Public Participation Summary Report for the Mount Edgecombe Refuse Transfer Station Relocation
A Report for the BA Process: DM/WML/0041/2012
8 August 2013
DOCUMENT DESCRIPTION
Client: Tongaat Hulett Developments
Project Name: Waste Management License Application for the Proposed Relocation of the Mount Edgecombe Refuse Transfer Station
Royal HaskoningDHV Reference Number: E02.DUR.000484
Authority Reference Number: DM/WML/0041/2012 KZN/WASTE/0000106/2012
Compiled by: Humayrah Bassa
Date: 8 August 2013
Location: Durban
Review: Prashika Reddy
______Signature
Approval: Malcolm Roods
______Signature
© Royal HaskoningDHV All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, without the written permission from Royal HaskoningDHV.
Table of Contents
1 INTRODUCTION ...... 1 1.1 Background ...... 1 1.2 The Public Participation Process ...... 1 1.3 Purpose of the Report ...... 1 1.4 Terms of Reference for Public Participation ...... 1 1.5 Public Participation Summary ...... 2 2 IDENTIFICATION OF I&APS ...... 2 3 NOTIFICATION OF PROCESS SEPERATION ...... 6 4 SITE NOTIFICATION...... 8 5 BACKGROUND INFORMATION DOCUMENT ...... 9 6 ADVERTISEMENT ...... 16 7 PUBLIC MEETING ...... 17 8 PUBLIC REVIEW OF THE BA Report ...... 39 9 ISSUES TRAIL ...... 39 10 WASTE MANAGEMENT LICENCE ...... 39
Appendices
Appendix A: Comments and Responses Report
1 INTRODUCTION
1.1 Background
As part of the greater Cornubia Mixed-Use Phased Development and the construction of the Cornubia Retail Park specifically, Tongaat Hulett Developments (THD) propose to relocate the existing Durban Solid Waste (DWS) Mount Edgecombe Refuse Transfer Station from it’s existing location on the Cornubia Retail Park site to a new location, 200 metres east of the existing site and within Cornubia (Figure 1). Cornubia is located within the eThekwini Municipality (eTM) and is situated north of Durban.
Royal HaskoningDHV (RHDHV) was appointed by THD to act as an independent Environmental Assessment Practitioner (EAP) for the Waste Management Licence (WML) application for the proposed relocation. This includes the construction of a new Station as well as the decommissioning of the existing Station.
The Environmental Impact Assessment (EIA) for the Cornubia Retail Park development assesses the infrastructural requirements for the new Station whilst this separate Basic Assessment (BA) process is underway to address the requirements of the Waste Management Licence (WML) Application.
1.2 The Public Participation Process
Public participation is a process that is designed to enable all I&APs to voice their opinion and/ or concerns which enables the practitioner to evaluate all aspects of the proposed development, with the objective of improving the project by maximising its benefits while minimising its adverse effects. I&APs include all interested stakeholders, technical specialists, and the various relevant organs of state who work together to produce better decisions.
The public participation process must adhere to the requirements of Regulations (GNR 543) under the National Environmental Management Act (NEMA) (No 107 of 1998)(as amended).
RHDHV is conducting the Public Participation Process for the Mount Edgecombe Refuse Transfer Station Relocation. In recent years THD has taken a much more participatory approach to their property development projects, with the understanding that the socio-political and economic context of the times invites this more public approach. Communities that surround the developments are invited to “inform and be informed” about developments through the establishment of fora in order to achieve the most positive impacts possible. It is also noted that engaging stakeholders even before developments are built can achieve the best impacts. It is for this reason that the PPP that forms part of the BA becomes the basis of a long-term stakeholder engagement process.
1.3 Purpose of the Report
The principal purpose of this Public Participation Summary Report is to:
Summarise the public participation processes undertaken for the BA Process; Highlight what has been done to date; Synthesise the issues and concerns identified by Interested and Affected Parties (I&APs) and various stakeholders during the public participation process; and Synthesise comments on the proposed development.
1.4 Terms of Reference for Public Participation
One of the main aims of the public participation process is to serve as a structure for communication and consultation with I&APs. An outline of the communication efforts that was launched as part of this process are listed below. It should, however, be noted that this plan was adapted throughout the process to ensure successful communication and consultation by the public participation consultants to all I&APs.
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The project team recognises successful communication as a relevant, timely, and continuous tool that enables the targeted project team, individual and groups of I&APs.
The terms of reference for the implementation of a successful and robust public participation programme, were as follows:
Identification of I&APs in the vicinity of the study area; Provision to all I&APs of an opportunity to comment or raise concerns regarding the project; Maintenance of procedures for communication with I&APs and receiving, documenting and responding to relevant communication from I&APs; Identification and elimination of any sources of misunderstandings between the Applicant, Consultants and the I&APs; Always aim to improve the communication between the Consultants, the Applicant and I&APs; Present the project in an objective way by supplying all appropriate, relevant and accurate information and facts in an unbiased manner to ensure a better understanding of the proposed project; and Ensure that the public participation process is an independent and transparent process.
1.5 Public Participation Summary
The PPP commenced in November 2012 where site notices were erected at the entrance of the site in Mount Edgecombe. In April 2013, the EIA for the Cornubia Retail Park was separated from the WML Application for the Mount Edgecombe Refuse Transfer Station Relocation and all I&APs were sent written notification informing them of this change. WML specific site notices were erected & Background Information Document (BID) flyers were distributed to neighbouring properties as well as other interested and affected parties (I&APs).
An advertisement was placed in the Northglen News newspaper on the 4th June 2013 followed by a comment period which was open for the I&APs to raise their issues and concerns regarding the proposed activity. A draft Basic Assessment Report and Environmental Management Programme has been compiled, and distributed to the relevant authorities and to the public for review, for a 40 day comment period in which I&AP’s were afforded the opportunity to raise any further issues and concerns.
An advert was placed in the Northglen News newspaper on the 24th of May 2013 notifying I&APs inviting I&APs to attend the EIA Phase Public Meeting. They were further notified of the availability of the draft Environmental Impact Assessment Report for public review for a period of 40 days.
A public meeting was held on the 13th of June 2013 at Mount Edgecombe Country Club.
Following receipt of all comments a Comments and Responses Report as part of the ongoing Issues Trail was updated where all comments were responded to and addressed in the final BAR. I&APs were notified of the availability of the final BAR for further review and comment for a period of 21 days prior to submission to the KZN DAEA for decision-making.
2 IDENTIFICATION OF I&APS
Prior to commencement of the PP Process a detailed understanding of the project description was attained from the Applicant. Upon receiving the description a site visit was undertaken, this process was used to identify the following:
Identify key areas of concern. Identify sites for the placing of the site notices. Attain a visual understanding of the project. Identify possible sites to undertake Focus Group Meeting / Public Meetings. Identify areas most impacted by the proposed development.
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The first step in the PP Process entailed the identification of key I&APs and Stakeholders, including:
Local and provincial government; Local businesses; Residents; Affected and neighbouring landowners; Environmental Non-Governmental Organisations; and Community Based Organisations.
An I&AP Database was compiled which has been maintained and updated throughout the duration of the BA process.
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I&AP DATABASE
First Name Last Name Company/Organisation Postal Address Telephone E-mail
Bheki Shongwe Tongaat Hulett Developments [email protected]
Cyril Gwala Tongaat Hulett Developments [email protected]
Rory Wilkinson Tongaat Hulett Developments [email protected]
Musa Shabane Tongaat Hulett Developments [email protected]
Mtura Matshini Tongaat Hulett Developments [email protected]
Karen Petersen Tongaat Hulett Developments [email protected]
Manisha Maharaj DWA [email protected]
Miss Modise DAFF [email protected]
Roy Ryan DoT 033 355 8600 [email protected]
Dominic Wieners KZN Wildlife [email protected]
Weziwe Tshabalala Amafa [email protected]
Sello Mokhaya Amafa [email protected]
Carolyn Schwegmann WESSA [email protected]
Adrian Coreejes South African Sugar Association [email protected] South African Sugar Research Private Bag X02, Mount
Carolyn Baker Institute Edgecombe, 4300 031 508 7404 [email protected]
Stephan Michaux Penny Pinchers [email protected]
Lingum Nayager Mount Edgecombe Virgin Active [email protected]
ZE Van Grenning Kempster Ford Umhlanga [email protected]
Deborag Kisten Fiat and Alfa Umhlanga [email protected]
R Nortje SPAR Mount Edgecombe [email protected]
B Cole Auto Umhlanga [email protected]
R Pillay Engen Island Park [email protected]
Tasnim Arbee Softline & Pastel VIP [email protected]
Elaine W Softline & Pastel VIP [email protected]
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First Name Last Name Company/Organisation Postal Address Telephone E-mail
R Conradt Tony Watson [email protected]
Diane van Rensburg eThekwini Municipality [email protected] Cllr Heinz de Boer Umhlanga Cllr [email protected] Mount Edgecombe Cllr (Riona Cllr Musa Dludla Gokool PA) [email protected] PO Box 20708, Durban North,
Sarah Kennedy Mt Edgecombe Stables 4016 031 564 8109 [email protected]
Claire Bustridge Mt Edgecombe Stables [email protected] Muhammad 24 Glenmore Cres, Durban
Ismail Omar North, 4051 [email protected]
Leroy White Flanders Aggregate [email protected]
K Pillay Engen Island Park 89 Flanders Drive [email protected]
Martin Koekemoer SMEC SA [email protected]
Nathan Iyer Iyer Urban Design Studio [email protected]
Paul Hauntermann Flanders Aggregate [email protected] Isabelle Luker Resident Mount Edgecombe
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3 NOTIFICATION OF PROCESS SEPERATION
Following the rejection of the Environmental Scoping Report by the KZN DAEA Pollution and Waste Management Branch, KZN DAEA was consulted and it was decided that the EIA and Waste Management Licence Application Processes should be separated. I&APs were notified of this in writing. NOTIFICATION LETTER
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4 SITE NOTIFICATION
The NEMA EIA Regulations (2010) require that a site notice be fixed at a place conspicuous to the public at the boundary or on the fence of the site where the activity to which the application relates is to be undertaken and on any alternative sites. The purpose of this is to notify the public of the project and to invite the public to register as stakeholders and inform them of the PP Process. Royal HaskoningDHV (known at the time as SSI Environmental) erected site notices at various noticeable locations around the perimeter of the site. These included the fence to the existing Station and along the access road. SITE NOTICE
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PROOF OF SITE NOTICE
5 BACKGROUND INFORMATION DOCUMENT
A briefing paper or Background Information Document (BID) for the project was compiled in English. The aim of this document is to provide a brief outline of the application and the nature of the development. It is also aimed at providing preliminary details regarding the BA process, and explains how I&APs could become involved in the project. The briefing paper was distributed to all identified I&APs and stakeholders, together with a registration/comment sheet inviting I&APs to submit details of any issues, concerns or inputs they might have with regards to the project.
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BID & COMMENT FORM
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6 ADVERTISEMENT
In compliance with the EIA Regulations (2010), notification of the commencement of the EIA process for the project was advertised in a local newspaper, namely the Northglen News newspaper on 7 June 2013 I&APs were requested to register their interest in the project and become involved in the EIA process. The primary aim of these advertisements was to ensure that the widest group of I&APs possible was informed and invited to provide input and questions and comments on the project. I&APs were also notified of the availability of the draft Basic Assessment Report for public review and invited to attend the Public Meeting.
ADVERTISEMENT
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PROOF OF ADVERTISEMENT
7 PUBLIC MEETING
The primary aim of the public meeting was to:
provide I&APs and stakeholders with information regarding the proposed project and associated infrastructure; provide I&APs and stakeholders with information regarding the BA process; provide an opportunity for I&APs and stakeholders to seek clarity on the project; record issues and concerns raised; and provide a forum for interaction with the project team.
A public meeting was held on the 13th of June 2013 at 17h30 at the Mount Edgecombe Country Club, Weaver’s Nest Room.
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PRESENTATION SLIDES
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MINUTES OF THE MEETING
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PROOF OF MEETING
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MEETING REGISTER
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8 PUBLIC REVIEW OF THE BA Report
The draft BAR was made available for authority and public review for a total of 40 days from 6 June 2013 to 15 July 2013. In addition, the report was made available at the following public locations within the study area, which are all readily accessible to I&APs:
Mount Edgecombe Country Club; Tongaat Hulett Developments: 305 Umhlanga Rocks Drive, La Lucia; and Royal HaskoningDHV Website: www.rhdhv.co.za
I&APs were then notified of the availability of the final EIAR for public review for a period of 21 days prior to submission to the KZN DAEA.
9 ISSUES TRAIL
Issues and concerns raised during the public participation process have been compiled into an Issues Trail presented in a Comment and Responses Report. The Issues Trail to date has been attached as Appendix A, in which all comments received and responses provided have been captured. This report includes all correspondence received from I&APs to date.
10 WASTE MANAGEMENT LICENCE
On receipt of WML (positive or negative) for the project, I&APs registered on the project database will be informed of this authorisation and its associated terms and conditions by correspondence and advertisement.
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APPENDIX A: COMMENTS & RESPONSES REPORT
Comments and Responses Report – Issues Trail as part of the Public Participation Process for the Mount Edgecombe Refuse Transfer Station Relocation A Report for the BA Process: DM/WML/0041/2012
Updated August 2013
DOCUMENT DESCRIPTION
Client: Tongaat Hulett Developments
Project Name: Waste Management License Application for the Proposed Relocation of the Mount Edgecombe Refuse Transfer Station
Royal HaskoningDHV Reference Number: E02.DUR.000484
Authority Reference Number: DM/0034/2012 and KZN/EIA/0000802/2012
Compiled by: Humayrah Bassa
Date: 8 August 2013
Location: Durban
Review: Prashika Reddy
Approval: Malcolm Roods
© Royal HaskoningDHV All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, without the written permission from Royal HaskoningDHV
PURPOSE OF THE DOCUMENT
Public participation is a process that is designed to enable all interested and affected parties (I&APs) to voice their opinion and/ or concerns which enables the practitioner to evaluate all aspects of the proposed development, with the objective of improving the project by maximising its benefits while minimising its adverse effects. I&APs include all interested stakeholders, technical specialists, and the various relevant organs of state who work together to produce better decisions. A comprehensive public participation process has been undertake as part of the Basic Assessment process for the proposed Mount Edgecombe Refuse Transfer Station Relocation in support of the Waste Management Licence Application and a summary of the issues raised and responses in relation to these issues is provided in this Issues Trail. This Issues Trail provides a summary of concerns raised by I&APs. A full record of the public participation process and stakeholder / I&AP correspondence is available at Royal HaskoningDHV offices. The issues have been arranged into groups of similar issues, and are listed within each group in the date order in which they were received. The name, affiliation and date of the commentator are also indicated.
Table of Contents
1. WETLANDS, ECOLOGY AND FORESTS ...... 1 2. EIA PROCESS ...... 6 3. LAND USE, PLANNING AND SERVICES ...... 7 4. WASTE ...... 10 5. GEOLOGY, SOILS AND TOPOGRAPHY ...... 13 6. HEALTH AND SAFETY ...... 14 7. HERITAGE ...... 15 8. STORMWATER MANAGEMENT ...... 17 9. WATER RESOURCE MANAGEMENT...... 17 11. ECONOMIC DEVELOPMENT ...... 20 10. ELECTRICITY ...... 20 11. ACCESS ...... 21
List of Appendices Appendix A: Comments Received and I&AP Correspondence Issues Trail for the Mount Edgecombe Refuse Transfer Station Relocation August 2013
ISSUE/COMMENT RAISED BY RESPONSE
1. WETLANDS, ECOLOGY AND FORESTS
It is acknowledged that the preferred and alternative sites for the Jabulani Hlophe, Ezemvelo Many thanks for the comments which are noted and proposed waste transfer station are located outside the 30m KZN Wildlife are being addressed. As discussed with Ezemvelo wetland buffer. The proposed construction of an access road to 23.07.13 KZN Wildlife, the access road (all infrastructural either site which will require traversing the watercourses namely requirements) for the Mount Edgecombe Refuse wetlands, drainage line etc. (BAR, Alternative S1_Preferred, Page Transfer Station is being assessed as part of the 10) is a concern. Cornubia Retail Park Development EIA. The BAR is in support of the Waste Management Licence The lack of details regarding the design and nature of the proposed Application and addresses waste specific access road crossing over the watercourse is of concern to requirements. Ezemvelo. Given that the Wetland Impact Assessment Report_ Sivest _Dated 19th December 2012_ Appendix D5 was undertaken It is acknowledged that the Wetland Assessment for the Cornubia Retail Development, it has not assessed the (Revision 3) presented in the draft EIAR and BAR specific impact of the proposed waste station transfer or access failed to assess the impacts of the access roads on road required, nor has appropriate mitigatory measures been the wetlands, however as stated, this has been identified with regards to watercourse crossing, makes it difficult for rectified in an updated report (revision 5.1) prepared Ezemvelo to make an informed decision on this application. by SiVEST and has been included in the Final EIAR and BAR. Ezemvelo KZN Wildlife has been notified Through our discussion with the EAP, Ezemvelo has been made of the submission of this Report and a further 21 aware that the road access impacts are being assessed in the days in which to comment on the final EIAR directly Cornubia Retail Park_ DM/0034/2012, which is being reviewed by to the KZN DAEA with a copy sent to the EAP. Ezemvelo. Given the above, Ezemvelo is not in a position to support this application in its current form as we cannot review it in isolation from the Cornubia Retail Park Development.
Please be informed that this correspondence therefore constitutes Ezemvelo preliminary comments only, as final comments will be
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Issues Trail for the Mount Edgecombe Refuse Transfer Station Relocation August 2013
ISSUE/COMMENT RAISED BY RESPONSE provided upon complete review of Cornubia Retail Park application by Ezemvelo. Should the department decide to grant an authorisation prior to Ezemvelo completing the review of Cornubia Retail Park, Ezemvelo kindly requests that the DRAFT Authorisation be provided for review. As indicated in the specialist study (Appendix D4, Cornubia Jabulani Hlophe, Ezemvelo According to the Vegetation Assessment presented, Vegetation Assessment_ 31 May 2013) part of the proposed site for KZN Wildlife most of this vegetation is alien invasive or exotic in the waste transfer station is located within the vegetation referred to 23.07.13 nature. However, there are a few occurrences of as Bush Clump1, (Green Polygon, SMEC_ Drawing No DH913-RP- indigenous vegetation for which licences/permits are DSW-Roads-01 dated 03/06/2013), and though disturbed by alien underway. Further to this, the remainder of Cornubia invasive plants infestation, it still comprises of indigenous trees of is proposed to be developed as part of the Cornubia conservation significance such as Scadoxus puniceus. Phase 2 development. The location of a suitable site Consequently where practical possible the site layout should be for the Mount Edgecombe Refuse Transfer Station realigned away from the dense vegetation, should this not be was restricted by the Cornubia Development feasible, a permit is required to remove or relocate special protected Framework Plan. However, suitable rehabilitation of plants (obtained via Durban District Conservation Officer- the wetland areas will be dealt with in greater detail 0312741150). in the Open Space and Wetland Rehabilitation Plan that is being compiled for the remainder of Cornubia Ezemvelo is supportive of the mitigation and rehabilitation measures (Phase 2 and the Retail Park). Permits will be proposed (Appendix D4, Cornubia Vegetation Assessment_ 31 May applied for where necessary. 2013_Section 5, Recommendations, Page 8) and therefore recommends that they be made conditions of the Environmental Authorisation. Although alternative S1 (preferred site) comprises of indigenous Department of Agriculture, This comment has been noted and alternative S1 is woody vegetation, invasive alien plant species are dominant on the Forestry and Fisheries the preferred option for the new facility. site. Given the above, the Department has no objections to the 17.07.13 activity as proposed and further recommends alternative S1 for construction of the refuse transfer station since it will have minimal
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Issues Trail for the Mount Edgecombe Refuse Transfer Station Relocation August 2013
ISSUE/COMMENT RAISED BY RESPONSE negative impacts. Comment in response to the BAR - The proposed development eThekwini Municipality – The comment is noted and it is further reiterated that must not have adverse impact on the flow regime habitat (physical Environmental Planning and the measures outlined in the Environmental structure and vegetation), biota and water quality of the Ohlanga Climate Protection Management Programme are recommended to River and estuary and any water resources in the vicinity of the Department reduce the risk of any negative impacts on water proposed development. 09.07.13 resources in the surrounding area. Comment in response to the BAR - The wetland report mentioned eThekwini Municipality – Please note that these comments are made based that the stormwater and sewer impacts will increase in the runoff Environmental Planning and on the current scenario, prior to any mitigation and or from impermeable surfaces and water quality will have a significant Climate Protection management thereof implemented. Thus these adverse impacts on the Ohlanga River. Department statements in the wetland report are made in the pre- 09.07.13 mitigation scenario. In the post-mitigation scenario these impacts will be reduced to acceptable levels. Mitigation measures include the implementation of a Stormwater Management Plan, low impact sewer routings and surcharge control measures. Therefore, once the rehabilitation of the wetlands and the stormwater management master plan has been implemented these impacts will be reduced to levels which are considered acceptable. There must be no contaminated water that enters the wetlands and Department of Water Affairs This is noted and stringent control measures have any water resource from the proposed facility. 29.07.13 been outlined in the Basic Assessment Report and Environmental Management Programme (EMPr). The buffer zone of 30 meters proposed by the wetland specialist Department of Water Affairs There will be no development within 30 meters of the must be adhered to by the applicant and no development must 29.07.13 wetlands for the Refuse Transfer Station except for occur within the proposed buffer zone. The loss of 2.96 ha of the access road realignment (Alternative S1). As wetlands is not supported especially wetland unit A7 since it will such, the 2.96 ha of wetland loss mentioned in the impact on marginal frog populations and bird habitat. A ratio of 1:3 initial Wetland Assessment Report (revision 3) is for and 1:4 must be employed by the applicant on Wetland Unit A5, A6, the loss of wetland for the Retail Park and is not
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ISSUE/COMMENT RAISED BY RESPONSE A7 and A8 to gain more than 2.96 ha of wetland loss. applicable to the Refuse Transfer Station. In the revised Report (revision 5.1) we see that 6 730 m2 of wetland will be lost for the realignment of the temporary access road. This has been included in the overall 3.54 ha of loss for the Cornubia Retail Park development and Mount Edgecombe Refuse Transfer Station relocation and an offset ratio of 1:3 has been used for which an integrated Water Use Licence Application is underway with the DWA. Due to the location of the proposed development to water resource, Department of Water Affairs There is no expected development in the vicinity of it is expected that there will be disturbances/destruction of 29.07.13 the Ohlanga River. However riparian habitats wetland/riparian areas occurring. pertaining to the wetlands will be impacted on. The The extent of damage must be minimised. comments have further been addressed and The banks adjacent to the construction site must be stabilised to mitigated in the Wetland Impact Report. prevent collapse and erosion. Increased sedimentation must be minimized as far as possible. Areas to be utilised by heavy machinery, etc must be clearly demarcated and a responsible person must be appointed to ensure that there is full compliance with the EMP. For the purpose of section 21(c) and (i) water use i.e. “impending or Department of Water Affairs As the development of Cornubia is not possible diverting the flow of water in a watercourse and altering the bed, 29.07.13 without some degree of wetland loss/ impacts, banks, course or characteristics of a watercourse” the watercourse wetland offsets are proposed as outlined in the encompasses the extent of (i) of the riparian habitat or the 1:100 wetland assessment presented in the EIA phase. year floodline, whichever is the greater or (ii) within 500m radius from the boundary of any wetland. An integrated Water Use Licence Application (iWULA) is currently underway for the remainder of The applicant must apply for a Water Use Licence under section Cornubia (Phase 2 and the Retail Park) for which a 21(c) and (i) of the National Water Act of 1998 (Act No 36 of 1998) detailed Wetland and Open Space Rehabilitation
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ISSUE/COMMENT RAISED BY RESPONSE “for impending or diverting the flow of a water in a watercourse and Plan is being compiled and will be submitted to the altering the bed, banks, course or characteristics of a watercourse” DWA. The entire professional team has already (wetlands infilling and sewer crossings) wetland rehabilitation. The engaged with the DWA at a Workshop held at THD realignment of the existing road which will require wetland (drainage to discuss the requirements for the iWULA for line) crossing also required a water use licence application. Cornubia on the 10th of June 2010. Minutes of this workshop are available on request from RHDHV. The following are the requirements of the license application required by this Department: Company registration/ certified ID of applicant Completed and signed water use forms Certified copies of property title deed for the property on which an activity will take place Civil design for all dams and river/wetland crossing Geotechnical study Stormwater Management Plan Wetland study (Functional Assessment) and Rehabilitation plan. Any wetlands on site must be delineated according to this Department’s guidelines entitled “A practical field procedure for identification and delineation of wetlands and riparian areas” (DWAF, 2005): Biomonitoring Monitoring programme for both surface and groundwater (full reports) R144 administration fee Proof of BBBEEE certificate/status considering to redress the results of past racial and gender discrimination according to Section 27 (1b) of National Water Act of 1998 (Act no 36 of 1998)
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ISSUE/COMMENT RAISED BY RESPONSE A detail Impact and Mitigation Measures on the receiving water resources in terms of quality and quantity. o RoD/ Exemption letter from Department Agriculture and Environmental Affairs and Rural Development o Adverts in the paper o Geohydrological study Layout maps The rehabilitation and monitoring plan of wetlands must contain the following information: o Rehabilitation objectives o Rehabilitation strategy o Rehabilitation design drawings and plan o Rehabilitation interventions o Final rehabilitations plans o Maintenance details o Construction notes
2. EIA PROCESS
WESSA will not be engaging further as an I&AP for this project, at WESSA This has been noted and WESSA has been removed this stage. 22.05.13 from the I&AP database as requested.
WESSA has actively engaged and contributed to EIA processes and related environmental authorisations in KwaZulu-Natal for over 15 years. In recent years, we have participated in an average of 400 individual projects per year. WESSA has sustained this level of participation in the absence of corresponding funding streams. After an internal review, WESSA decided to engage with EIA at a
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ISSUE/COMMENT RAISED BY RESPONSE strategic level rather than at an operational project-by-project level. This means engagement with EIA in the following ways: i) WESSA will focus on EIA capacity building through established WESSA training courses, ii) WESSA will continue to give input into the National Environmental Impact Assessment Management System (EIAMS) as a key monitoring process, and iii) WESSA will continue to guide strategic national processes through our presence on the Board of the Environmental Assessment Practitioners Association of South Africa. WESSA may continue to engage on EIA projects of national and strategic impact together with key partners in the sector. This includes seeking funding to support participation as far as possible, taking every opportunity to mobilise WESSA staff and partners in the regions in which WESSA has capacity.
3. LAND USE, PLANNING AND SERVICES
Reference is made to a number of correspondences and meetings Department of Agriculture & Noted. The Department of the Agriculture supports regarding the proposed development. For ease of reference such Environmental Affairs, Macro the development of Cornubia as an agreement is in previous correspondences have been attached to this report. Of Planning, Land Use place between Tongaat Hulett and this Department particular importance is that the Department had not supported the Regulatory Unit regarding an action plan for loss of agricultural land. proposed development attributed to the quality of agricultural 24.06.13 resources in the proposed land development area (Farm).
The Provincial Department of Agriculture has subsequently held a meeting with Tongaat Hulett on the 24th of May 2011 to discuss amongst other things the strategic current and future role of sugar cane production in Coastal belt of KwaZulu-Natal. Of grave concern was the exponential proportions with which sugar cane production
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ISSUE/COMMENT RAISED BY RESPONSE had been replaced by other alternative non-agricultural developments in specific areas of the Province, this has been an important question as it hinges on the sustainability of the continued production of this important commodity or enterprise within the province and its effect and the influence to the production of value chain. This meeting provided a platform for the Department to be appraised of current and future programs by the Tongaat Hulett Group which aims at investing on a further 32000 hectares of new cane development (Greenfield).
This is a deliberate and conscious investment decision by the Tongaat Group in the short to medium term to firstly mitigate against any possible loss in production whilst also creating opportunities and potential revenue base for emerging rural farmers.
At this meeting, the Department resolved that a strategic and holistic research study should be commissioned to research in depth the natural resources and the emerging landscape between Umhlanga and Ballito commercial centres. This study is further necessitated by the location of the Province’s Dube Trade Port which has been identified amongst others as the economic driver for the KwaZulu- Natal economic growth path. The Port is also seen as a strategic investment opportunity for both export and import of agricultural products.
Please be advised that the Provincial Department of Agriculture and Environmental Affairs, agriculture component has reviewed the report and has no objection to the Cornubia Retail Park
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ISSUE/COMMENT RAISED BY RESPONSE development following a number of meetings that this office had with Tongaat Hulett to release Cornubia from the provision of the Subdivision of Agricultural Land Act 70 of 1970. Comment in response to the Background Information Document - It eThekwini Municipality – This was noted and the proposed relocation was is noted that the proposed relocation of the waste transfer site is on Framework Planning Branch assessed further during the BAR where two land identified for residential and open space north of the proposed 11.09.12 alternative site options have been presented in the retail park. This Branch does not support the relocation within BAR. The preferred option is situated in area Cornubia as an option. It is preferred that the site developer retains earmarked for commercial land uses in the the waste transfer site located in an industrial area. It must be noted Framework Plan as outlined in the detailed Planning that the Cornubia development is intended for future short-term Assessment. implementation and in view of this, relocating the waste transfer site within vacant land in Cornubia is certainly not a suitable or desirable arrangement. Comment in response to the Environmental Scoping Report - The eThekwini Municipality – This comment has been noted. relocation of the waste transfer station site must not fall within any Environmental Planning and identified open space and the relocation must be to a final Climate Protection destination where there will be no need for further relocation. Department 07.11.12 Comment in response to the Environmental Scoping Report - It is eThekwini Municipality – The comment has been noted and a detailed noted that the proposed relocation of the waste transfer site is on Framework Planning Branch planning assessment of the new proposed sites has land identified for residential and open space north of the proposed 07.11.12 been undertaken and provided in the EIA Report as Retail Park. The exact location is unknown. This Branch reiterated well as the BAR to which this Department has its position as provided in the comment to the BID that it is not provided further comment noted below. supportive of the relocation of the waste transfer site within Cornubia as an option. It is preferred that the site developer considers having the waste transfer site located in an industrial area. It must be noted that the Cornubia development is intended for future short-term implementation and in view of this, relocating the waste transfer site within vacant land in Cornubia is certainly not a
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ISSUE/COMMENT RAISED BY RESPONSE suitable or desirable arrangement. It is further submitted that is the applicant is now regularizing the operation of the waste transfer site the application should be for an appropriately located site from this stage forward. Comment in response to the Environmental Impact Assessment eThekwini Municipality – This comment has been noted. Report - It is noted that a separate application is being done to Framework Planning Branch obtain a waste licence to operate a Waste Transfer site. It is further 26.06.13 noted that the proposed Waste Transfer Site shown in Section 2.10 of the report is aligned with the Cornubia Phase 2 Block Layout plan dated 8 May 2013. The proposed site as an option is supported. It is noted that the proposed Cornubia Retail Park Development falls within and aligns to the General Business land use identified within the Cornubia Framework Plan. Stakeholder queried the two choices for the new DSW Transfer Geoff Pullan Both sites presented are outside of the 30 m buffer to Station and wanted clarification if they were near to or have an 13.06.13 any wetlands and there will be no direct impacts. impact on any watercourses or wetlands? However, there may be the need for access roads which will traverse wetlands.
4. WASTE
Comment in response to the Background Information Document - eThekwini Municipality – Noted and further clarity has been provided in both Further clarity and detail is needed on whether the waste transfer Framework Planning Branch the EIA Report as well as the Basic Assessment site is a depot for garden refuse or includes other types of waste. 11.09.12 Report for the relocation of the Mount Edgecombe Further detail on who currently manages the site, the frequency of Refuse Transfer Station. The Mount Edgecombe removal of waste, whether noise, dust, odours and the like are Refuse Transfer Station provides for the collection generated is required. and storage of general waste (household and garden) which is compacted and sent to a landfill. Further detail is provided for in the separate Basic
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ISSUE/COMMENT RAISED BY RESPONSE Assessment as part of the Waste Management Licence (WML) application. The facility is managed by Durban Solid Waste. Comment in response to the Environmental Scoping Report - This eThekwini Municipality – Comments have been noted and DSW has since Department must agree to the new position and layout of the Durban Solid Waste granted their approval for the preferred site and Transfer Station prior to construction commencing. The existing 07.11.12 layout for the Mount Edgecombe Refuse Transfer Transfer Station must remain operation until the new Transfer Station (Appended to the BA Report). The existing Station is commissioned. station will remain in operation until the new station is commissioned. Comment in response to the Environmental Impact Assessment eThekwini Municipality – Comments have been noted and DSW has since Report - It must be clearly understood that the design of the new Durban Solid Waste granted their approval for the preferred site and transfer station has to be signed off by Durban Solid Waste and that 26.06.13 layout for the Mount Edgecombe Refuse Transfer the new facility needs to be operational prior to the existing station Station (Appended to the BA Report). being decommissioned i.e. all new equipment except where agreed by Durban Solid Waste. Comment in response to the Background Information Document - eThekwini Municipality – Noted and provided in the BAR and EMPr. Please This Department requests that the following information be Environmental Planning and refer to the BAR and EMPr for further details. provided: Climate Protection Specifically, please refer to the following Sections: A list of all the waste management listed activities being Department applied for; 24.05.13 Section 3 of the BAR; The types of waste to be stored and or treated in order to confirm the category of waste management license Section 2 of the BAR; required; A proposed site layout plan for the proposed facility and the Section 2 of the BAR and Appendix A & C associated infrastructures. This is needed to confirm if the proposal will not encroach into the open spaces. The layout plan must also be superimposed onto the Section 2 of the BAR and Appendix A & C Cornubia Framework Plan to confirm if the proposed facility
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ISSUE/COMMENT RAISED BY RESPONSE is in line with it. All potential impacts on the receiving environment must be Section E of the BAR; and assessed; An EMPr needs to be prepared. The EMPr must also include details on the management of effluent and leachate Section 6.32 of the EMPr. to be generated at the tipping area. Comment in response to the BAR - Page 17 and 19 of the eThekwini Municipality – This comment is noted. The word landfill has been Professional Waste Impact Statement Report dated May 2013 has Environmental Planning and changed to transfer station. made reference to the visual impacts of landfill operations; this must Climate Protection be clarified and/or rectified on the final BAR since the application is Department about a transfer station and not about a landfill. 09.07.13 Comment in response to the BAR - DSW supports this proposal, eThekwini Municipality – This comment is noted and DSW approval has been however, as this facility will be handed over to eThekwini, all Durban Solid Waste obtained. specifications must comply with Council standards and approval 09.07.13 must be received from the designated DSW technical representative prior to any construction or purchases taking place. Removal and disposal of solid waste (surplus of spoil material) to a Department of Water Affairs The comments have been noted and the permitted waste disposal site is required and this is the 29.07.13 recommendations included in the Environmental responsibility of the Applicant. Contaminated/ hazardous materials Management Programme (EMPr). are to be disposed of at a permitted hazardous landfill site that is authorised to accept such waste material. All waste generated at the proposed development should be disposed of in a suitable manner so as not to cause any surface and groundwater pollution or a health hazard. Should private contractors be used, all solid waste must be disposed of at a permitted landfill site and proof of this must be made available to this Department. Please note, that all waste material prior to being collected for safe disposal, must be stored under cover and within a designated waste collection/storage area.
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ISSUE/COMMENT RAISED BY RESPONSE Access control to this area must be properly managed. The recycling of suitable material (i.e. glass, paper, plastic, etc) is encouraged by this Department, provided it is properly managed.
5. GEOLOGY, SOILS AND TOPOGRAPHY
It is impossible to see any detail on site as the surrounding cane is eThekwini Municipality – A detailed Geotechnical Investigation has not been 2.5 m high and I could not get a decent elevated viewpoint from Geotechnical Engineering done for the new proposed sites. The overall across the hill. From the GIS, the converging/diverging contours of Branch Geotechnical Investigation for Cornubia has been that little valley head looks very much like a past slope movement 27.05.13 used as a guide and detailed investigations will be with a steep rear scarp and convex bulge on the lower slope. undertaken prior to construction as is the case for Modification of the lower slope by platforming for the DSW transfer other areas of Cornubia. A detailed Geotechnical station could reactivate the upper slope. It is quite possible that this Investigation will be carried out before the area would not have been specifically investigated as part of the construction of the bulk platforms, and a fill stability overall Cornubia geotechnical investigation; apart from the wide report compiled with recommendations on toe spread on test positions in a broad, general investigation, areas of treatments and stability analysis. This has been done bush are usually avoided until environmental clearance is given later only for the Cornubia Industrial & Business Estate to in the project. Ideally, a specific slope stability investigation should the north within the Cornubia Precinct. be carried out to determine if the slope is stable (the slope in question may be larger than just the DSW site) and if it can be developed economically should the slope require stabilisation. The potential slope movement may be outside the actual footprint of the DSW site, but modification of the lower slope could destabilise the upper slope, most definitely affecting the lower DSW portion. This department has a list of local, ‘approved’ geotechnical practitioners who have a proven track record in slope stability analysis as this is a very specialised field within overall geotech; this can be made available to the EAP.
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ISSUE/COMMENT RAISED BY RESPONSE Comment in response to the BAR - Provided a geotechnical eThekwini Municipality – Comment in response to the BAR - Provided a assessment is done of the DSW site and the steep slope above it, Geotechnical Engineering geotechnical assessment is done of the DSW site before commencing earthworks, this Department has no objection to Department and the steep slope above it, before commencing the development as proposed. 09.07.13 earthworks, this Department has no objection to the development as proposed.
6. HEALTH AND SAFETY
During construction and within the operational context of the new eThekwini Municipality – Comment is noted and the measures provided have refuse transfer station the following measures must be adhered to at Environmental Health been included in the Environmental Management all times: Department Programme as part of the Basic Assessment Provide a comprehensive report on the manner in which odour, 15.07.13 Process for the Mount Edgecombe Refuse Transfer dust and noise will be controlled and measured in regard to any Station. potential impacts on the township development. All waste generated from the deconstruction must be disposed of in accordance with the relevant legislative requirements – details of which must be kept and produced upon request. All vehicles traveling along the access roads must adhere to speed limits to avoid creating excessive dust, especially during dry and windy conditions. Mitigatory measures to reduce the potential environmental health impacts identified in the EMP must be strictly adhered to. The construction area must be cordoned-off and adequately sign-posted to prevent public access. Adequate ablution and wash-up facilities to be provided, made easily accessible to all workers and be serviced on a daily basis. The provision of adequate, wholesome supply of fresh drinking water to be made available to all staff on a daily basis.
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ISSUE/COMMENT RAISED BY RESPONSE All wastewater to be adequately channeled and disposed of in an approved manner. Records of oil spillages and action taken must be kept and made available for inspection. Results of any management monitoring and sampling programmes conducted in terms of dust, water and noise must be submitted to the Environmental Health office timeously. A complaint register and incident register must be kept on site and produced upon request. A first aid kit to be made available on site at all times. All operations on the transfer site must be managed in such a manner that it does not endanger the health, environment or cause a nuisance through noise, odour, dust or cause any visual impacts.
7. HERITAGE
Comment in response to the Environmental Impact Assessment AMAFA This comment is noted. There are no sites of cultural Report and Basic Assessment Report - We acknowledge receipt of 10.06.13 or heritage significance within the Cornubia Retail the Retail Park application and Mount Edgecombe Refuse Transfer 13.06.13 Park or the Mount Edgecombe Refuse Transfer Station application incorporating the HIA for the whole Cornubia Station sites. Should any object of heritage Mixed Development Area done by eThembeni in 2007 and identified significance be encountered during construction, four heritage resources: Two structures over 60 years, graves and construction will be halted immediately and a an archaeological site. qualified archaeologist will be requested to investigate the findings. AMAFA will then be notified. We note that the EIA Practitioner indicates that the Retail Park and Only once approval from AMAFA is obtained to sites for the Mount Edgecombe Refuse Transfer Station is not proceed will construction continue. located in the area where the Heritage Resources were noted in the
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ISSUE/COMMENT RAISED BY RESPONSE 2007 study. Mitigation of these four resources should be highlighted to the construction team and the ECO to ensure that they remain protected from accidental damage.
In view of the findings outlined in the HIA Report by Len Schalkwyk and Elizabeth Wahl (eThembeni Cultural Heritage) that we received for the above proposed development, in terms of KwaZulu-Natal Heritage Act No. 4 of 2008 and the National Heritage Resources Act No.25 of 1999 (Section 38 (1), we have no objection to the proposed development within limits of the prescribed mitigation measures and recommendations.
You are also required to adhere to the below-mentioned conditions: Amafa should be contacted if any heritage objects are identified during earthmoving activities and all development should cease until further notice. No structures older than sixty years or parts thereof are allowed to be demolished, altered or extended without a permit from Amafa. No activities are allowed within 50 m of a site which contains rock art. Amafa should be contacted if any graves are identified during construction and the following procedure is to be followed: o stop construction; o report finding to local police station; and o report to Amafa to investigate.
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8. STORMWATER MANAGEMENT
Clean and dirty areas must be separated. The runoff or stormwater Department of Water Affairs Noted. The SWMP report is to be amended to from the dirty areas must be treated as water containing waste and 29.07.13 address concerns regarding separation of clean & must not enter the stormwater system; further details on the dirty stormwater runoff areas. management of wastewater must be forwarded to this Department for comments. The stormwater drainage network system must be kept separate from the wastewater (water containing waste) system. These networks must be designed and constructed in such a manner that stormwater of a suitable quality will drain into the Municipal Stormwater System. After construction, the site should be contoured to ensure free flow of runoff and to prevent ponding of water. Drainage must be controlled to ensure that runoff from the site will not culminate in off-site pollution or result in damage to properties downstream of any stormwater discharge. The Stormwater Management Plan should ensure that the ultimate flow from the development does not result in any negative impacts on the watercourse and must therefore ensure that stormwater is managed within the overall site as effectively as possible.
9. WATER RESOURCE MANAGEMENT
The proposed development must not have adverse impact on the Department of Water Affairs Please note that these comments are made based flow regime habitat (physical structure and vegetation), biota and 29.07.13 on the current scenario, prior to any mitigation and or water quality of the Ohlanga River and estuary and any water management thereof implemented. Thus these resources in the vicinity of the proposed development. statements in the wetland report are made in the pre- mitigation scenario. In the post-mitigation scenario The wetland report mentioned that the stormwater and sewer these impacts will be reduced to acceptable levels.
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ISSUE/COMMENT RAISED BY RESPONSE impacts will increase in the runoff from impermeable surfaces and Mitigation measures include the implementation of a water quality will have a significant adverse impacts on the Ohlanga Stormwater Management Plan, low impact sewer River. routings and surcharge control measures. Therefore, once the rehabilitation of the wetlands and the stormwater management master plan has been implemented these impacts will be reduced to levels which are considered acceptable. There must be no unacceptable impact on the quality of both Department of Water Affairs The comment is noted and it is further noted that the surface and groundwater in the area and wetlands. If pollution of 29.07.13 measures outlined in the Environmental any surface or groundwater occurs, it must be immediately reported Management Programme are recommended to to this Department and the appropriate mitigation measure must be reduce the risk of any negative impacts on water employed. resources in the surrounding area. Stockpiling of soil or any other materials used during the Department of Water Affairs Preventative measures have been outlined in the construction phase must not be allowed on or near steep slopes, 29.07.13 Environmental Management Programme (EMPr). near a warehouse or water body. This is to prevent pollution or the impediment of surface runoff. Soil erosion on site must be prevented at all times i.e. pre-, during- Department of Water Affairs This comment is noted and suitable erosion control and post-construction activities. Erosion control measures to be 29.07.13 measures have been forwarded in the Environmental implemented in areas sensitive to erosion such as near water Management Programme (EMPr). supply points, edges of slopes, etc. These measures could include the use of sand bags, hessian sheets, retention or replacement of vegetation. All contaminated runoff (leachate) must be disposed of at a Department of Water Affairs Leachate control measures have been forwarded in wastewater treatment works and no leachate must be discharged 29.07.13 the Basic Assessment Report and Environmental into the water resource (wetlands). The applicant must put liners to Management Programme (EMPr). Leachate will be limit the potential of leachate from reaching surface and collected and disposed of site and will be restricted groundwater. Leachate collection systems must be installed above from entering any watercourses. the liner at the tipping areas.
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ISSUE/COMMENT RAISED BY RESPONSE The sewer manholes and chemical toilets must be situated out of Department of Water Affairs This is noted and has been included in the the wetlands, Ohlanga River and 1:100 year floodline and not 20 m 29.07.13 Environmental Management Programme (EMPr). as mentioned in the wetland report. The conditions and responsibilities contained in the draft EMP must Department of Water Affairs Comment has been noted. be strictly enforced. The final EMP must be submitted to this 29.07.13 Department for comment. Compliance to the approved EMP must be audited regularly by the designated Environmental Control Officer. No forms of secondary pollution should arise from the disposal of Department of Water Affairs Comment has been noted and included in the sewage and refuse. Any pollution problems arising from the above 29.07.13 Environmental Management Programme (EMPr). development is to be addressed immediately by the Applicant. Storage of material, chemicals, fuels, etc must not pose a risk to the Department of Water Affairs This comment is noted and suitable measures have surrounding environment and this includes surface and 29.07.13 been forwarded in the Environmental Management groundwater. Such storage areas must be located outside the 1:100 Programme (EMPr). year floodline of any watercourse and must be fenced to prevent unauthorised access into the area. Temporary bunds must also be constructed around chemical or fuel storage areas to contain possible spillages. The recommendations made by the Wetlands specialist, Drennan Department of Water Affairs This comment is noted and specialist Maud and Partners and SMEC must be adhered by the applicant. 29.07.13 recommendations have been included in the Environmental Management Programme (EMPr). The conditions of the permit issues by the Department of Water Department of Water Affairs This is noted. However, it is further noted that the Affairs, Permit Number 16/2/7/U202/D3/Z1/P505 must be adhered 29.07.13 conditions with regard to the rehabilitation of the to by the applicant. existing site once decommissioned are not relevant as the site will be prepared for the earthworks for the Further details on rehabilitation and future use of the facility Cornubia Retail Park development. (decommissioned) must be forwarded to this Department.
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ISSUE/COMMENT RAISED BY RESPONSE Spill Contingency or Emergency Response Plan must be drawn up Department of Water Affairs A Spill Contingency Plan has been included in the and should include the following actions that need to be taken into 29.07.13 Annexures to the EMPr as part of the THD Standard account in the event of a spill: Operating Procedures. Stop the source of the spill Contain the spill All significant spills must be reported to this Department and other relevant authorities Remove the spilled product for treatment or authorised disposal Determine if there is any soil, groundwater or other environmental impact If necessary, remedial action must be taken in consultation with this Department Incident must be documented
10. ECONOMIC DEVELOPMENT
Please note that we have no objection to the proposed relocation of eThekwini Municipality – This comment is noted. the Mount Edgecombe Refuse Transfer Station in order to facilitate Economic Development and the development of the Cornubia Retail Park. Investment Promotion Unit 09.07.13
11. ELECTRICITY
HV operations is not affected by this Proposal and the relocation of eThekwini Municipality – This comment is noted. the Refuse Facility. eThekwini Electricity 09.07.13
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12. ACCESS
Comment in response to the Basic Assessment Report in support of eThekwini Municipality A letter addressed to all I&APs clearly stipulates that the Waste Management Licence Application - Page 19-20 of the 09.07.13 the Waste Management Licence for the relocation of BAR has made reference to the need to realign existing roads for the Mount Edgecombe Refuse Transfer Station has use as temporal accesses to both the preferred as well as the been separated from the EIA process for the alternative site. The proposed temporary access roads on their own Cornubia Retail Park, however as the relocation of right are activities that require environmental authorisation due to the Mount Edgecombe Refuse Transfer Station the fact that they will be traversing some watercourses and will forms part of the Cornubia Retail Park Development therefore require a separate EIA application. intentions, all infrastructural requirements for the relocation of the Station will continue to be The watercourses which are to be traversed by the proposed addressed as part of this EIA application. Therefore, temporary access roads have already been set aside as open the access road has been applied for and is spaces on the approved Cornubia Framework Plan and must not be assessed as part of this EIA process and only the encroached onto. This department will therefore not support any waste licence requirements form part of the BA proposed temporary access roads across these areas. Process. As such, no further EIA processes will be required. In addition to the above, no other activities/ and or infrastructures will be supported within all open spaces and their buffers. The access road is required as at present, the district Recommendations outlined on the Environmental Management road which runs past the existing DSW transfer Programme with respect to all construction works in and around station will be cut off with the proposed bulk wetland areas and their buffers must be adhered to. This earthworks for the Retail Park. This road serves the recommendation is however not applicable to construction of the sugarcane farmers as well as the local community at proposed temporary access roads as these are not supported. Blackburn Village, and therefore the link needs to be retained.
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APPENDIX A: COMMENTS RECEIVED AND I&AP CORRESPONDENCE