number and field of expertise; 3.2 A signed statement of independence by the specialist; 3.3 Methodology used to undertake the site survey and prepare the compliance statement, including equipment and modelling used where relevant; 3.4 Where required, proposed impact management outcomes or any monitoring requirements for inclusion in the EMPr; 3.5 A description of the assumptions made and any uncertainties or gaps in knowledge or data as well as a statement of the timing and intensity of site inspection observations; and 3.6 Any conditions to which the statement is subjected.

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4. A signed copy of the full Terrestrial Animal Species Compliance Statement must be appended to the BAR or EIAR.

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16 ANNEX 8. CRITERIA FOR THE ASSESSMENT AND REPORTING OF IMPACTS ON TERRESTRIAL BIODIVERSITY FOR ACTIVITIES REQUIRING ENVIRONMENTAL AUTHORISATION

The table below provides the Protocol for the Assessment and Reporting of Environmental Impacts on Terrestrial Biodiversity – as published in the Government Gazette no. 45421 (2019).

TABLE 1: REQUIREMENTS FOR THE ASSESSMENT AND REPORTING OF IMPACTS ON TERRESTRIAL BIODIVERSITY FOR ACTIVITIES REQUIRING ENVIRONMENTAL AUTHORISATION

VERY HIGH SENSITIVITY RATING - for terrestrial biodiversity features 1 General Information

1.1 An applicant intending to undertake an activity identified in the Scope of this Protocol, on a site identified as being of “very high sensitivity” for terrestrial biodiversity on the national web based environmental screening tool must submit a Terrestrial Biodiversity Impact Assessment . 1.2 However, where the information gathered from the Initial Site Sensitivity Verification identified in section 2.1 of this Protocol or the specialist assessment differs from the designation of “very high” terrestrial biodiversity sensitivity from the national web based environmental screening tool and it is found to be of a “low” sensitivity, then a terrestrial biodiversity impact assessment is not required. 1.3 Should paragraph 1.2 apply, a Terrestrial Biodiversity Compliance Statement is to be provided. An Environmental Assessment Practitioner or a suitably qualified and SACNASP registered specialist, must append to the Terrestrial Biodiversity Compliance Statement a motivation and evidence (e.g. photographs) of the changed Terrestrial Biodiversity sensitivity.

2 The Terrestrial Biodiversity Impact Assessment

2.1 The assessment must be undertaken by a SACNASP registered specialist, on the preferred development site. 2.2 Description of the preferred site - the following aspects, as a minimum, must be considered in the baseline description: 2.2.1 A description of the ecological drivers/processes of the system and how the proposed development will impact these; 2.2.2 Ecological functioning and ecological processes (e.g. fire, migration, pollination, etc.) that operate within the proposed development site; 2.2.3 The ecological corridors that the development would impede including migration and movement of flora and fauna; 2.2.4 The description of any significant landscape features (including rare or important flora/faunal associations, presence of Strategic Water Source Areas (SWSAs) or Freshwater Ecosystem Priority Areas (FEPA) sub catchments; 2.2.5 A description of terrestrial biodiversity and ecosystems on the proposed development site, including – a) Main vegetation types; b) Threatened ecosystems, including Listed Ecosystems as well as locally important habitat types identified; c) Ecological connectivity, habitat fragmentation, ecological processes and fine-scale habitats; and d) Species, distribution, important habitats (e.g. feeding grounds, nesting sites, etc.) and movement patterns identified. 2.3 Identify any alternative development footprints within the preferred development site which would be of a “low” sensitivity as identified by the national web based

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environmental screening tool and verified through the Initial Site Sensitivity Verification; 2.4 The Terrestrial Biodiversity Impact Assessment must be based on the results of a site inspection undertaken on the preferred development site and must identify:

2.5 Terrestrial Critical Biodiversity Areas (CBAs), including: 2.5.1 The reasons why an area has been identified as a CBA; 2.5.2 An indication of whether or not the development is consistent with maintaining the CBA in a natural or near natural state or in achieving the goal of rehabilitation; 2.5.3 The impact on species composition and structure of vegetation with an indication of the extent of clearing activities; 2.5.4 The impact on ecosystem threat status; 2.5.5 The impact on explicit subtypes in the vegetation; 2.5.6 The impact on overall species and ecosystem diversity of the site; and 2.5.7 The impact on populations of species of special concern in the CBA. 2.6 Terrestrial Ecological Support Areas, including; 2.6.1 The impact on the ecological processes that operate within or across the site; 2.6.2 The extent the development will impact on the functionality of the ESA; and 2.6.3 Loss of ecological connectivity (on site, and in relation to the broader landscape) due to the degradation and severing of ecological corridors or introducing barriers that impede migration and movement of flora and fauna. 2.7 Protected Areas as defined by the National Environmental Management: Protected Areas Act, 2004 including: 2.7.1 An opinion on whether the proposed development aligns with the objectives/purpose of the Protected Area and the zoning as per the Protected Area Management Plan; 2.8 Priority Areas for Protected Area Expansion, including: 2.8.1 The way in which in which the development will compromise or contribute to the expansion of the protected area network. 2.9 Strategic Water Source Areas (SWSA) including: 2.9.1 The impact(s) on the terrestrial habitat of a Strategic Water Source Area, and 2.9.2 The impacts of the development on the SWSA water quality and quantity (e.g. describing potential increased runoff leading to increased sediment load in water courses). 2.10 Freshwater Ecosystem Priority Area (FEPA) sub catchments, including: 2.10.1 The impacts of the development on habitat condition and/or species in the FEPA sub catchment. 2.11 Indigenous Forests, including: 2.11.1 Impact on the ecological integrity of the forest; 2.11.2 Extent of natural or near natural indigenous forest area lost.

3 The findings of the Terrestrial Biodiversity Impact Assessment must be written up in a Terrestrial Biodiversity Impact Assessment Report.

This report must include as a minimum the following information: 3.1 Contact details and curriculum vitae of the specialist including SACNASP registration number and field of expertise and their curriculum vitae; 3.2 A signed statement of independence by the specialist; 3.3 Duration, date and season of the site inspection and the relevance of the season to the outcome of the assessment; 3.4 A description of the methodology used to undertake the impact assessment and site inspection, including equipment and modelling used where relevant; 3.5 A description of the assumptions made and any uncertainties or gaps in knowledge or data as well as a statement of the timing and intensity of site inspection observations; 3.6 Areas not suitable for development, to be avoided during construction and operation (where relevant); 3.7 Additional environmental impacts expected from the proposed development based on those already evident on the site and a discussion on the cumulative impacts;

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3.8 Impact management actions and impact management outcomes proposed by the specialist for inclusion in the EMPr; and 3.9 A motivation where the development footprint identified as per section 2.3 in this Table were not considered stating reasons why these were not being not considered. 3.10 A reasoned opinion, based on the findings of the specialist assessment, regarding the acceptability or not of the development and if the development should receive approval or not, and any conditions to which the statement is subjected.

4 The findings of the Terrestrial Biodiversity Impact Assessment must be incorporated into the Basic Assessment Report or the Environmental Impact Assessment Report, including the mitigation and monitoring measures as identified, which must be incorporated into the EMPr. A signed copy of the Assessment must be appended to the Basic Assessment Report or Environmental Assessment Report.

LOW SENSITIVITY RATING – for terrestrial biodiversity features 1 General Information

1.1 An applicant, intending to undertake an activity identified in the Scope of this Protocol, on a site identified as being of “low sensitivity” for terrestrial biodiversity on the national web based environmental screening tool must submit a Terrestrial Biodiversity Compliance Statement to the competent authority, unless: 1.1.1 The information gathered from the Initial Site Sensitivity Verification differs from that identified as having a “low” terrestrial biodiversity sensitivity by the national web based environmental screening tool and it is found to be of a “very high” sensitivity. 1.2 Should paragraph 1.1.1 apply, a Terrestrial Biodiversity Impact Assessment is to be undertaken and a report should be prepared in accordance with the requirements of a Terrestrial Biodiversity Impact Assessment.

2 Terrestrial Biodiversity Compliance Statement

2.1 The Terrestrial Biodiversity Compliance Statement , must be prepared by a suitably qualified specialist in the field of ecological sciences, on the site being submitted as the preferred development site and must verify:

2.1.1 That the site is of “low” sensitivity for terrestrial biodiversity; and 2.1.2 Whether or not the proposed development will have any impact on the biodiversity feature.

3 The Terrestrial Biodiversity Compliance Statement , must contain, as a minimum, the following information:

3.1 Contact details and curriculum vitae of the specialist including SACNASP registration number and field of expertise; 3.2 A signed statement of independence by the specialist; 3.3 Baseline profile description of biodiversity and ecosystems, including the duration, date and season of the site investigation and the relevance of the season to the outcome of the assessment; 3.4 Methodology used to verify the sensitivities of the terrestrial biodiversity on the national web based environmental screening; 3.5 Methodology used to undertake the site survey and prepare the Compliance Statement, including equipment and modelling used where relevant; 3.6 Where required, proposed impact management outcomes or any monitoring requirements for inclusion in the EMPr;

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3.7 A description of the assumptions made and any uncertainties or gaps in knowledge or data as well as a statement of the timing and intensity of site inspection observations; and 3.8 Any conditions to which the statement is subjected.

4 A signed copy of the full Terrestrial Biodiversity Compliance Statement must be appended to the Basic Assessment Report or Environmental Impact Assessment Report.

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