Wild Coast Abalone Expansion

DRAFT SCOPING REPORT:

WILD COAST ABALONE EXPANSION

DRAFT Scoping Report

WILD COAST ABALONE EXPANSION, MARSHSTRAND, EASTERN CAPE

DEDEAT REF: TBC

DRAFT SCOPING REPORT

Prepared for:

Wild Coast Abalone (Pty) Ltd

Prepared by:

CES

EAST LONDON 39 Harewood Drive Nahoon, East London 043 726 7809

Also in Grahamstown, Port Elizabeth, Cape Town, Johannesburg and Maputo (Mozambique)

www.cesnet.co.za DECEMBER 2020

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REVISIONS TRACKING TABLE

CES Report Revision and Tracking Schedule Document Title: Wild Coast Abalone Facility Expansion

Client Name & Wild Coast Abalone (Pty) Ltd Address: Richard Clark Portion 1 Farm 259, Haga Haga, Eastern Cape

Status: Draft

Issue Date:

Lead Author: Caryn Clarke Robyn Thomson

Reviewer: Greer Hawley

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

DEDEAT 1 1 IAPs 1

Report Version Date 9 December 2020

This document has been prepared in accordance with the scope of CES’s appointment and contains intellectual property and proprietary information that is protected by copyright in favour of CES. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of CES. This document is prepared exclusively for use by CES’s client. CES accepts no liability for any use of this document other than by its client and only for the

purposes for which it was prepared. No person other than the client may [email protected] copy (in whole or in part) use or rely on the contents of this document, www.cesnet.co.za without the prior written permission of CES. The document is subject to all confidentiality, copyright and trade secrets rules, intellectual property law and practices of South Africa.

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TABLE OF CONTENTS

1 INTRODUCTION ...... 1

1.1 SCOPING REPORT REQUIREMENT CHECKLIST ...... 1 1.2 STRUCTURE OF THIS REPORT ...... 3 1.3 ASSUMPTIONS AND LIMITATIONS ...... 5 2 ENVIRONMENTAL ASSESSMENT PRACTIONER ...... 6

2.1 DETAILS OF THE EAP ...... 6 2.2 EXPERTISE OF THE PROJECT TEAM ...... 7 2.3 EAP DECLARATION ...... 8 3 PROPERTY DESCRIPTION AND ACTIVITY LOCATION ...... 9

3.1 PROJECT LOCATION ...... 9 3.2 PROPERTY DESCRIPTION...... 11 3.3 LAND OWNERSHIP ...... 11 3.4 SITE PHOTOS ...... 11 4 PROJECT DESCRIPTION ...... 12

4.1 BACKGROUND AND OVERVIEW OF THE WILD COAST ABALONE FACILITY ...... 12 4.2 PROPOSED EXPANSION ...... 12 4.2.1 CONSTRUCTION OF MANAGERIAL DWELLING UNITS AND ASSOCIATED SERVICE INFRASTRUCTURE 16 4.2.2 CONSTRUCTION OF A NEW PUMPHOUSE AND ADDITIONAL SEAWATER INLET AND OUTLET PIPELINES ...... 17 4.2.3 SERVICES INFRASTRUCTURE ...... 19 5 LEGISLATIVE REQUIREMENTS ...... 23

5.1 RELEVANT ENVIRONMENTAL LEGISLATION ...... 23 5.1.1 RELEVANT POLICY AND PLANS ...... 30 5.1.2 LISTED ACTIVITIES ...... 31 6 NEED AND DESIRABILITY ...... 38

7 ALTERNATIVES ...... 39

7.1 Types of alternatives ...... 39 7.1.1 FUNDAMENTAL ALTERNATIVES ...... 39 7.1.2 INCREMENTAL ALTERNATIVES ...... 40

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7.1.3 NO-GO ALTERNATIVE ...... 40 7.2 ALTERNATIVES ASSESSED FOR THE WILD COAST ABALONE FACILITY EXPANSION ...... 40 7.3 ALTERNATIVES FOR FURTHER ASSESSMENT ...... 49 8 PUBLIC PARTICIPATION ...... 50

8.1 SITE NOTICE ...... 50 8.2 NEWSPAPER ADVERTISEMENT ...... 50 8.3 I&AP AND STAKEHOLDER NOTIFICATIONS ...... 51 8.4 STAKEHOLDER IDENTIFICATION AND REGISTERED I&APS ...... 51 8.5 ISSUES RAISED BY I&APS ...... 52 9 DESCRIPTION OF THE ENVIRONMENT ...... 53

9.1 CLIMATE ...... 53 9.2 TOPOGRAPHY ...... 54 9.3 GEOLOGY AND SOILS ...... 56 9.4 HYDROLOGY ...... 58 9.4.1 SURFACE HYDROLOGY ...... 58 9.4.2 GROUNDWATER ...... 60 9.5 VEGETATION ...... 60 9.5.1 SA VEGMAP (MUCINA AND RUTHERFORD, 2018) ...... 60 9.5.2 FOREST CLASSIFICATION (NFA) ...... 63 9.6 FAUNA ...... 65 9.6.1 MAMMALS ...... 65 9.6.2 BIRDS ...... 65 9.6.3 AMPHIBIANS AND REPTILES ...... 65 9.7 LAND USE ...... 65 9.8 BIODIVERSITY CONSERVATION ...... 67 9.8.1 PROTECTED AREAS ...... 67 9.8.2 NEMBA THREATENED ECOSYSTEMS ...... 69 9.8.3 EASTERN CAPE BIODIVERSITY CONSERVATION PLAN (ECBCP) ...... 69 9.8.4 PLANT SPECIES OF CONSERVATION CONCERN ...... 74 9.8.5 ALIEN INVASIVE PLANT SPECIES ...... 75 9.8.6 GREAT KEI LOCAL MUNICIPALITY SPATIAL DEVELOPMENT FRAMEWORK (SDF) AND STRATEGIC ENVIRONMENTAL FRAMEWORK (SEA) ...... 75 9.9 SOCIO-ECONOMIC PROFILE ...... 76 9.9.1 POPULATION ...... 77 9.9.2 EMPLOYMENT ...... 77

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9.9.3 EDUCATION ...... 77 9.9.4 LIVING CONDITIONS ...... 77 10 PRELIMINARY SENSITIVITY ANALYSIS ...... 78

10.1 CONSERVATION AND SPATIAL PLANNING TOOLS ...... 78 10.1.1 NBA (2018) ECOSYSTEM THREAT STATUS ...... 78 10.1.2 LAND COVER ...... 78 10.1.3 RIVERS AND WETLANDS ...... 79 10.1.4 ECBCP CBA’S ...... 79 10.2 SENSITIVITY ALLOCATION ...... 79 11 IMPACT IDENTIFICATION AND PRELIMINARY ASSESSMENT ...... 83

11.1 PRELIMINARY IMPACTS IDENTIFIED ...... 83 11.2 PRELIMINARY IMPACT ASSESSMENT ...... 88 11.2.1 PLANNING AND DESIGN PHASE IMPACTS ...... 88 11.2.2 CONSTRUCTION PHASE IMPACTS ...... 91 11.2.3 OPERATION PHASE IMPACTS ...... 97 12 PLAN OF STUDY: EIA PHASE ...... 101

12.1 EIA PHASE ...... 101 12.2 ALTERNATIVES ...... 102 12.3 SPECIALIST STUDIES ...... 103 12.3.1 ECOLOGICAL IMPACT ASSESSMENT ...... 103 12.3.2 WETLAND AND AQUATIC IMPACT ASSESSMENT ...... 104 12.3.3 MARINE IMPACT ASSESSMENT ...... 104 12.3.4 BIOSECURITY RISK ASSESSMENT ...... 105 12.3.5 HERITAGE AND PALEONTOLOGICAL IMPACT ASSESSMENT ...... 105 12.3.6 SOCIO-ECONOMIC IMPACT ASSESSMENT ...... 106 12.3.7 SANITATION PROTOCOL ...... 107 12.3.8 STORMWATER MANAGEMENT PLAN ...... 107 12.4 PUBLIC PARTICIPATION PROCESS ...... 107 12.4.1 IDENTIFICATION OF AND CONSULTATION WITH KEY STAKEHOLDERS ...... 107 12.4.2 INTERESTED AND AFFECTED PARTIES DATABASE ...... 108 12.4.3 PUBLIC REVIEW OF THE DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT ...... 108 12.4.4 PUBLIC MEETINGS ...... 108 12.4.5 COMMENTS AND RESPONSE REPORT ...... 108 12.4.6 NOTIFICATION OF ENVIRONMENTAL AUTHORISATION (EA) AND APPEALS PROCESS ...... 108 12.5 ENVIRONMENTAL IMPACT REPORT (EIR) ...... 108

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12.6 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR) ...... 109 12.7 IMPACT ASSESSMENT METHODOLOGY ...... 110 13 RECOMMENDATIONS AND CONCLUSIONS ...... 113

13.1 SUMMARY OF PROJECT DESCRIPTION ...... 113 13.2 SUMMARY OF PRELIMINARY IMPACT ASSESSMENT ...... 113 13.3 FATAL FLAWS ...... 115 13.4 RECOMMENDATIONS ...... 115 14 REFERENCES ...... 116

15 APPENDICES ...... 117

APPENDIX A: CURRICULUM VITAE OF THE EAP ...... 118

APPENDIX B: PUBLIC PARTICIPATION PROOF ...... 125

APPENDIX B1: SITE NOTICE ...... 125

APPENDIX B2: COPY OF NEWSPAPER ADVERT ...... 128

APPENDIX B3: BACKGROUND INFORMATION DOCUMENT ...... 129

APPENDIX B4: COMMENTS AND RESPONSES TRAIL ...... 142

APPENDIX B5: PROOF OF NOTIFICATIONS, COMMENTS AND RESPONSES ...... 148

APPENDIX B6: AUTHORITY MEETING MINUTES/CORRESPONDENCE ...... 149

APPENDIX B7: I&AP DATABASE ...... 150

APPENDIX C: ADDITIONAL INFORMATION ...... 153

APPENDIX C1: MARINE SPECIALIST STUDY (2008) ...... 153

APPENDIX C2: EXISTING APPROVALS ...... 154

APPENDIX C3: GREAT KEI LOCALITY MUNICIPALITY STRATEGIC ENVIRONMENTAL ASSESSMENT (SEA) ...... 1

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LIST OF TABLES

Table 1-1: Requirements for the content of the Scoping Report as per Appendix 2 of the EIA Regulations (2014, as amended)...... 1 Table 3-1: Location of the activity...... 11 Table 3-2: Land owner details ...... 11 Table 4-1: Expansion parameters ...... 13 Table 5-1: Environmental legislation considered in the preparation of this report...... 23 Table 5-2: NEMA listed activities triggered by the proposed development ...... 31 Table 5-3: Additional licenses/permits required by the proposed development ...... 36 Table 7-1: Assessment of alternatives for the expansion of the existing Wild Coast Abalone Facility.41 Table 7-2: Alternatives to be assessed further during the EIA phase of the project...... 49 Table 9-1: ECBCP CBA Land Management Objectives (ECBCP Handbook, 2019) ...... 70 Table 9-2: Potential plant SCCs likely to occur within the study area ...... 74 Table 9-3: Potential alien invasive plants found within the study area ...... 75 Table 9-4: Summary of GKLM Environmental Guidelines for spatial planning ...... 76 Table 10-1: Sensitivity criteria...... 79 Table 10-2: Sensitivity assessment of the study area ...... 80 Table 11-1: Technical Scope of Issues identified during all phases of the proposed expansion of the Wild Coast Abalone Facility...... 84 Table 11-1-1: Planning and Design Phase Preliminary Impact Assessment ...... 88 Table 11-1-2: Construction Phase Preliminary Impact Assessment ...... 91 Table 11-3: Operation Phase Preliminary Impact Assessment ...... 97 Table 12-1: Ranking of Evaluation Criteria ...... 110 Table 12-2: Description of significance ratings ...... 112 Table 13-1: Summary of Preliminary Impact Assessment ...... 113

LIST OF FIGURES

Figure 3-1: Locality Map ...... 10 Figure 4-1: Site plan of the proposed expansion ...... 15 Figure 4-2: View of the location for the proposed housing units (looking north west) ...... 16 Figure 4-3: View of the location for the proposed housing units (looking south towards the facility and coast) ...... 17 Figure 4-4: Existing housing units on site...... 17 Figure 4-5: Existing seawater sump and pumphouse ...... 18 Figure 4-6: Existing seawater inlet pipeline lies 7m below the ground leading to the sump and pumphouse (left). Proposed location of new seawater inlet pipeline (right)...... 18 Figure 4-7: Existing discharge outlet channel (left). Proposed location of new discharge outlet channel (right)...... 19 Figure 4-8: Rainwater harvesting on site ...... 19 Figure 4-9: Existing seaweed paddle ponds on site used for bio-filtration of the abalone waste water...... 20

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Figure 4-10: General waste skip (left). Organic waste is temporarily stored in sealed drums (right) until collected by EnviroServ...... 21 Figure 4-11: Preliminary design of stormwater diversion (red lines reflect the location of proposed new earth swales, green line reflects the location of the existing earth swale)...... 22 Figure 7-1: Seawater inlet layout alternatives ...... 45 Figure 7-2: Discharge outlet channel layout alternatives ...... 47 Figure 9-1: Climate of Haga Haga (saexplorer, 2019)...... 53 Figure 9-2: Elevation profile of the study area, showing the north-south profile (top image) and diagonal profile (bottom image)...... 54 Figure 9-3: Topographical map of the study area ...... 55 Figure 9-4: Underlying geology of the study area...... 57 Figure 9-5: Hydrology map of the study area ...... 59 Figure 9-6: SANBI vegetation map of the study area ...... 62 Figure 9-7: Forest patches within the broader study area ...... 64 Figure 9-8: Land use map of the study area ...... 66 Figure 9-11: Protected areas map of the study area ...... 69 Figure 9-12: ECBCP Terrestrial CBA Map of the study area ...... 72 Figure 9-13 ECBCP Aquatic CBA Map of the study area ...... 73 Figure 110-1: Preliminary Sensitivity Map ...... 82

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LIST OF ACRONYMS

The following acronyms have been used in this report:

ADM Amathole District Municipality BID Background Information Document BAR Basic Assessment Report CA Competent Authority CARA Conservation of Agricultural Resources Act CBA Critical Biodiversity Area CR Critically endangered DAFF Department of Agriculture, Forestry and Fisheries DEA Department of Environmental Affairs DEFF Department of Environmental Affairs, Forestry and Fisheries DSR Draft Scoping Report DWS Department of Water and Sanitation EA Environmental Authorisation EAP Environmental Assessment Practitioner EAPSA Environmental Assessment Practitioners of South Africa ECO Environmental Control Officer ECPTA Eastern Cape Parks and Tourism Agency ECPHRA Eastern Cape Provincial Heritage Resources Authority EIA Environmental Impact Assessment EMPr Environmental Management Programme EN Endangered GKLM Great Kei Local Municipality GN Government Notice ha Hectares HIA Heritage Impact Assessment ICMA Integrated Coastal Management Act IDP Integrated Development Plan I&AP Interested and Affected Party l litres m3 Cubic meters MEC Member of the Executive Council MLRA Marine Living Resources Act MPA Marine Protected Area NEMA National Environmental Management Act NEM:BA National Environment Management: Biodiversity Act NEMPAA National Environmental Management: Protected Areas Act NEM:WA National Environmental Management Waste Act NFEPA National Freshwater Ecosystem Priority Area NDP National Development Plan NWA National Water Act OHSA Occupational Health and Safety Act PoS Pan of Study PPP Public Participation Process RDB Red Data Book PNECO Provincial Nature and Environmental Conservation Ordinance SACNASP South African Council for Natural Scientific Professions SAHRA South African Heritage Resources Agency SANBI South African National Biodiversity Institute

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SDF Spatial Development Framework SEA Strategic Environmental Assessment SCC Species of Conservation Concern SG Surveyor General SIA Social Impact Assessment SOER State of Environment Reporting SPLUMA Spatial Planning and Land Use Management Act VU Vulnerable WHS World Heritage Site WULA Water Use License Application

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1 INTRODUCTION

1.1 SCOPING REPORT REQUIREMENT CHECKLIST This report is based on the content requirements for a Scoping Report as listed in Appendix 2, Section 2 (1), of the EIA Regulations (2014, as amended) (

Table 1-1 below).

Table 1-1: Requirements for the content of the Scoping Report as per Appendix 2 of the EIA Regulations (2014, as amended). Relevant Section in Requirement Description Relevant Section in This Report GN R 326 (i) The EAP who prepared the report; and Please refer to Chapter 2 (a) Details of- (ii) The expertise of the EAP, including a Please refer to Chapter 2, and curriculum vitae; Appendix A. (i) The 21-digit Surveyor General code of each cadastral land parcel; (b) The location of (ii) Where available, the physical address and the activity, farm name; Please refer to Chapter 3 including- (iii) Where the required information in items (i) and (ii) is not available, the coordinates of the boundary of the property or properties; (c) A plan which (i) A linear activity, a description and coordinates locates the of the corridor in which the proposed activity or proposed activity or activities is to be undertaken; or Please refer to Figure 3-1 within activities applied for (ii) On land where the property has not been Chapter 3 at an appropriate defined, the coordinates within which the activity scale is to be undertaken; Please refer to Chapter 5, (d) A description of (i) All listed and specified activities triggered; Section 5.1.2 the scope of the (ii) A description of the activities to be proposed activity, undertaken, including associated structures and Please refer to Chapter 4 including infrastructure; A description of the policy and legislative context within which the development is proposed including an identification of all legislation, policies, plans, guidelines, spatial tools, municipal (e) Please refer to Chapter 5 development planning frameworks and instruments that are applicable to this activity and are to be considered in the assessment process A motivation for the need and desirability for the proposed development including the need and (f) Please refer to Chapter 6 desirability of the activity in the context of the preferred location (g) A full description (i) Details of all the alternatives considered; Please refer to Chapter 7 of the process (ii) Details of the public participation process followed to reach undertaken in terms of regulation 41 of the the proposed Regulations, including copies of the supporting Please refer to Chapter 8 and preferred activity, documents and inputs; Appendix B. site and (iii) A summary of the issues raised by interested location of the and affected parties, and an indication of the

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Relevant Section in Requirement Description Relevant Section in This Report GN R 326 development manner in which the issues were incorporated, or footprint within the the reasons for not including them; site, including - (iv) The environmental attributes associated with the alternatives focusing on the geographical, Please refer to Chapter 9 physical, biological, social, economic, heritage and cultural aspects; (v) The impacts and risks which have informed the identification of each alternative, including the nature, significance, consequence, extent, duration and probability of such identified impacts, including the degree to which these Please refer to Chapters 10 and impacts- 11 (aa) Can be reversed; (bb) May cause irreplaceable loss of resources; and (cc) Can be avoided, managed or mitigated; (vi) The methodology used in identifying and ranking the nature, significance, consequences, Please refer to Chapter 12, extent, duration and probability of potential Section 12.7 environmental impacts and risks associated with the alternatives; (vii) Positive and negative impacts that the proposed activity and alternatives will have on the environment and on the community that may Please refer to Chapter 12 be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects; (viii) The possible mitigation measures that could Please refer to Chapter 12 be applied and level of residual risk; (ix) The outcome of the site selection matrix; Please refer to Chapter 7 (x) If no alternatives, including alternative locations for the activity were investigated, the Please refer to Chapter 7 motivation for not considering such and (xi) A concluding statement indicating the preferred alternatives, including preferred Please refer to Chapter 7 location of the activity; (i) A description of the alternatives to be considered and assessed within the preferred Please refer to Chapter 12, site, including the option of not proceeding with Section 12.2 the activity; (ii) A description of the aspects to be assessed as (h) a plan of study part of the environmental impact assessment for undertaking the process; environmental (iii) Aspects to be assessed by specialists; impact assessment (iv) A description of the proposed method of Please refer to Chapter 12 process to be assessing the environmental aspects, including undertaken, aspects to be assessed by specialists; including (v) A description of the proposed method of assessing duration and significance; (vi) An indication of the stages at which the Please refer to Chapter 7 and competent authority will be consulted Chapter 12, Section 12.4. (vii) Particulars of the public participation process

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Relevant Section in Requirement Description Relevant Section in This Report GN R 326 that will be conducted during the environmental impact assessment process; and (viii) A description of the tasks that will be undertaken as part of the environmental impact Please refer to Chapter 12 assessment process; (ix) Identify suitable measures to avoid, mitigate or manage identified impacts and to determine Please refer to Chapter 11 and the extent of the residual risks that need to be Chapter 12 managed and monitored. (i) The correctness of the information provided in the report; (i) an undertaking under oath or (ii) The inclusion of comments and inputs from affirmation by the stakeholders and interested and affected parties; Please refer to Chapter 2 EAP in relation to - (iii) Any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested or affected parties; An undertaking under oath or affirmation by the EAP in relation to the level of agreement between Please refer to Chapter 2, (j) the EAP and interested and affected parties on Section 2.3, and Appendix A. the plan of study for undertaking the environmental impact assessment; No specific information has Where applicable, any specific information (k) been requested by the authority required by the competent authority; and to date. Any other matter required in terms of section (l) Not Applicable. 24(4) (a) and (b) of the Act.

1.2 STRUCTURE OF THIS REPORT

The structure of this report is as follows:

Chapter 2 – The Environmental Assessment Practitioner The details of the environmental assessment practitioner (EAP) and project team are provided within this chapter.

Chapter 3 – Property Description and Activity Location This chapter provides a description of the properties on which the development is to be undertaken, the associated land ownership of these properties, and the location of the development on the property.

Chapter 4 – Project Description This chapter provides a description of the technical details of the proposed aquaponics development. The associated bulk infrastructure requirements are also explained.

Chapter 5 – Legislative Requirements The motivation for the proposed aquaponics development is provided within this chapter.

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Chapter 6 – Need and Desirability This chapter provides a description of the fundamental and incremental alternatives to be assessed further during the EIA process.

Chapter 7 – Alternatives This chapter identifies all the legislation and guidelines that have been considered in the preparation of this DSR and outlines the listed activities triggered by the proposed development.

Chapter 8 – Public Participation This chapter provides an outline of the Public Participation Process (PPP) conducted in terms of Section 41 of the EIA Regulations (2014, as amended).

Chapter 9 – Description of the Environment This chapter provides a brief overview of the biophysical and socio-economic characteristics of the site and its environs that may be affected by the proposed development, compiled largely from published information, but supplemented by information from the initial site visit.

Chapter 10 – Sensitivity Analysis This chapter provides the overall sensitivity rating of the application and broader study area, and visually represents this in a sensitivity map.

Chapter 11 – Impact Identification and Preliminary Assessment This chapter provides a description of the methodology used in identifying and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks, as well as a description of the key issues that have been identified, which will be assessed further in the EIA phase.

Chapter 12 – Plan of Study: Environmental Impact Assessment Phase This chapter sets out the proposed approach to the EIA including: • A description of the scope of work that will be undertaken as part of the EIA phase, including any specialist reports or specialised processes, and the manner in which the described scope of work will be undertaken; • An indication of the stages at which the competent authority will be consulted; • A description of the proposed methodology for assessing the environmental issues and alternatives, including the option of not proceeding with the proposed development; • Particulars of the PPP that will be conducted during the EIA phase; and • Any specific information required by the authority.

Chapter 13 – Recommendations and Conclusions This chapter provides a brief summary of the proposed development and outlines recommendations for the proposed way forward.

Appendices

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The appendices contain all supporting and supplementary information.

1.3 ASSUMPTIONS AND LIMITATIONS

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

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

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2 ENVIRONMENTAL ASSESSMENT PRACTIONER

According to Appendix 2, Section 2 (1), of the EIA Regulations (2014, as amended), a “scoping report must contain the information that is necessary for a proper understanding of the process, informing all preferred alternatives, including location alternatives, the scope of the assessment, and the consultation process to be undertaken through the environmental impact assessment process, and must include—

(a) details of – (i) the EAP who prepared the report; and (ii) the expertise of the EAP, including a curriculum vitae”

In fulfilment of the above-mentioned legislative requirements, the details of the EAP that prepared this DSR, as well as the expertise of the individual members of the study team, are provided in the sections below.

2.1 DETAILS OF THE EAP

CES has been appointed by Wild Coast Abalone (Pty) Ltd, as the independent EAP to apply for an Environmental Authorisation (EA) for the proposed expansion of the existing abalone facility within the Great Kei Local Municipality (GKLM) of the Eastern Cape Province.

EAP: Dr Alan Carter Pr.Sci.Nat and registered with EAPASA Company: CES Address: 39 Harewood Drive, Nahoon, East London, 5241 Telephone: +27 (87) 830 9800 Fax: +27 86 410 7822 Email: [email protected] Website: www.cesnet.co.za

Dr Alan Carter – Executive Alan is the executive of the CES East London Office. He holds a PhD in Marine Biology and is a Certified Public Accountant, with extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He has 25 years’ experience in environmental management and has specialist skills in sanitation, coastal environments and industrial waste. Dr Carter is registered as a Professional Natural Scientist under the South African Council for Natural Scientific Professions (SACNASP). He is also registered as an EAP with the Environmental Assessment Practitioners of South Africa (EAPSA) interim EAP certification body. Alan will assume the role of project leader and report reviewer.

Please find the CV and proof of SACNASP and EAPASA registration in Appendix A

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2.2 EXPERTISE OF THE PROJECT TEAM

CES was established in 1990 as a specialist environmental consulting company and has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, State of Environment Reporting (SOER), Integrated Waste Management Plans (IWMP), Environmental Management Programme (EMPr), Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) processes. CES has been active in all of the above fields, and in so doing have made a positive contribution towards environmental management and sustainable development in the Eastern Cape, South Africa and many other African countries. We believe that a balance between development and environmental protection can be achieved by skilful, considerate and careful planning.

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

Ms Caryn Clarke – Senior Environmental Consultant (Report Writer) Caryn holds a M.Sc. Environmental Science (2012), B.Sc. Hon. Environmental Science, and a B.Sc. Environmental Science and Economics (2009) from Rhodes University. Her M.Sc. thesis was titled “Responses to the linked stressors of Climate Change and HIV/AIDS amongst vulnerable rural households in the Eastern Cape, South Africa”. Her B.Sc. Hon. thesis investigated climate change perceptions, drought responses and views on carbon farming amongst commercial livestock and game farmers within the Great Fish River Valley, Eastern Cape, from which a paper was published in the African Journal of Range and Forage Science 2012, 29(1):13-23. Caryn has further completed a Carbon Footprint Analysis Course (2013). Caryn’s expertise includes project management, environmental impact assessments including public participation, environmental compliance monitoring, various licensing and permit applications, feasibility assessments and GIS mapping. Caryn is a registered Candidate Natural Scientist under SACNASP.

Ms Robyn Thomson – Senior Environmental Consultant (Report Writer) Robyn is a Senior Environmental Consultant and holds a BSc (Environmental Science) degree with majors in Archaeology, Environmental and Geographical Science, as well as a BSc (Hons.) in Environmental Science, with coursework in Environmental Management, Environmental Impact

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Assessment, Environmental Risk Assessment, Environmental Contamination Rehabilitation, Geographic Information Systems and fundamentals in Statistics. The Honours programme also entailed a research project, which looked at the effectiveness of the community awareness programme conducted by the Asbestos Interest Group (AIG) on the effects of and attitudes towards asbestos contamination in two rural communities, Heuningvlei and Ga-Mopedi respectively, in the Northern Cape Province. The research project formed part of a larger project quantifying the extent of secondary environmental asbestos contamination in South Africa. Robyn obtained her undergraduate degree at the University of Cape Town, and her Honours degree at Rhodes University. Robyn has 15 years of experience and expertise in Basic Assessments, Environmental Impact Assessments, Environmental Monitoring, Environmental Management Plans, Water Use Licencing, public participation, GIS and project coordination. Robyn has particularly strong experience in infrastructure projects for various municipal, provincial and national organisations. Robyn is registered with Environmental Assessment Practitioner South Africa (Interim Certification Board) as an Environmental Assessment Practitioner.

2.3 EAP DECLARATION

I, Dr. Alan Robert Carter, declare that:

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

Signature of EAP:

Name of company: Coastal and Environmental Services (trading as CES)

Date: 24 November 2020

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3 PROPERTY DESCRIPTION AND ACTIVITY LOCATION

According to Appendix 2, Section 2 (1), EIA Regulations 2014 (as amended), a “scoping report must contain the information that is necessary for a proper understanding of the process, informing all preferred alternatives, including location alternatives, the scope of the assessment, and the consultation process to be undertaken through the environmental impact assessment process, and must include—

(b) the location of the activity, including – (i) the 21-digit Surveyor General code of each cadastral land parcel; (ii) where available, the physical address and farm name; (iii) where the required information in items (i) and (ii) is not available, the coordinates of the boundary of the property or properties; (c) a plan which locates the proposed activity or activities applied for at an appropriate scale, or, if it is— (ii) on land where the property has not been defined, the coordinates within which the activity is to be undertaken.

The following section provides information on the general location of the proposed development as well as more detailed information regarding the land ownership within and surrounding the application area.

3.1 PROJECT LOCATION

The proposed expansion of the existing Wild Coast Abalone facility is located on the coastline between Marshstrand and Fish Bay, within the Great Kei Local Municipality (GKLM) and the Amathole District Municipality (ADM), in the Eastern Cape Province.

Marshstrand is a small coastal village in close proximity to Haga Haga and Double Mouth. The Wild Coast Abalone property is bordered by the town of Marshstrand in the south-west, Fish Bay to the north east, and farms to the north and west. The Indian Ocean forms the south-east border.

Figure 3-1 below provides the location of the proposed activity.

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Figure 3-1: Locality Map

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3.2 PROPERTY DESCRIPTION

The existing Wild Coast Abalone Facility is located on Portion 1 of Farm 259, Haga Haga, Eastern Cape Province. Table 3-1 below provides the property details of the proposed expansion.

Table 3-1: Location of the activity Farm name Address 21- digit Surveyor General code Farm 459 Haga Haga, 5272 C04000000000045900000 Portion 1 of Farm 259 Hag Haga, 5272 C04000000000025900001 Farm 108 Haga Haga, 5272 C04000000000010800000 Farm 456 Haga Haga, 5272 C04000000000045600000

3.3 LAND OWNERSHIP

Table 3-2 below details the landowner information for the applicable farm portions affected by the proposed expansion of the existing Wild Coast Abalone facility. Refer to Appendix B7 for copies of the landowner consent forms and Windeed proof of ownership.

Table 3-2: Land owner details ACTIVITY FARM LAND OWNERSHIP

Expansion of the existing abalone processing - Portion 1 of - Wild Coast Abalone (Pty) plant, construction of a new pumphouse, and Farm 259 Ltd associated service infrastructure (roads and pipelines).

Addition of abalone and seaweed culturing - Farm 459 - Latrodex (Pty) Ltd ponds, workshops, feed store, processing plant, and the construction of managerial dwelling units and associated service infrastructure (internal roads, water and sewage reticulation, septic tanks).

Additional seawater inlet and outlet - Farm 108 - State-owned land: structures (seawater abstraction and managed by Eastern discharge channel). Cape Parks and Tourism Agency (ECPTA) - Stormwater Attenuation dam - Farm 456 - Latrodex (Pty) Ltd

3.4 SITE PHOTOS

Photos of the existing facility and proposed expansion have been included in Chapter 4 below.

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4 PROJECT DESCRIPTION

(d) a description of the scope of the proposed activity, including— (ii) a description of the activities to be undertaken, including associated structures and infrastructure.

The following section provides background information regarding the existing Wild Coast Abalone facility as well as a more detailed description of the proposed development and the associated activities and infrastructure involved. 4.1 BACKGROUND AND OVERVIEW OF THE WILD COAST ABALONE FACILITY

The Wild Coast Abalone farm was established in 1998 after the original environmental authorisation was granted. The facility was granted authorisation for expansion in 2008. Due to a further increase in demand for these high value products, the applicant, Wild Coast Abalone (Pty) Ltd, is proposing an additional expansion to the existing abalone facility.

The existing facility produces abalone (mostly known locally as perlemoen), specifically Haliotis midae, which is one of five South African endemic abalone species. The facility exports both live and dried abalone. In addition to abalone, the facility also plans to diversify into the production of other indigenous marine species, such as (but not limited to), rock lobster and sea cucumbers (Holothuria scabra).

The existing facility makes use of a flow-through system, where natural seawater is continuously pumped through the facility, and is released back into the marine environment as treated effluent water. The incoming natural seawater is filtered to remove suspended solids prior to being circulated into various abalone tanks. Thereafter, it is circulated to the seaweed paddle ponds for settling and removal of nutrients from feeds. The effluent passes through an anchovy netting filter prior to being released, via an open discharge channel along the rocky shore, into the coastal waters.

The seaweed paddle ponds also function as a source of feed for the abalone. A mixed feeding regime is implemented at the facility where both artificial feed and seaweed (Ulva spp. and Gracilaria verrucosa), cultured in the seaweed paddle ponds, are used.

A description of the proposed expansion is detailed below. 4.2 PROPOSED EXPANSION

The expansion of the existing Wild Coast Abalone facility will result in an increase in abalone production from 350 tonnes per annum (taking into consideration the 2008 approved expansion currently under construction) to 1500 tonnes per annum of a variety of marine species. This will include the following activities:

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• Construction of additional abalone grow out tanks and seaweed paddle ponds; • Construction/expansion of the workshops, packroom and processing facility, hatchery expansion and feed factory/storage; • Construction of a new pumphouse and an additional seawater inlet pipeline and outlet channel, for seawater abstraction and discharge, respectively; • Construction of an additional 24 managerial dwelling units and associated infrastructure; • Construction of two additional office precincts including parking area; • Construction of two vehicle workshop and garage facilities; • Construction of associated infrastructure, such as internal roads, stormwater channels and attenuation dam, electric cabling, and water reticulation; • Realignment of approximately 1 km of the main road leading down to Fish Bay; • Construction of an onsite sewage package plant and associated reticulation; and • Construction of two additional substations on site, and additional above-ground diesel storage tanks.

Table 4-1 provides further details of the expansion parameters. Sections 4.2.1 to 4.2.3 provide further information on specific activities concerning the proposed expansion.

Table 4-1: Expansion parameters PARAMETERS CURRENT EXPANSION COMBINED UNIT TOTAL Production Production of abalone 350 1150 1500 tonnes /annum Seaweed 127 373 500 tonnes/month production/cultivation Total spat requirement 386 533 713 467 1 100 000 Units/month Artificial feed usage 27 868 82 132 110 000 kg/month Staff Staff 432 1368 1800 persons Infrastructure Abalone tanks 19 992 63 308 83 300 m2 1470 4655 6125 tanks Seaweed paddle ponds 32 100 101 700 133 500 m2 107 339 446 ponds Pumphouse 355 892 1247 m2 Central Office Space 485 315 800 m2 Parking 20 80 100 vehicles Housing 8 24 32 Houses Workshops (main workshop, 1186 2207 3393 m2 vehicle workshop and garage, and general storeroom) Packroom and processing 545 1634 2200 m2 facility Hatchery expansion 2163 3403 5566 m2 Water usage 2500 7368 9868 Liter/second Seawater Abstraction 9 000 26 524 35 525 m3/h Freshwater usage (rainwater 43 200 136 800 180 000 Liter/day harvesting and borehole) Waste/Effluent Seawater Effluent 2500 7368 9868 Liter/second Solid Waste - general 2 5 7 31m3 skips/month Biological waste 7 23 30 m3/month Sewage 0 0.15 0.15 Ml/day

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PARAMETERS CURRENT EXPANSION COMBINED UNIT TOTAL Electricity Electricity (Eskom supply) 2.2 6.5 8.7 MVA Diesel storage tanks 22 000 68 000 90 000 litres Substations 294 958 1252 m2

Figure 4-1 below presents the proposed layout plan for the expansion of the existing Wild Coast Abalone facility. Figure 3-1 above shows the proposed location of the offshore wave energy pump in relation to the abalone facility and Amathole Marine Protected Area (MPA).

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Figure 4-1: Site plan of the proposed expansion

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4.2.1 CONSTRUCTION OF MANAGERIAL DWELLING UNITS AND ASSOCIATED SERVICE INFRASTRUCTURE

The proposed housing units will be located on grassland and thicket classified as Hamburg Dune Thicket (refer to section 9.5.1 below), previously used as grazing land for livestock. The layout and design of the additional managerial housing will be done in a similar manner as per the existing managerial housing located on site (authorised as part of the application for expansion in 2008). The existing farmhouse located along the Fish Bay road will be converted into offices. A vehicle workshop and garage will be located on the other side of the existing road to Fish Bay. This will necessitate the realignment of the road to the north of the workshop and garage so traffic (residents of Fish Bay) will not pass through the office precinct.

Each house will have a rainwater tank for potable water supply. Currently, the existing facility and houses makes use of septic tanks coupled with french drains, as favoured by the Sanitation Protocol Report written in 2008 for the original expansion. The report concluded that septic tanks are suitable for the area as the risk of groundwater contamination is low due to the underlying geology and soils.

It should be noted that Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) are not in favour of new proposals for septic tanks within the coastal reserve, and therefore, alternatives are being considered as part of the Sanitation Protocol Assessment update to determine the best manner in which to treat and dispose of sewage generated on site from the proposed current expansion of the facility. The updated Sanitation Protocol Assessment forms part of the Plan of Study (PoS) for the EIA phase of the project (refer to Section 12.3.7 below).

Preliminary sewage treatment alternatives have been considered for the proposed expansion, which are further discussed and assessed in Section 7.1.2 (incremental alternatives) below.

Figure 4-2: View of the location for the proposed housing units (looking north west)

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Figure 4-3: View of the location for the proposed housing units (looking south towards the facility and coast)

Figure 4-4: Existing housing units on site

4.2.2 CONSTRUCTION OF A NEW PUMPHOUSE AND ADDITIONAL SEAWATER INLET AND OUTLET PIPELINES

Seawater abstraction

The increase in abalone growth tanks and tonnage production (350 to 1500 tonnes per annum) will increase the volume of seawater required from 9 000 m3 per hour currently to 35 525 m3 per hour (9868 litres/second).

Due to the substantial increase in seawater required to be abstracted, the use of the existing pumphouse and seawater inlet pipeline will not be able to abstract the volumes required to meet the demand of the proposed expansion. Due to spatial limitations for expansion to the existing pumphouse, an additional pumphouse and seawater inlet pipeline is proposed to be constructed west (up current) from the existing seawater inlet (refer to Figure 4-6 below).

The proposed pipeline will transverse a portion of coastal thicket within the East London Coast Nature Reserve (managed by ECPTA). The construction of the inlet pipeline with therefore require clearance of the coastal thicket (0.15 ha), as well as excavation of the seashore and blasting of the coastal rock in order to lay the pipeline 7 m below sea level. The pipeline will extend from the new sump and pumphouse roughly 100 - 150m offshore, maintaining a depth (estimated to be 7m) equal to that which will allow for seawater to be abstracted during a spring tide low.

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Layout alternatives have been considered for the proposed new inlet pipeline and pumphouse, which are further discussed and assessed in Section 7.1.2 (incremental alternatives).

Figure 4-5: Existing seawater sump and pumphouse

Figure 4-6: Existing seawater inlet pipeline lies 7m below the ground leading to the sump and pumphouse (left). Proposed location of new seawater inlet pipeline (right).

Discharge outlet channel

The proposed new discharge channel will target a natural clearance within the coastal thicket, to avoid additional clearance (refer to Figure 4-7 below). The discharge channel will be an open channel reinforced with EnviroRock, which are durable geotextile bags filled with soil and/or sand. As is the case with the existing discharge channel, the proposed new discharge channel will also have a wooden access bridge constructed over the channel in order to allow continued beach access.

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Layout alternatives have been considered for the proposed new discharge outlet channel, which are further discussed and assessed in Section 7.1.2 (incremental alternatives).

Figure 4-7: Existing discharge outlet channel (left). Proposed location of new discharge outlet channel (right).

4.2.3 SERVICES INFRASTRUCTURE

Potable water supply

The existing facility currently has capacity to store 90 000 litres (l) of freshwater on site (see Figure 4-8). Rainwater harvesting is currently the primary source of potable water for the existing facility, with an average amount of 35 000 l being harvested per annum. Groundwater is abstracted from four existing boreholes located on the southwestern portion of the facility, which supplements the housing units on site, when needed.

Additional rainwater harvesting, as well as the continued use of the four boreholes on site, is expected to meet the freshwater water demand of the facility once fully expanded.

Figure 4-8: Rainwater harvesting on site

Abalone waste water

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Waste is generated by each individual animal (abalone) that is present within the Wild Coast Abalone facility. Nitrogen, phosphorous and organic matter are the primary by-products produced by animals that are present in any aquaculture operation. The bulk of the waste is produced in the abalone grow-out tanks where there are high concentrations of abalone being produced. Other sources of waste include excess feed in the tanks and the waste generated as a result of maintenance and cleaning of the pipelines to remove any biofouling. The effluent water, after leaving the grow-out and hatchery facilities, is directed to seaweed (Ulva) paddle ponds (see Figure 4-9 below). These seaweed ponds function as biological filters where nutrients and particles in the waste water are utilized by the Ulva, and act as settling tanks where any particulate matter in the effluent water can settle out. From there, the effluent water follows a pipeline to the discharge outlet channel (as shown in Figure 4-1 above).

The increased volume of seawater required to be abstracted will increase the waste water/effluent production from the abalone grow out tanks accordingly (9868 litres/second or 35 525 m3/hour). This will necessitate the need for an increase in seaweed paddle ponds to treat the increase waste water via bio-filtration. With the expansion, the seaweed paddle ponds will produce a total of 500 tonnes per month of seaweed which are used to supplement the feed for the abalone.

Figure 4-9: Existing seaweed paddle ponds on site used for bio-filtration of the abalone waste water.

Solid Waste

Solid waste generated by the Wild Coast Abalone facility is currently collected by a waste removal service provider (EnviroServ) and disposed of offsite. Organic waste (abalone mortalities and remains from the processing plant) are stored in sealed drums and is collected by EnviroServ and disposed of accordingly offsite. The increase in general and organic waste generated from the proposed expansion will continue to be disposed of in the same manner.

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Figure 4-10: General waste skip (left). Organic waste is temporarily stored in sealed drums (right) until collected by EnviroServ.

Sanitation

The existing sewage production of the Wild Coast Abalone facility is estimated at 27m3/day or 9855m3/annum, which is comprised of staff sanitation at the facility as well as on site resident housing sanitation. Currently, the facility uses septic tanks coupled with french drains, as favoured by the Sanitation Protocol Report written in 2008 for the original expansion. The report concluded that septic tanks are suitable for the area as the risk of groundwater contamination is low due to the underlying geology and soils.

As mentioned above, the Sanitation Protocol Assessment is currently being updated to determine the best manner in which to treat and dispose of sewage generated on site from the proposed expansion of the facility. The updated report forms part of the Plan of Study (PoS) for the EIA phase of the project.

Preliminary sewage treatment alternatives are further discussed and assessed in Section 7.1.2 (incremental alternatives).

Access Roads

Internal gravel access roads will be constructed on site as shown in the site layout plan (Figure 4-1 above).

Stormwater Management

There is an existing open stormwater channel (earth swale) which passes through the existing facility and releases at the southwestern corner of the facility (refer to the green line in Figure 4-11 below).

It is proposed that additional earth swales are constructed to direct stormwater runoff away from the proposed facility expansion area (refer to the red lines in Figure 4-11 below). It is proposed that the existing dam wall be raised to 4m (total capacity of 7410 m³) and the spillway be reconstructed in the direction of the second earth swale that is to capture and direct stormwater runoff to the new stormwater attenuation dam proposed. The attenuation dam will be constructed with a spillway to allow for controlled release of flows downstream when required.

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A stormwater management plan is currently being developed by CBM Africa Engineers, details of which will be included in the Environmental Impact Report (EIR). Stormwater management alternatives will be further investigated during the EIA phase of the project.

Earth swale 1

Earth swale 3

Earth swale 2

existing swale

Figure 4-11: Preliminary design of stormwater diversion (red lines reflect the location of proposed new earth swales, green line reflects the location of the existing earth swale).

Power Supply

Wild Coast Abalone have an existing Eskom grid connection. Due to the large energy demands of the proposed expansion and the desire to invest in ‘greener’ energy alternatives, Wild Coast Abalone are proposing the following:

1. Construction of two additional substations and associated infrastructure; and 2. Construction of five (5) wind turbines to provide renewable energy to the facility (currently undergoing a separate EIA process).

Two additional substations (green shaded areas in Figure 4-1 above) and associated underground cabling are being proposed on site. This will also require the additional above ground diesel storage tanks.

Vegetation Screen

In order to mitigate the potential visual impact to the Fish Bay residents on the far north-eastern side of proposed expansion, Wild Coast Abalone are proposing to construct a vegetation screen

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using indigenous species deemed appropriate by the Ecological Specialist. This will be assessed as part of the Ecological Impact Assessment during the EIA phase.

5 LEGISLATIVE REQUIREMENTS

According to Appendix 2, Section 2 (1), of the EIA Regulations 2014 (as amended), a “scoping report must contain the information that is necessary for a proper understanding of the process, informing all preferred alternatives, including location alternatives, the scope of the assessment, and the consultation process to be undertaken through the environmental impact assessment process, and must include—

(d) a description of the scope of the proposed activity, including— (i) all listed and specified activities triggered; (e) a description of the policy and legislative context within which the development is proposed including an identification of all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks and instruments that are applicable to this activity and are to be considered in the assessment process.

This section describes the South African (National), Eastern Cape (Provincial) and ADM and GKLM (Local) legislation considered during the Scoping Phase of the proposed development.

5.1 RELEVANT ENVIRONMENTAL LEGISLATION

Table 5-1 below summarises the legislation that is relevant to the proposed Wild Coast Abalone Facility Expansion.

Table 5-1: Environmental legislation considered in the preparation of this report. Title of Environmental Implications for the proposed Wild Coast Abalone Facility Expansion Legislation The Constitution This is the supreme law of the land. As a result, all laws, including those pertaining to (Act No. 108 of the proposed development, must conform to the Constitution. The Bill of Rights - 1996) Chapter 2 of the Constitution, includes an environmental right (Section 24) according to which, everyone has the right: a) To an environment that is not harmful to their health or well-being. b) To have the environment protected for the benefit of present and future generations, through reasonable legislative and other measures that: (i) Prevent pollution and ecological degradation. (ii) Promote conservation. (iii) Secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.

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Title of Environmental Implications for the proposed Wild Coast Abalone Facility Expansion Legislation National The applicant must be mindful of the principles, broad liability and implications Environmental associated with NEMA and must eliminate or mitigate any potential impacts. The Management Act applicant must also comply with the EIA Regulations (2014, as amended) in the terms of (NEMA) (Act No. the Act which specifies when an environmental authorisation is required and the 107 of 1998) nature of the EIA process.

Integrated Coastal According to Section 16(1) of the Integrated Coastal Management Act (ICMA) (Act No. Management Act 24 of 2008), the coastal protection zone consists of: (ICMA) (Act No. 24 (a) land falling within an area declared in terms of the Environment Conservation Act, of 2008) 1989 (Act No. 73 of 1989), as a sensitive coastal area within which activities identified in terms of section 21(1) of that Act may not be undertaken without an authorisation; (b) any part of the littoral active zone that is not coastal public property; (c) any coastal protection area, or part of such area, which is not coastal public property; (d) Any land unit situated wholly or partially within one kilometre of the high-water mark which, when this Act came into force— (i) was zoned for agricultural or undetermined use; or (ii) was not zoned and was not part of a lawfully established township, urban area or other human settlement; (e) any land unit not referred to in paragraph (d) that is situated wholly or partially within 100 metres of the high-water mark; (f) any coastal wetland, lake, lagoon or dam which is situated wholly or partially within a land unit referred to in paragraph (d) or (e); (g) any part of the seashore which is not coastal public property, including all privately owned land below the high-water mark; (h) any admiralty reserve which is not coastal public property: or (i) any land that would be inundated by a 1:50 year flood or storm event. Section 38 of the This 1km coastal corridor is managed by DEDEAT which was appointed by the Premier ICMA (Act No. 24 of under Section 38(1) of the ICMA as the lead agency for coastal management within the 2008) Eastern Cape. The coastal protection zone is established to manage, regulate and restrict the use of land that is adjacent to coastal public property, or that plays a significant role in the coastal ecosystem.

In addition, the National Department of Environmental Affairs (DEA) commissioned an Environmental Management Framework (EMF) (DEA, 2009) study for the coastal zone between Cannon Rocks to the Great Kei River Mouth. The aim of the framework is to give effect to the objectives of the National Environmental Management: Coastal Management Act 24 of 2008.

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Title of Environmental Implications for the proposed Wild Coast Abalone Facility Expansion Legislation Section 65 of the With regards to Part 4: Award of leases and concessions on coastal public property, ICMA (Act No. 24 of Section 65 states “(1) Subject to sections 67 and 95, no person may occupy any part of, 2008) or site on, or construct or erect any building, road, barrier or structure on or in. coastal public properly except under and in accordance with a coastal lease awarded by the Minister in terms of this Chapter.”

An application by the applicant for a coastal lease will be required for the construction of any infrastructure on coastal public property. Section 69 of the Section 69 (1) of the ICM Act states: ICMA (Act No. 24 of “No person may discharge effluent that originates from a source on land into coastal 2008) waters except in terms of a general authorisation ... or a coastal waters discharge permit ...” Under the ICMA, “effluent” is defined as: (a) Any liquid discharged into the coastal environment as waste, and includes any substance dissolved or suspended in the liquid; or (b) Liquid which is a different temperature from the body of water into which it is being discharged.

A Coastal Waters Discharge Permit (CWDP) will be submitted to National DEA: Oceans and Coast for the additional effluent to be discharged as part of the expansion of the abalone facility. Marine Living The Marine Living Resources Act (MLRA) (Act No. 18 of 1998) provides for the Resources Act (Act conservation of the marine ecosystem, the long-term sustainable utilisation of marine No. 18 of 1998) living resources and the orderly access to exploitation, utilisation and protection of certain marine living resources, and for these purposes, to provide for the exercise of control over marine living resources in a fair and equitable manner to the benefit of all the citizens of South Africa.

Chapter 4 of the MLRA details regulations regarding Marine Protected Areas: “(2) No person shall in any marine protected area, without permission in terms of subsection (3)— (b) take or destroy any fauna and flora other than fish; (c) dredge, extract sand or gravel, discharge or deposit waste or any other polluting matter, or in any way disturb, alter or destroy the natural environment; (d) construct or erect any building or other structure on or over any land or water within such a marine protected area; or (e) carry on any activity which may adversely impact on the ecosystems of that area. (3) The Minister may, after consultation with the Forum, give permission in writing that any activity prohibited in terms of this section may be undertaken, where such activity is required for the proper management of the marine protected area.”

The provincial and national Oceans and Coast department will need to grant permission for the construction of infrastructure within an MPA, as well as the discharge of effluent into the MPA.

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Title of Environmental Implications for the proposed Wild Coast Abalone Facility Expansion Legislation National The National Environment Management: Biodiversity Act (No. 10 of 2004) (NEMBA) Environmental provides for the management and conservation of South Africa’s biodiversity and the Management: protection of species and ecosystems that warrant national protection. The objectives Biodiversity Act of this Act are to: (Act No. 10 of 2004) a) Provide, within the framework of the National Environmental Management Act; b) Manage and conserve of biological diversity within the Republic; and c) Promote the use of indigenous biological resources in a sustainable manner.

In addition to this, Sections 50-62 of the Act provide details relating to the protection of threatened or protected ecosystems and species, while Sections 63-77 of the Act provide details relating to alien and invasive species with the purpose of preventing their introduction and spread, managing, controlling and eradicating of alien and invasive species. NEMBA National The National List of Ecosystems is in place for the ecosystems that are threatened and List of Threatened in need of protection. The NEMBA provides for listing of threatened or protected or Protected ecosystems in one of the following categories: Ecosystems (GNR  Critically endangered (CR) ecosystems, being ecosystems that have undergone 1002 of 9 December severe degradation of ecological structure, function or composition as a result of 2011) human intervention and are subject to an extremely high risk of irreversible transformation;  Endangered (EN) ecosystems, being ecosystems that have undergone degradation of ecological structure, function or composition as a result of human intervention, although they are not critically endangered ecosystems;  Vulnerable (VU) ecosystems, being ecosystems that have a high risk of undergoing significant degradation of ecological structure, function or composition as a result of human intervention, although they are not critically endangered ecosystems or endangered ecosystems;  Protected ecosystems, being ecosystems that are of high conservation value or of high national or provincial importance, although they are not listed as critically endangered, endangered or vulnerable. NEMBA: Alien Invasive alien species are plants, animals and microbes that are introduced into Invasive Species countries, and then out-compete the indigenous species. Invasive alien species are Regulations (2014) cause billions of Rands of damage to South Africa’s economy on an annual basis and are a major threat to the country’s biological biodiversity.

The Alien and Invasive Species Regulations (2014) categorises the different types of alien and invasive plant and animal species and how they should be managed:

 Category 1a Listed Invasive Species – species which must be combatted or eradicated.  Category 1b Listed Invasive Species – species which must be controlled.  Category 2 Listed Invasive Species – species which require a permit and must not be allowed to spread outside of the designated area.  Category 3 Listed Invasive Species – species which are subject to exemptions in terms of section requiring a permit, but where such a species occurs in riparian areas, must, for the purposes of these regulations, be considered to be a Category 1b Listed Invasive Species and must be managed according to regulation 3.

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Title of Environmental Implications for the proposed Wild Coast Abalone Facility Expansion Legislation Provincial Nature The Provincial Nature and Environmental Conservation Ordinance (PNECO) (No. 19 of and Environmental 1974) lists species of special concern which require permits for removal. Schedules 1 to Conservation 4 list protected and endangered plant and animal species. Ordinance (No. 19 of 1974) National The National Environmental Management: Protected Areas Act (No. 57 of 2003) Environmental (NEMPAA) mainly provides for the following: Management: (i) Declaration of nature reserves and determination of the type of reserve Protected Areas Act declared; (NEMPAA) (ii) Cooperative governance in the declaration and management of nature (Act No. 57 of 2003) reserves; (iii) A system of protected areas in order to manage and conserve biodiversity; and (iv) Utilization and participation of local communities in the management of protected areas.

In terms of Section 50(5) “No development, construction or farming may be permitted in a nature reserve or world heritage site without the prior written approval of the management authority.” Therefore, written approval will be required from DAFF: Forestry and ECPTA for the proposed infrastructure to be constructed through the adjacent nature reserve. Amathole Marine The Amathole MPA was formally promulgated on 16 September 2011. The purpose for Protected Area declaring the MPA is to: (MPA): Government  Protect and conserve the marine environment and marine biodiversity in the Notice R731, 16 Amathole region; September 2011  To provide a sanctuary for species impacted by boat-based exploitation;  To provide benchmark areas for scientific research and monitoring aimed at the protection and conservation of biodiversity and ecosystems; and  To control activities in the MPA to reduce the risks of habitat degradation.

The provincial and national Oceans and Coast department will need to grant permission for the construction of infrastructure within an MPA, as well as the discharge of effluent into the MPA. National Forest Act This act makes provision for promoting the sustainable management and development (Act No. 84 of 1998) of forests, and for the protection of certain forests and trees for environmental, economic, educational, recreational, cultural, health and spiritual purposes. A permit must be obtained from the Department of Water Affairs and Forestry (DWAF) to remove or destroy any plants listed in the NFA.

National Heritage Section 38(1) of the National Heritage Resources Act (Act No. 25 of 1999) states: Resources Act “Subject to the provisions of subsections (7), (8) and (9), any person who intends to (Act No. 25 of 1999) undertake a development categorised as: (a) the construction of a road, wall, powerline, pipeline, canal or other similar form of linear development or barrier exceeding 300m in length; (b) the construction of a bridge or similar structure exceeding 50 m in length;

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Title of Environmental Implications for the proposed Wild Coast Abalone Facility Expansion Legislation (c) any development or other activity which will change the character of a site: (i) exceeding 5 000 m2 in extent; or (ii) involving three or more existing erven or subdivisions thereof; or (iii) involving three or more erven or divisions thereof which have been consolidated within the past five years; or (iv) the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources authority; (d) the re-zoning of a site exceeding 10 000 m2 in extent; or (e) any other category of development provided for in regulations by SAHRA or a provincial heritage resources authority, must at the very earliest stages of initiating such a development, notify the responsible heritage resources authority and furnish it with details regarding the location, nature and extent of the proposed development.” A Heritage Impact Assessment and desktop Paleontological Assessment is currently being undertaken for the proposed development. The National and Provincial Heritage Authority will be notified of the proposed development and be provided with an opportunity to comment on all draft environmental reports. National Water Act The National Water Act (No. 36 of 1998) (NWA) provides for fundamental reform of the (Act No. 36 of 1998) law relating to water resources in South Africa. The NWA is concerned with the overall management, equitable allocation and conservation of water resources in South Africa. To this end, it requires registration of water users and licenses to be obtained for water use except for certain limited instances set out in Section 21 of the Act. These instances include domestic use, certain recreational use, where the use occurs in terms of an existing lawful use or where the Department of Water and Sanitation (DWS) has issued a general authorisation that obviates the need for a permit.

Water use for which a permit is required: For the purposes of this Act, water uses for which a permit is required (amongst other), are defined in Section 21 as follows: (a) taking water from a water resource; (b) storing water; (c) impeding or diverting the flow of water in a watercourse; (d) engaging in a stream flow reduction activity contemplated in section 36; (e) engaging in a controlled activity identified as such in section 37(1) or declared under section 38(1); (f) discharging waste or water containing waste into a water resource through a pipe, canal, sewer, sea outfall or other conduit; (g) disposing of waste in a manner which may detrimentally impact on a water resource; (h) disposing in any manner of water which contains waste from, or which has been heated in, any industrial or power generation process; (i) altering the bed, banks, course or characteristics of a watercourse; (j) removing, discharging or disposing of water found underground if it is necessary for the efficient continuation of an activity or for the safety of people; and (k) using water for recreational purposes.”

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Title of Environmental Implications for the proposed Wild Coast Abalone Facility Expansion Legislation A Water Use License Application (WULA) will be submitted to Department of Water and Sanitation (DWS) for proposed water uses requiring a license, during the EIA process.

National The purpose of this Act relates to the proper disposal of waste. The Act also provides Environmental for the waste related activities where a Waste Licence is required. This includes the Management: recycling and refining of waste. GN R 921 further lists the applicable Waste Waste Act (59 of Management Activities which details activities that have, or are likely to have, a 2008) detrimental effect on the environment.

A waste license will not be required in terms of GN R921 due to thresholds not being met by the proposed expansion. Animal Diseases Act In terms of Section 6 of the Animal Diseases Act (Act no 35 of 1984), no animal or (Act no 35 of 1984) animal product may be imported into or moved in transit through South Africa without the importer obtaining a veterinary import permit from the Department of Agriculture, Forestry and Fisheries (DAFF). Directorate: Food Import and Export Standards. The DAFF has a regulatory function over the protection of agricultural resources and animal health matters. Veterinary Services of the Provincial Department(s) of Agriculture must be engaged for the export certification of live freshwater aquatic organisms. Conservation of The Conservation of Agricultural Resources Act (CARA) aims to control over-utilisation Agricultural of the natural agricultural resources to promote the conservation of soil, water sources Resources Act (Act and vegetation through the combat of weeds and invader plants. Regulations 15 and 16 No. 43 of 1983) under this Act, which relate problem plants, were amended in March 2001. The Act provides a list of declared weeds and invader plants as well as indicators of bush encroachment. These lists include:  Combating of category 1 plants (Section 15A) according to CARA (Act No 43 of 1983); and  Combating of category 2 plants (Section 15B) according to CARA (Act No 43 of 1983) In addition, section 6 of the Act makes provisions for control measures to be applied to achieve the objectives of the Act. These measures relate to inter alia:  Cultivation of virgin soil;  Protection of “vleis”, marshes, water courses and water sources;  The regulation of the flow pattern and run-off;  The protection of natural vegetation in the area; and  The restoration or reclamation of land which is eroded or disturbed. Occupational Health The objective of the Occupational Health and Safety Act (OHSA) is to provide for the and Safety Act (Act health and safety of persons at work. In addition, the Act requires that, “as far as No. 85 of 1993) reasonably practicable, employers must ensure that their activities do not expose non- employees to health hazards”. The importance of the Act lies in its numerous regulations, many of which will be relevant to the proposed development. This covers, among other issues, noise and lighting. Hazardous The Hazardous Substances Act provides for: Substances Act (Act  The control of substances which may cause injury or ill-health to or death of No. 15 of 1973) human beings by reason of their toxic, corrosive, irritant, strongly sensitizing or flammable nature or the generation of pressure thereby in

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Title of Environmental Implications for the proposed Wild Coast Abalone Facility Expansion Legislation certain circumstances, and for the control of certain electronic products;  The division of such substances or products into groups in relation to the degree of danger;  The prohibition and control of the importation, manufacture, sale, use, operation, application, modification, disposal or dumping of such substances and products. The diesel fuel proposed to be stored at the facility is defined as a hazardous substance.

National This act provides reasonable measures for the prevention of pollution and ecological Environmental degradation; and provides for specific air quality measures; for national norms and Management: Air standards regulating air quality monitoring, management and control by all spheres of Quality Act (Act No. government. 39 of 2004)

Noise Control This act provides reasonable measures for the control and prevention of disturbing Regulations in terms noise and noise nuisance. of Section 25 of the Environment Conservation Act, 1989 (Act No. 73 of 1989)

5.1.1 RELEVANT POLICY AND PLANS

Other legislation that may be relevant to the proposed development includes:

• Spatial Planning and Land Use Management Act (SPLUMA) (Act 16 of 2013 – came into force on 1 July 2015) aims to provide inclusive, developmental, equitable and efficient spatial planning at the different spheres of the government. This act repeals national laws on the Removal of Restrictions Act, Physical Planning Act, Less Formal Township Planning Act and Development Facilitation Act; • Aquaculture Development Bill (2018); • Guidelines for Aquaculture in the Eastern Cape; • Department of Agriculture, Forestry and Fisheries (2013). Legal Guide to Aquaculture in South Africa (First Edition), 94 pp; • Department of Environmental Affairs (2013). EIA Guideline for Aquaculture in South Africa, 72 pp; • Amathole District Municipality and GKLM Integrated Development Plans (IDP’s) and Spatial Development Frameworks SDF’s; • GKLM Strategic Environmental Assessment (SEA) (2005); • DEA Coastal Environmental Management Framework – Cannon Rocks to Great Kei River Mouth (DEA, 2009); • Eastern Cape Coastal Management Plan (2013); and

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• Department of Forestry and Fisheries (DAFF) list of protected tree species.

In addition to the above, the following spatial tools from the South African National Biodiversity Institute (SANBI) need to be taken into consideration:

• The South African Vegetation Map (Mucina and Rutherford, 2018); • The Eastern Cape Biodiversity Conservation Plan (ECBCP, 2020); and • The National Freshwater Ecosystem Priority Areas (NFEPA) project.

5.1.2 LISTED ACTIVITIES

Three lists of activities, initially published on 21 April 2006 were amended in 2010, 2014 and again on 7 April 2017, as per Listing Notices 1, 2 and 3 (GN R 324, 325, and 327 respectively), which define the activities that require, respectively, a Basic Assessment (applies to activities with limited environmental impacts), or a full Scoping and EIA (applies to activities which are significant in extent and duration).

The proposed expansion of the Wild Coast Abalone Facility will require a full Scoping and EIA process, as per the triggered NEMA listed activities as detailed in Table 5-2 below.

Table 5-2: NEMA listed activities triggered by the proposed development LISTED ACTIVITIES APPLICABILITY LISTING NOTICE 1: ACTIVITIES REQUIRING A BASIC ASSESSMENT 12 (i) (ii) The development of— The proposed expansion will require the (a) (c) (i) dams or weirs, where the dam or weir, construction of a new stormwater attenuation including infrastructure and water surface dam and an earth swale (stormwater diversion area, exceeds 100 square metres; or channel), exceeding 100m2 within a (ii) infrastructure or structures with a physical watercourse/wetland, and within 32 metres of a footprint of 100 square metres or more; watercourse/wetland. where such development occurs— (a) within a watercourse; (c) if no development setback exists, within 32 metres of a watercourse, measured from the edge of a watercourse. 14 The development and related operation of The combined capacity of diesel storage will be facilities or infrastructure, for the storage, or 90m3. for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80 cubic metres or more but not exceeding 500 cubic metres. 19 The excavation, removal or moving of soil, The proposed expansion will involve earthworks sand, shells, shell grit, pebbles or rock of more related to stormwater management within a than 10 cubic metres from a watercourse. watercourse.

19A The infilling or depositing of any material of The proposed seawater inlet pipeline and wave (i)(ii)(iii) more than 5 cubic metres into, or the energy pipeline will involve excavation and dredging, excavation, removal or moving of backfilling of sand/shells/rock (exceeding 5m3) soil, sand, shells, shell grit, pebbles or rock of from the seashore, 100 meters inland of the

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LISTED ACTIVITIES APPLICABILITY more than 5 cubic metres from: high-water mark, and sea. (i) the seashore (ii) the littoral active zone, an estuary or a distance of 100 metres inland of the high-water mark of the sea or an estuary, whichever distance is the greater. (iii) The sea. 24 (ii) The development of a road— It is proposed that the existing road to Fish Bay (ii) with a reserve wider than 13,5 meters, or be realigned to the north of the proposed new where no reserve exists where the road is vehicle workshop, garage and offices. wider than 8 metres; 34 The expansion of existing facilities or The proposed expansion of the abalone facility infrastructure for any processor activity where will result in the need for a coastal water such expansion will result in the need for a discharge permit for the release of treated permit or licence or an amended permit or effluent (increase by more than 50m3 per day). licence in terms of national or provincial legislation governing the release of emissions, effluent or pollution, excluding— (iii) the expansion is directly related to aquaculture facilities or infrastructure where the wastewater discharge capacity will be increased by 50 cubic meters or less per day. 41 (i) (ii) The expansion and related operation of The proposed expansion is for the existing (iii) facilities, infrastructure or structure for abalone facility which will result in an increase aquaculture of: of abalone (Molluscs - Haliotidae sp.) (i) finfish, crustaceans, reptiles or amphibians, production from 350 tonnes to 1500 tonnes per where the annual production output of such annum. There will also be an increase in facility, infrastructure or structures will be seaweed production (aquatic plants) of more increased by 20,000 kg (wet weight) or more; than 60,000kg. (ii) molluscs and echinoderms where the annual production output of such facility, In addition to abalone, the facility also plans to infrastructure or structures will be increased diversify into the production of other by 30,000 kg (wet weight) or more; indigenous marine species, such as (but not (iii) aquatic plants where the annual limited to), rock lobster, sea cucumbers production output of such facility, (Holothuria scabra) and sea urchins (Tripneustes infrastructure or structures will be increased gratilla). by 60,000 kg (wet weight) or more. 45 (i) (ii) The expansion of infrastructure for the bulk The proposed expansion will require the (a) (b) transportation of water or storm water where construction of internal stormwater channels the existing infrastructure— (earth swales) and underground water pipelines (i) has an internal diameter of 0,36 metres or likely to exceed 120 litres per second more; or (stormwater), and exceed 1000m in total, (ii) has a peak throughput of 120 litres per and/or have an increase in throughput capacity second or more; and of more than 10%. (a) where the facility or infrastructure is expanded by more than 1 000 metres in length; or (b) where the throughput capacity of the facility or infrastructure will be

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LISTED ACTIVITIES APPLICABILITY increased by 10% or more; 46 (i) (ii) The expansion and related operation of The proposed expansion will require the (a) (b) infrastructure for the bulk transportation of construction of additional infrastructure for the sewage, effluent, process water, waste water, transportation of sewage (domestic) and return water, industrial discharge or slimes abalone effluent (facility) water, likely to exceed where the existing infrastructure— 120 litres per second, and exceed 1000m in (i) has an internal diameter of 0,36 metres or total, and/or have an increase in throughput more; or capacity of more than 10%. (ii) has a peak throughput of 120 litres per second or more; and (a) where the facility or infrastructure is expanded by more than 1 000 metres in length; or (b) where the throughput capacity of the facility or infrastructure will be increased by 10% or more. 48 (i) (ii) The expansion of The proposed expansion will require the (a) (c) (i) infrastructure or structures where the construction of a new stormwater attenuation physical footprint is expanded by 100 square dam and the expansion of the existing abalone metres or more; facility and associated infrastructure (exceeding (ii) dams or weirs, where the dam or weir, 100m2) within a watercourse/wetland, and including infrastructure and water surface within 32 meters of a watercourse/wetland. where such expansion occurs: (a) within a watercourse and/or (c) within 32 metres of a watercourse. 52 The expansion of structures in the coastal The proposed expansion will require the public property where the development construction of additional seawater inlet footprint will be increased by more than 50 pipeline and discharge channel within the square metres coastal public property that, combined, are likely to exceed 50m2. 54 (v) (e) The expansion of facilities: The proposed expansion will require the (f) (v) if no development setback exists, within a construction of infrastructure (exceeding 50m2) distance of 100 metres inland of the high- within the sea, littoral zone and within 100m of water mark of the sea or an estuary, high-water mark of the sea. whichever is the greater; in respect of: (f) infrastructure or structures where the development footprint is expanded by 50 square metres or more. 57 The expansion and related operation of The proposed expansion of the abalone facility facilities or infrastructure for the treatment of will result in significant waste water being effluent, wastewater or sewage where the generated (more than 15 000 m3 per day), capacity will be increased by 15 000 cubic which will be treated in algal ponds prior to metres or more per day and the development discharge, the footprint of which will exceed footprint will increase by 1 000 square meters 1000m2. or more. The discharge of treated domestic sewage effluent will be less than the thresholds outlined in LN1 (25). LISTING NOTICE 2: ACTIVITIES REQUIRING A FULL SCOPING AND EIA

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LISTED ACTIVITIES APPLICABILITY 15 The clearance of an area of 20 hectares or The expansion of the existing Wild Coast more of indigenous vegetation. Abalone facility will involve the clearance of more than 20 hectares of indigenous vegetation, classified as Hamburg Dune Thicket. LISTING NOTICE 3: ACTIVITIES REQUIRING A BASIC ASSESSMENT 2 (a) (ii) The development of reservoirs, excluding The expansion of the existing abalone facility (aa) (dd) dams, with a capacity of more than 250 cubic will involve the construction of additional (ff) (hh) metres. reservoirs with a total capacity of more than a. Eastern Cape 250 m3 for abalone grow tanks and seaweed ii. Outside urban areas, in: paddle ponds, located in the Eastern Cape, (aa) National Protected Area Expansion within a NPAES focus area, a critical biodiversity Strategy Focus areas; area, within 5 kilometres (km) of a protected (dd) Critical biodiversity areas as identified in area, and within 1km inland from the high- systematic biodiversity plans adopted by the water mark of the sea. competent authority or in bioregional plans; (ff) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined 4 (a) (i) The development of a road wider than 4 It is proposed that the existing road to Fish Bay (bb) (ee) metres with a reserve less than 13,5 metres. be realigned to the north of the proposed new (gg) (hh) a. Eastern Cape vehicle workshop, garage and offices. A new i. Outside urban areas: road linking the new vehicle workshop and (bb) National Protected Area Expansion offices to the abalone facility is also proposed. Strategy Focus areas; (ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core areas of a biosphere reserve, excluding disturbed areas; (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined; 12(a) (ii) The clearance of an area of 300 square metres The expansion of the existing abalone facility (iii) (v) or more of indigenous vegetation will involve the clearance of more than 300 (a) Eastern Cape square meters of indigenous vegetation located (iii) Within the littoral active zone or 100 in the Eastern Cape, within 100 metres inland metres inland from the high-water mark of the from the high-water mark of the sea, within a sea, whichever distance is the greater, or protected nature reserve managed by ECPTA.

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LISTED ACTIVITIES APPLICABILITY (v) On land, where, at the time of the coming into effect of this Notice or thereafter such land was zoned open space, conservation or had an equivalent zoning. 16 (a) (i) The expansion of reservoirs, for bulk water The existing Abalone facility will involve the (ff) (hh) supply excluding dams, where the capacity will expansion of reservoirs (abalone grow out tanks (ii) be increased by more than 250 cubic metres. and seaweed ponds) by more than 250 cubic (a) Eastern Cape meters within a watercourse, located in the (i) Outside urban areas: Eastern Cape, within critical biodiversity areas, (ff) Critical biodiversity areas as identified in within 5 kilometres (km) of a protected area, systematic biodiversity plans adopted by the and within 1 km of the of the high-water mark competent authority or in bioregional plans; of the sea. (hh) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; or (ii) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined. 18 (a) (i) The widening of a road by more than 4 metres, The expansion of the existing facility will likely (ee) (gg) or the lengthening of a road by more than 1 require the lengthening of internal access roads (hh) (ii) kilometre: by more than 1 kilometre, located in the Eastern (a) Eastern Cape Cape, within a critical biodiversity area, within 5 (i) Outside urban areas: kilometres (km) of a protected area, and within (ee) Critical biodiversity areas as identified in 1 km of the of the high-water mark of the sea, systematic biodiversity plans; and within 100m of a watercourse/wetland. (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined; (ii) Areas on the watercourse side of the development setback line or within 100 metres from the edge of a watercourse where no such setback line has been determined. 22 (a) (i) The expansion and related operation of The proposed expansion will require the (ee) (gg) facilities or infrastructure for the storage, or installation of additional above-ground diesel (hh) storage and handling of a dangerous good, storage tanks with a combined capacity of 68 where such storage facilities or infrastructure 000 litres (68m3), located in the Eastern Cape, will be expanded by 30 cubic metres or more outside an urban area, within a critical but no more than 80 cubic metres. biodiversity area, within 5 kilometres (km) of a (a) Eastern Cape, (i) outside urban areas: protected area, and within 1 km of the high- (ee) Within critical biodiversity areas identified water mark of the sea. in systematic biodiversity plans; or

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LISTED ACTIVITIES APPLICABILITY (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; or (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined. 23 (i) (ii) The expansion of: The existing abalone facility will involve the (a) (c) (a) (i) dams or weirs where the dam or weir is expansion of the existing dam and (i) (ee) expanded by 10 square metres or more; or infrastructure by more than 10 square meters (gg) (hh) (ii) infrastructure or structures with a physical within 32m and within a watercourse/wetland, footprint of 10 square metres or more; where located outside an urban area in the Eastern such development occurs: (a) within a Cape, within a critical biodiversity area, within 5 watercourse; or (c) if no development setback kilometres (km) of a protected area, and within has been adopted, within 32 metres of a 1 km of the of the high-water mark of the sea. watercourse, measured from the edge of a watercourse: (a) Eastern Cape (i) Outside urban areas: (ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; or (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined. 24 (a) (ii) The expansion and related operation of The existing abalone facility will involve the (iii) (iv) facilities of any size for any form of expansion of infrastructure for aquaculture aquaculture. located in the Eastern Cape, within a (a) Eastern Cape watercourse and within 100 metres from the (ii) In a Protected Area identified in the edge of a watercourse, and within a protected NEMPAA; nature reserve managed by ECPTA (seawater (iii) Areas on the watercourse side of the inlet pipeline). development setback line or within 100 metres from the edge of a watercourse where no such setback line has been determined; or (iv) Within a watercourse.

In addition to the NEMA listed activities detailed above, the proposed development will also require the following licenses/permits, as detailed in Table 5-3 below.

Table 5-3: Additional licenses/permits required by the proposed development SECTION 21 OF THE NATIONAL WATER ACT (ACT NO. 36 OF 1998)

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A Water Use Licence Application (WULA) will need be submitted to the Department of Water and Sanitation (DWS), in terms of Section 21 of the National Water Act (Act no. 36 of 1998), for the following potential activities: (a) taking water from a water resource; (b) storing water; (c) impeding or diverting the flow of water in a watercourse; (e) engaging in a controlled activity identified as such in section 37(1): a) irrigation of any land with waste or water containing waste generated through any industrial activity or by a waterwork; (g) disposing of waste in a manner which may detrimentally impact on a water resource; and (i) altering the bed, banks, course or characteristics of a watercourse;

SECTION 69 (3) OF THE NATIONAL ENVIRONMENTAL MANAGEMENT: INTEGRATED COASTAL MANAGEMENT ACT (ACT NO. 24 OF 2008): THE COASTAL WATER DISCHARGE PERMIT REGULATIONS A Coastal Water Discharge Permit (CWDP) application will be required as per Section 69 (3) the National Environmental Management: Integrated Coastal Management Act (Act No. 24 of 2008, as amended): “(3) Any person who wishes to discharge effluent into coastal waters in circumstances that are not authorised under a general discharge authorisation referred to in subsection (2) must apply to the Department for a coastal waters discharge permit.”

SECTION 65 OF THE INTEGRATED COASTAL MANAGEMENT ACT (ACT NO. 24 OF 2008): COASTAL LEASE With regards to Part 4: Award of leases and concessions on coastal public property, Section 65 states “(1) Subject to sections 67 and 95, no person may occupy any part of, or site on, or construct or erect any building, road, barrier or structure on or in. coastal public properly except under and in accordance with a coastal lease awarded by the Minister in terms of this Chapter.”

An application for a coastal lease (and payment of the lease fee) will be required in order for the applicant to construct any infrastructure on coastal public property.

SECTION 38 OF THE NATIONAL HERITAGE ACT (ACT NO. 25 OF 1999) As the proposed development will be larger than 5000 m2, a Heritage Impact Assessment is being undertaken as part of this Scoping and EIA process, in order to comply with the requirements of the Act.

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6 NEED AND DESIRABILITY

f) A motivation for the need and desirability for the proposed development including the need and desirability of the activity in the context of the preferred location.

South Africa has enormous potential to become an international player in the farmed abalone market. This sector contributes substantially to the country’s export. Efforts have been made on a national level (Operation Phakisa) to develop, invest in and increase this sector even further in South Africa due to the high product market value of abalone and other mariculture/aquaculture products. In addition to socio-economic benefits, aquaculture also plays a major role in conserving the wild stock of specific marine species, by means of farming fish and shellfish more intensively to meet the market demand.

More than 2000 tonnes of abalone are exported illegally from South Africa each year, resulting in R 1.1 billion being stolen from the economy. The production of excess abalone spat (juveniles), allows for ranching activities (where abalone are planted back into the ocean to grow naturally) to help replenish the wild abalone stock which illegal harvesting has threatened significantly. To date, Wild Coast Abalone have supplied over 3.7 million abalone spat to reseed the ocean as part of their ranching activities.

The current application constitutes the second expansion of the existing Wild Coast Abalone facility, located between Marshstrand and Fish Bay, Eastern Cape. Wild Coast Abalone (Pty) Ltd has established the need for such expansion, which will result in substantial increases in permanent jobs, while utilising natural resources in a sustainable manner. As waste water is effectively treated using bio-filters, the overall environmental impact of the development to the marine environment is regarded as low based on the findings of the previous Marine Impact Assessment conducted in 2008 for the original expansion (refer to Appendix D1). An additional Marine Impact Assessment has been commissioned for the proposed expansion, the results of which will be considered during the EIA phase of the project.

Wild Coast Abalone (Pty) Ltd. currently employs 300 people and are the largest employer within the local area. The facility boosted the local economy by paying almost R20 million in salaries and wages during the 2019/20 financial year.

The proposed expansion is anticipated to generate an additional 1400 jobs as production is anticipated to increase from 350 to 1500 tonnes per annum. This expansion will result in direct and indirect socio-economic benefits for the local economy and aquaculture on a national level.

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7 ALTERNATIVES

(g) a full description of the process followed to reach the proposed preferred activity, site and location of the development footprint within the site, including—

(i) details of all the alternatives considered.

One of the objectives of the EIA process is to investigate alternatives to the proposed project. There are several types of alternatives that are assessed in the EIA process, as detailed in the following sections.

7.1 Types of alternatives

Alternatives should include consideration of all possible means by which the purpose and need of the proposed activity could be accomplished. The no-go alternative must also in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. The determination of whether site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment.

“Alternatives”, in relation to a proposed activity, is defined as different means of meeting the general purpose and requirements of the activity, which may include alternatives to:

a) the property on which or location where it is proposed to undertake the activity; b) the type of activity to be undertaken; c) the design or layout of the activity; or d) the option of not implementing the activity.

7.1.1 FUNDAMENTAL ALTERNATIVES

Fundamental alternatives are developments that are completely different from the proposed project and usually involve a different type of development (different activity other than the no-go option) on the proposed site, or a different location for the proposed development to take place. Such alternatives include:

• Alternative property or location where it is proposed to undertake the activity; and • Alternative type of activity to be undertaken.

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7.1.2 INCREMENTAL ALTERNATIVES

Incremental alternatives are changes or variations to the technical design of a project that provides different options to reduce or minimise any environmental impacts. There are several incremental alternatives that will be refined and assessed further during the EIA Phase of the project, including:

• Alternative design or layout of the activity; and • Alternative technology to be used in the activity.

7.1.3 NO-GO ALTERNATIVE

The EIA process is obligated to assess the status quo (i.e. the “No-Go” option). The No-Go alternative provides the assessment with a baseline against which predicted impacts resulting from the proposed development may be compared. A “No-Go” alternative has been assessed for the proposed development.

7.2 ALTERNATIVES ASSESSED FOR THE WILD COAST ABALONE FACILITY EXPANSION

Table 7-1 below provides details all alternatives assessed for the proposed expansion of the Wild Coast Abalone Facility:

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Table 7-1: Assessment of alternatives for the expansion of the existing Wild Coast Abalone Facility. ALTERNATIVE ALTERNATIVE ADVANTAGES DISADVANTAGES REASONABLE AND FURTHER ASSESSMENT TYPE FEASIBLE REQUIRED IN SECTION 11: PRELIMINARY IMPACT ASSESSMENT FUNDAMENTAL ALTERNATIVES Location Preferred site alternative 1: Existing • Located adjacent to existing • Portions of the expansion are YES YES site facility; located within 100 meters of the • Suitable topography; highwater mark; The consideration of alternative • Existing infrastructure in close • Impacts on existing wetlands; localities was not considered feasible proximity to expansion area; and as the proposed expansion is and • Located in close proximity to associated with the facility’s • Access already established to adjacent residents of established locality and existing the proposed site. Marshstrand and Fish Bay. infrastructure.

Activity Preferred activity 1: Marine • Job creation; • Portions of the expansion are YES YES Aquaculture • Economic development; located within 100 meters of the • Increase in export; and highwater mark; The consideration of alternative • Ranching activities will help • Potential impacts on existing activities was not considered feasible replenish wild stock wetlands; and as the existing facility is already • Located in close proximity to established for marine aquaculture, adjacent residents of primarily abalone farming. Marshstrand and Fish Bay. INCREMENTAL ALTERNATIVES Potable water Alternative 1: Boreholes • Existing boreholes with • Borehole water abstraction alone NO NO supply determined yields. will not be able to meet the potable water demands of the abalone facility. • Borehole water quality should be treated first if used for drinking. Alternative 2: Marshstrand reservoir • Existing dam located fairly • The Marshstrand reservoir does NO NO close to the abalone facility. not have additional capacity to supply the abalone facility in terms of potable water. • Water supply constraints for the surrounding residents Alternative 3: Rainwater harvesting • Currently the primary source • Rainfall is too unreliable to be the NO NO of potable water; only source of supply.

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ALTERNATIVE ALTERNATIVE ADVANTAGES DISADVANTAGES REASONABLE AND FURTHER ASSESSMENT TYPE FEASIBLE REQUIRED IN SECTION 11: PRELIMINARY IMPACT ASSESSMENT • Expansion will create additional roof surface area to collect rainwater from. • Rainwater harvesting is sustainable and does not impact on the surrounding residents. Alternative 4: Combination of • Rainwater harvesting is • Borehole water quality should be YES: based on determined YES rainwater harvesting (primary) and currently the primary source treated first to drinking standard, borehole yields and use of the boreholes of potable water. however, fresh water is largely expected rainwater • Expansion will create used for the kitchen and flushing harvesting yields. additional roof surface area to of toilets, and an alternative collect rainwater from. source of purified water needs to • Rainwater harvesting is be provided to the staff for sustainable and does not drinking. impact on the surrounding residents. • Borehole water will be used to supplement rainwater harvesting, when needed, according to determined yield of the borehole. Sanitation Alternative 1: Septic tanks • Geotechnical investigation • DEDEAT are not in favour of NO: NO conducted for Wild Coast septic tanks being used within • Applications for septic Abalone Facility in 2008 was the coastal zone. tanks within the coastal in favour of septic tanks with • Nuisance odours can be caused zone run the risk of being proven success on site by poor maintenance or clogged rejected by DEDEAT and already. septic systems. DWS. • Does not rely on electrical • Risk of soil and groundwater • Taking into consideration power to operate contamination from poor the substantial increase • The maintenance of the septic maintenance. in staffing density per system is very economical and hectare, septic tanks will not technical. not be appropriate. • Compact system not requiring large amounts of space.

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ALTERNATIVE ALTERNATIVE ADVANTAGES DISADVANTAGES REASONABLE AND FURTHER ASSESSMENT TYPE FEASIBLE REQUIRED IN SECTION 11: PRELIMINARY IMPACT ASSESSMENT • Water quality is obtained. • Good option in rural settings. Alternative 2: Conservancy tanks • Flexible and adaptable to a • Must be regularly emptied by a NO: NO wide variety of individual service provider, which can be • Not practical in remote household waste disposal costly, particularly in rural areas given the number requirements. settings. of conservancy tanks that • Essentially no maintenance • Nuisance odours can be caused will be required. needs except the periodic by poorly serviced tanks. emptying. • Risk of soil and groundwater contamination from poor maintenance. Alternative 3: Package plant • Produces clean, non-polluting • Expensive; YES: YES effluent which can be • Reliance on electrical power to • The updated discharged directly into a operate; and groundwater protocol to watercourse, or to a • Technical, requiring skilled be completed will soakaway for dispersal into operators. determine the the soil (with the required appropriateness of a water use licensing in place) package plant taking into • Requires less time to treat consideration the staffing waste water to standard. density for the area. • The most feasible location and design alternatives for the package plant will be considered as part of the updated groundwater protocol assessment and assessed further in the EIA. Seawater Alternative 1: Construction of new • Shortest new route possible • Vegetation clearance through the YES: YES abstraction pumphouse and inlet (refer to Figure of inlet pipeline to proposed coastal dune thicket and • Further assessment will 7-1 below) new pumphouse location. excavations within the seashore. be required in the EIA • Will target a stormwater phase to determine the channel created through the significance of the coastal dune thicket. potential impacts.

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ALTERNATIVE ALTERNATIVE ADVANTAGES DISADVANTAGES REASONABLE AND FURTHER ASSESSMENT TYPE FEASIBLE REQUIRED IN SECTION 11: PRELIMINARY IMPACT ASSESSMENT • In addition, permits/permission from DEFF: Forestry and ECPTA will be required. Alternative 2: Use of existing • No construction activities • The option of abstracting the NO: NO pumphouse and inlet (refer to Figure required, therefore no further additional volumes using the • Technically flawed due to 7-1 below) disturbances to the coastal existing pump house and existing capacity constraints dune thicket, seashore and pipeline will be technically inter-tidal zones. flawed, as the existing pumphouse and abstraction pipeline will not have the capacity for the larger volumes required to be abstracted. Alternative 3: Construction of new • Construction activities will • Excavations and/or blasting NO: NO pumphouse (or expansion of take place on previously within close proximity to the Technically flawed due to existing) and inlet parallel to existing disturbed areas. existing inlet pipeline will pose a spatial constraints inlet (refer to Figure 7-1 below) risk to existing infrastructure and to the incoming seawater quality for the facility; • There are spatial limitations for the construction of a new pumphouse and sump (or further expansion to the existing pumphouse and sump) due to the close proximity of adjacent structures/buildings. • Construction machinery will have difficulties in accessing the area from the land-based facility side, as the existing pumphouse and adjacent substation are in close proximity to the boundary fence. The temporary dismantling of the boundary fence may pose security risks to the abalone

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ALTERNATIVE ALTERNATIVE ADVANTAGES DISADVANTAGES REASONABLE AND FURTHER ASSESSMENT TYPE FEASIBLE REQUIRED IN SECTION 11: PRELIMINARY IMPACT ASSESSMENT facility.

Alternative 2: Alternative 1 Existing inlet

Alternative 3

Figure 7-1: Seawater inlet layout alternatives

Coastal Alternative 1: Construction of new • New discharge channel can be • Coastal Water Discharge Permit • YES: YES discharge outlet channel down current of designed and reinforced required; • Further assessment will (abalone existing outlet (refer to Figure 7-2 according to the erosive force • Facility is located adjacent to the be required in the EIA effluent) below) of the seawater passing Amathole MPA; phase to determine the through. • Construction of a new channel significance of the will require vegetation clearance potential terrestrial and (coastal grasslands and possible marine impacts; and coastal thicket) and excavations; • In addition, • Potential impacts to the seashore permits/permission from

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ALTERNATIVE ALTERNATIVE ADVANTAGES DISADVANTAGES REASONABLE AND FURTHER ASSESSMENT TYPE FEASIBLE REQUIRED IN SECTION 11: PRELIMINARY IMPACT ASSESSMENT and marine environment; DEDEAT and DEA Oceans • Potential impacts for beach and Coast, DAFF Forestry access. and ECPTA will be required. Alternative 2: Expansion and use of • Least impactful to the • Coastal Water Discharge Permit NO: NO existing outlet (refer to Figure 7-2 surrounding natural required; The design of the flow below) environment as the existing • Facility is located adjacent to the through system through channel would be used. Amathole MPA; the proposed expansion • The substantial increase in the area has been designed volume of seawater passing according to the natural through this channel would be contours of the area too erosive for the current allowing for gravity to channel structure, and direct flow to the outlet reinforcement would be channel (Alternative 1). required; Redirecting the flow of • Substantial increase in erosive treated abalone effluent force of water to the seashore against the flow of gravity, and inter-tidal zones. to the existing outlet channel may pose significant challenges from a technical and design perspective.

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ALTERNATIVE ALTERNATIVE ADVANTAGES DISADVANTAGES REASONABLE AND FURTHER ASSESSMENT TYPE FEASIBLE REQUIRED IN SECTION 11: PRELIMINARY IMPACT ASSESSMENT

Figure 7-2: Discharge outlet channel layout alternatives

Stormwater Alternatives will be assessed in the • Directing stormwater away • Potential impacts to local surface TO BE DETERMINED: This YES Management EIA phase of the project, as this will from facility infrastructure to hydrology within the area. will be further assessed be dependent on the Stormwater prevent runoff damage during the EIA phase Management Plan commissioned to be completed during the EIA phase. Energy Supply Alternative 1: Eskom connection • Existing connection • Non-renewable YES YES • Can be unreliable • Construction of two additional substations and associated infrastructure will be required; • Additional diesel storage will be required on site – possible

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ALTERNATIVE ALTERNATIVE ADVANTAGES DISADVANTAGES REASONABLE AND FURTHER ASSESSMENT TYPE FEASIBLE REQUIRED IN SECTION 11: PRELIMINARY IMPACT ASSESSMENT contamination of local surface water should a spill occur. Alternative 2: Renewable Energy in This is currently being investigated as an additional renewable energy source. This will form part of a separate EIA application combination with an Eskom process and will not be assessed further in this EIA process. connection NO-GO ALTERNATIVE No-Go Status quo: The proposed expansion • No further loss of natural • Underutilized agricultural land; TO BE DETERMINED: This YES Alternative area is privately owned land currently vegetation; • No additional job creation; and option will be further zoned as agriculture, however • No impacts to fresh water • No additional contribution to assessed during the EIA undeveloped and unutilised. and marine environment; economic development and phase. • No additional disturbance to social upliftment, at a national to surrounding residents. local level.

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7.3 ALTERNATIVES FOR FURTHER ASSESSMENT

The removal of the non-feasible alternatives listed above leaves the following alternatives to be assessed further in the preliminary impact assessment provided in section 11 below. Incremental alternatives, such as design and micro-siting of infrastructure will be assessed further in the EIA phase.

Table 7-2: Alternatives to be assessed further during the EIA phase of the project. ALTERNATIVE TYPE ALTERNATIVE FUNDAMENTAL ALTERNATIVES Location Preferred site alternative 1: Existing site The consideration of alternative localities was not considered feasible as the proposed expansion is associated to the facility’s established locality and existing infrastructure. Activity Preferred activity 1: Marine Aquaculture The consideration of alternative activities was not considered feasible as existing facility is already established for marine aquaculture, primarily abalone farming. INCREMENTAL ALTERNATIVES Fresh water supply Alternative 4: Combination of rainwater harvesting (primary) and use of the boreholes Sanitation Alternative 3: Package plant Incremental alternatives in package plant design and micro-siting will be assessed in the EIA phase of the project, as this will be dependent on the Groundwater Protocol commissioned to be completed during the EIA phase. Seawater abstraction Alternative 1: Construction of new pumphouse and inlet up current of existing inlet Micro-siting alternatives will be assessed further in the EIA phase of the project. Coastal discharge (abalone effluent) Alternative 1: Construction of new outlet channel down current of existing outlet Micro-siting alternatives will be assessed further in the EIA phase of the project. Stormwater Management Design alternatives and micro-siting of stormwater infrastructure will be assessed in the EIA phase of the project, as this will be dependent on the Stormwater Management Plan commissioned to be completed during the EIA phase. Energy Supply Alternative 1: Eskom connection Alternative 2: Renewable Energy (Wind) in combination with an Eskom connection (assessed in a separate EIA process) No-Go Alternative Status quo: The proposed expansion area is privately owned land currently zoned as agriculture, however undeveloped and unutilised.

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8 PUBLIC PARTICIPATION

Public consultation is a legal requirement throughout the EIA process. Developers are required to conduct public consultation throughout the Scoping and EIA phase. Formal EIA documents are required to be made available for public review and comment by the proponent, these include the Project Brief, Scoping Report and Terms of Reference and Plan of Study (PoS) the EIA, the Draft and Final EIAR, and the decision of the Competent Authority (DEDEAT).

The method of public consultation to be used depends largely on the location of the development and the level of education of those being impacted on by the project. Required means of public consultation include:

• Site notice(s); • Newspaper advertisements; • Letter of Notification and information to affected landowner(s), stakeholders and registered I&APs; • Background Information Document (BID) distribution; • Public Meeting (attendance register and meeting minutes); and • Authority and Stakeholder engagement (DWS and DEDEAT).

8.1 SITE NOTICE

According to Regulation 41(2) of the NEMA EIA Regulations 2014 (as amended) “the person conducting a public participation process must take into account any relevant guidelines applicable to public participation as contemplated in section 24J of the Act and must give notice to all potential interested and affected parties of an application or proposed application which is subjected to public participation by:

(a) fixing a notice board at a place conspicuous to and accessible by the public at the boundary, on the fence or along the corridor of: (i) the site where the activity to which the application or proposed application relates is or is to be undertaken; and (ii) any alternative site.

During the initial site visit, 2 site notices were placed on site. Refer to Appendix B1 for proof of placement.

8.2 NEWSPAPER ADVERTISEMENT

(b) placing an advertisement in: (i) one local newspaper; or (ii) any official Gazette that is published specifically for the purpose of providing public notice of applications or other submissions made in terms of these Regulations;

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(c) placing an advertisement in at least one provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the boundaries of the metropolitan or district municipality in which it is or will be undertaken: Provided that this paragraph need not be complied with if an advertisement has been placed in an official Gazette referred to in paragraph (c)(ii);

A newspaper advertisement was placed in the Daily Dispatch (provincial newspaper) on the 7h December 2020, in order to notify the general public of the proposed development and of the availability of the DSR for public review. Refer to Appendix B2 for proof of placement.

8.3 I&AP AND STAKEHOLDER NOTIFICATIONS

(d) giving written notice, in any of the manners provided for in section 47 D of the Act, to: (i) the occupiers of the site and, if the proponent or applicant is not the owner or person in control of the site on which the activity is to be undertaken, the owner and to any alternative site where the activity is to be undertaken; (ii) owners, persons in control of, and occupiers of land adjacent to the site where the activity is or is to be undertaken and to any alternative site where the activity is to be undertaken; (iii) the municipal councillor of the ward in which the site and alternative site is situated and any organisation of ratepayers that represent the community in the area; (iv) the municipality which has jurisdiction in the area; (v) any organ of state having jurisdiction in respect of any aspect of the activity; and (vi) any other party as required by the competent authority;

Contact details of all stakeholders identified (I&AP list) are available in Appendix B. Initial notifications, including a Letter of Notification and Background Information Documents (BID), were sent out via email on the 4h December 2020. Refer to Appendix B for proof of notifications.

All I&APs have been notified of the commencement of the DSR public review period (and how to access the DSR) by means of email and via an advertisement placed in the Daily Dispatch newspaper (date of placement: 7h December 2020). Refer to Appendix B for all notification proofs.

Similarly, all I&APs will be notified of the submission of the Final Scoping Report (FSR) to the competent authority (all proofs will be included in the Draft Environmental Impact Report (DEIR)).

8.4 STAKEHOLDER IDENTIFICATION AND REGISTERED I&APS

A proponent or applicant must ensure the opening and maintenance of a register of interested and affected parties and submit such a register to the competent authority, which register must contain the names, contact details and addresses of: (a) all persons who, as a consequence of the public participation process conducted in respect of that application, have submitted written comments or attended meetings with the proponent, applicant

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or EAP; (b) all persons who have requested the proponent or applicant, in writing, for their names to be placed on the register; and (c) all organs of state which have jurisdiction in respect of the activity to which the application relates.

As such, a comprehensive I&AP database, including all identified and registered I&APs, has been included in Appendix B of this report.

8.5 ISSUES RAISED BY I&APS

The DSR has been made available to I&APs for a period of 30 days (excluding the 20 exclusion period over the December period). All comments and issues raised during this period will be addressed in the Comments and Response Report (CCR), which will be included in the FSR. The Comments and Response Report (CCR) of all stakeholder comments received to date has been included in Appendix B.

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9 DESCRIPTION OF THE ENVIRONMENT

According to Appendix 2, Section 2 (1), of the Amended EIA Regulations 2014 (as amended), a “scoping report must contain the information that is necessary for a proper understanding of the process, informing all preferred alternatives, including location alternatives, the scope of the assessment, and the consultation process to be undertaken through the environmental impact assessment process, and must include:

(g) a full description of the process followed to reach the proposed preferred activity, site and location of the development footprint within the site, including— (iv) the environmental attributes associated with the alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects;

The following chapter outlines the biophysical features of the study area for the proposed expansion. In addition, the socio-economic baseline of the region is provided. The section draws on existing available information within the immediate area as well as municipal and local planning tools and any additional published and unpublished material. The biophysical baseline section looks at aspects relating to climate, topography, geology, soils, flora, and surface and groundwater resources, while the social baseline section will address the administrative and institutional structures, demographic profile and economy.

9.1 CLIMATE

The climate in the Haga Haga to Kei Mouth area is characterised by warm coastal, temperate conditions with mild summer and winter temperatures. Haga Haga normally receives about 694 mm of rain per year, with most rainfall occurring during summer. Haga Haga receives on average the lowest rainfall (14 mm) in July and the highest (95 mm) in March.

The monthly distribution of average daily maximum temperatures (centre chart below) shows that the average midday temperatures for Haga Haga range from 20.1°C in July to 25.4°C in February. The region is the coldest during July when the temperature drops to 9.4°C on average during the night. Refer to Figure 9-1 below.

Figure 9-1: Climate of Haga Haga (saexplorer, 2019).

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9.2 TOPOGRAPHY

The proposed expansion is located on relatively flat coastal grassland (Figure 9-3). The elevation profile indicates a gentle and gradual slope, with the highest elevation point of the proposed development being 50 m above sea level (north western corner), and lowest being 2 m above sea level at the discharge point (Figure 9-2).

Figure 9-2: Elevation profile of the study area, showing the north-south profile (top image) and diagonal profile (bottom image).

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Figure 9-3: Topographical map of the study area

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9.3 GEOLOGY AND SOILS

The underlying geology of the proposed expansion area can be classified as mudstones of the Beaufort Group and sedimentary alluvial sands. According to the SOTER soils association map, the soils underlying the study area can be described as having minimal development, usually shallow on hard or weathering rock with or without intermittent diverse soils (association of Leptosols, Regosols, Calcisols and Durisols, with one or more of Cambisols and Luvisols) (refer to Figure 9-4).

The Sanitation Protocol Assessment (conducted in 2008 for the original expansion) found the presence of massive heavy clays roughly 1.5 m below the surface underlying the study area. This clay layer allows for static water levels, (hence, the name Marshstand), which inhibits both the downward infiltration of surface water and protects underlying groundwater from possible water contamination.

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Figure 9-4: Underlying geology of the study area

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9.4 HYDROLOGY

9.4.1 SURFACE HYDROLOGY

Figure 9-5 below illustrates the general hydrology of the proposed expansion area. It is evident that a portion of the development site falls over one natural wetland and is within 500 m of two adjacent natural wetlands.

A portion of the proposed expansion site also falls over a non-perennial river line, however no NFEPA rivers are directly affected by the proposed development. The nearest NFEPA river, the Mtendwe River, is approximately 1km northeast of the expansion area.

Due to the hydrology of the proposed expansion area as well as the nature of the proposed project, a detailed Wetland and Aquatic Impact Assessment will be conducted for the proposed expansion which will elaborate further on the potential impact of the proposed expansion of the abalone facility on the aquatic environment.

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Figure 9-5: Hydrology map of the study area

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9.4.2 GROUNDWATER

This section references the Sanitation Protocol Assessment (2008) for the previous original expansion of the facility.

Groundwater quality and yields:

Data from the existing boreholes in the area indicates that groundwater quality is generally poor (DWAF class 3). The sustainable yields of the boreholes range from 1l/s to 0.2l/s, whilst the average yield is 0.36l/s (vicinity of Black Rock). There existing nearby boreholes are currently used to provide water to two residences and a few holiday homes at Barracuda Bay.

Aquifer zones:

The area of investigation contains predominantly compact arenaceous and argillaceous strata from the Katberg and Balfour subgroups. The geology is mainly mudstone, sandstone; intruded by dolerite dykes and sheets. The rock is a fractured compact sedimentary rock and has water bearing fractures principally restricted to a shallow zone below groundwater level.

A moderate groundwater potential ranging between 30-40% probability of a successful borehole (yield > 2l/s) is found within this area. The unsaturated zones which normally consists of mudstones/sandstones (massive) will have low transmissivities (<10m/d). This will create the conditions under which the bacteria and possible viruses will be minimised.

Therefore, the capacity of the media to absorb contaminants and create an effective barrier is high. This aquifer zone forms a very good barrier to the movement of contaminants. 9.5 VEGETATION

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

• SA Vegetation Map (Mucina and Rutherford, 2018); and • Forest Classification (NFA)

It should be note that the updated 2018 SA Vegetation Map (herein referred to as the SA VEGMAP) classification has incorporated the Subtropical Thicket Ecosystem Project (STEP) classification.

9.5.1 SA VEGMAP (MUCINA AND RUTHERFORD, 2018)

The vegetation of the study area, as described by the SA VEGMAP (Mucina and Rutherford, 2018), is largely classified as Hamburg Dune Thicket with a small strip of Subtropical Seashore Vegetation (Figure 9-6 below).

Hamburg Dune Thicket (AT 56)

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

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

According to the National Biodiversity Assessment (NBA, 2018), the ecosystem threat status of this vegetation type is currently classified as least concern and has been given a conservation target of 19 %. This vegetation is poorly protected with 31.44 % currently transformed mainly due to Alien invasion by Psidium guava and some degree of erosion.

Majority of the proposed expansion (roughly 50 ha) will take place on vegetation classified as Hamburg Dune Thicket. The coastal strip of Hamburg Dune Thicket will be impacted by the construction of the seawater inlet pipeline and discharge channel.

Subtropical Seashore Vegetation (AZd 4)

This vegetation type occurs in the Eastern Cape and KwaZulu Natal Provinces along beaches, coastal dunes, dune slacks and coastal cliffs of the subtropical coasts of the Indian Ocean (from northeast of Kei Mouth in the Eastern Cape to the Mozambique border), the region includes South East, Transkei and KwaZulu-Natal coasts.

It is characterised by open, grassy, herbaceous and to some extent also dwarf-shrubby, often dominated by a single species of pioneer character. Important taxa found on beaches and dunes include succulent shrubs, such as Phylohydrax carnosa, Scaevola plumieri, and S. sericea, herbaceous climbers, such as Ipomoea pes-caprae, and I. wightii, herbs, such as, Canavalia rosea, Gazania rigens, and gramanoids, such as Ficinia nodosa, Juncus kraussii subsp. kraussii, and Sporobolus virginicus.

According to the National Biodiversity Assessment (NBA, 2018), the ecosystem threat status of this vegetation type is classified as least concern and has a conservation target of 20 %. Almost 10 % of this vegetation unit has already been transformed by urban (largely tourism) development.

A small portion of the Subtropical Seashore Vegetation unit is likely to be impacted by the construction of the seawater inlet pipeline and discharge channel.

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Figure 9-6: SANBI vegetation map of the study area

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9.5.2 FOREST CLASSIFICATION (NFA)

According to the National Forestry Database, the nearest forest patch is approximately 1.8km southwest of the proposed expansion area. This indigenous forest patch is classified as an Eastern Cape Dune Forest or the Southern Coastal Forest Group (Figure 9-7).

The proposed pipeline will transverse a portion of coastal thicket within the East London Coast Nature Reserve (owned by DEFF: Forestry but managed by ECPTA) (refer to Figure 9-9 below). The construction of the inlet pipeline will require clearance of the coastal thicket (0.15 ha) and the relevant permission/permits from DEFF: Forestry and ECPTA will be required prior to this.

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Figure 9-7: Forest patches within the broader study area

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9.6 FAUNA

The following section details the fauna found within the broader study area. A more detailed assessment will be included in the Ecological Impact Assessment to be completed during the EIA phase.

9.6.1 MAMMALS

In terms of wildlife, the rural nature of the area would be conducive for small fauna. Small buck such as Duiker and bushbuck have been recorded in the area. As the existing facility is neighboured by the small coastal towns of Marshstrand (south west) and Fish Bay (north east), the expansion of the existing abalone facility is not expected to have a large impact on the local wildlife.

9.6.2 BIRDS

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

9.6.3 AMPHIBIANS AND REPTILES

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

9.7 LAND USE

The proposed expansion area is currently zoned as agricultural land. The surrounding grassland area (on land owned by Wild Coast Abalone) is currently leased to neighbouring farmers as grazing land for livestock. The vegetation within the expansion footprint of roughly 50 ha can be classified as near-natural thicket and grassland of the Hamburg Dune Thicket, with some areas being somewhat disturbed by grazing and coastal development. The existing abalone facility as well as the neighbouring towns of Marshstrand and Fish Bay make up the low-density urban areas within the study area (Figure 9-8). It is noted that the NFEPA artificial wetlands (dams) indicated in Figure 9-8 below include water bodies within the existing abalone facility. The NFEPA data was obtained, amongst other means, using remote sensing, and as such the abalone facility paddle ponds have been identified as artificial wetland features.

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NFEPA Artificial Wetlands Rivers

Figure 9-8: Land use map of the study area

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9.8 BIODIVERSITY CONSERVATION

South Africa's policy and legislative framework for biodiversity is well developed, providing a strong basis for the conservation and sustainable use of biodiversity. Key components of the national policy and legislative framework for biodiversity include:

 The National Environmental Management: Biodiversity Act (Act 10 of 2004) (NEMBA);  NEMBA List of Ecosystems in need of Protection;  NEMBA List of Threatened or Protected Species;  NEMBA List of Alien Invasive Species;  The National Environmental Management: Protected Areas Act (Act 57 of 2003) (NEMPAA);  The National Biodiversity Strategy and Action Plan (NBSAP) (2015);  The National Biodiversity Assessment (2018);  The National Biodiversity Framework (2008) (NBF); and  The National Protected Area Expansion Strategy (2008) (NPAES).

Other relevant provincial policy and legislative framework for biodiversity conservation includes:

 Eastern Cape Biodiversity Conservation Plan (ECBCP) (2020); and  GKLM SDF and GKLM Strategic Environment Framework (SEA).

9.8.1 PROTECTED AREAS

Target areas (focus areas) for expansion of the Protected Area network in South Africa were identified through a systematic biodiversity planning process undertaken as part of the development of the 2008 NPAES, as well as the 2012 provincial Protected Area Expansion Strategy. The proposed development falls within the Albany Thicket and Wild Coast Priority Area and adjacent the Bisho Kei Focus Area (Figure 9-9 below).

The proposed expansion area also falls directly adjacent to a portion of the East London Coast Nature Reserve, known as the Double Mouth Nature Reserve, and within 5 km of the Cape Morgan Nature Reserve (located to the south west of the proposed development). In addition, the proposed new seawater abstraction pipeline and discharge channel are to be located and within the Amathole MPA (Nyara River Mouth to Great Kei River Mouth) (Figure 9-9 below).

In terms of Section 50(5) of NEMPAA, “No development, construction or farming may be permitted in a nature reserve or world heritage site without the prior written approval of the management authority.” Therefore, written approval will be required from DEFF: Forestry and Eastern Cape Parks and Tourism Agency (ECPTA) for the proposed construction of the seawater inlet pipeline and discharge channel through the adjacent Double Mouth Provincial Nature Reserve. Approval will also be required from national Department of Environment, Forestry and Fisheries (DEFF): Oceans and Coast (through the submission of a CWDP application) for additional discharge into the Amathole MPA.

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Refer to Appendix B6: Authority Meeting Minutes/Correspondence for pre-application engagement with all authorities to date. It should be noted that discussion regarding an offshore wave energy pump proposed are no longer applicable as the offshore wave energy pump will not be part of the proposed expansion going forward.

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Figure 9-9: Protected areas map of the study area

9.8.2 NEMBA THREATENED ECOSYSTEMS

The National Environmental Management: Biodiversity Act (No. 10 of 2004) (NEMBA) has released a national list of ecosystems that are threatened and in need of protection (GN. 1002 of 2011). The proposed expansion footprint does not fall within a threatened ecosystem.

9.8.3 EASTERN CAPE BIODIVERSITY CONSERVATION PLAN (ECBCP)

In addition to national legislation, some of South Africa's nine provinces have their own provincial biodiversity legislation, as nature conservation is a concurrent function of national and provincial government in terms of the Constitution (Act No. 108 of 1996). The relevant biodiversity plan in the Eastern Cape is the Eastern Cape Biodiversity Conservation Plan (ECBCP) (2019).

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The ECBCP maps CBAs based on extensive biological data and input from key stakeholders. Critical Biodiversity Areas (CBA 1 and 2 as well as ESA 1 and 2), as defined by the ECBCP, form the foundation areas where conservation is a priority. These areas provide essential ecosystem services. CBA Areas provide the spatial framework for future spatial development planning, particularly indicating those areas where development needs to be avoided or at best, carefully managed. The ECBCP, although updated, is still mapped at a "coarse" scale. Therefore, it is imperative that the status of the environment, for any proposed development MUST first be verified before the management recommendations associated with the ECBCP are considered. Despite these short- comings, the ECBCP has been adopted by the provincial department of Economic Development, Environmental Affairs and Tourism (DEDEAT) as a strategic biodiversity plan for the Eastern Cape.

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

Table 9-1: ECBCP CBA Land Management Objectives (ECBCP Handbook, 2019) CBA MAP DESIRED LAND MANAGEMENT OBJECTIVE CATEGORY STATE Protected Natural Protected Areas are managed through Protected Area Management Plans and Areas are therefore not managed through the ECBCP. Critical Natural Maintain in a natural state (or near-natural state if this is the current condition of Biodiversity the site) that secures the retention of biodiversity pattern and ecological Area 1 processes: For areas classified as CBA1, the following objectives must apply:  Ecosystem and species must remain intact and undisturbed;  Since these areas demonstrate high irreplaceability, if disturbed or lost, biodiversity targets will not be met;  Important: these biodiversity features are at, or beyond, their limits of acceptable change. If land use activities are unavoidable in these areas, and depending on expert opinion of the condition of the site, a Biodiversity Offset must be designed and implemented. Critical Natural Maintain in natural (or near-natural state if this is the current condition of the Biodiversity site) that secures the retention of biodiversity pattern and ecological processes: Area 2 For areas classified as CBA2, the following objectives must apply:  Ecosystem and species must remain intact and undisturbed;  There is some flexibility in the landscape to achieve biodiversity targets in these areas. It must be noted that the loss of a CBA2 area may elevate other CBA 2 areas to a CBA 1 category.  These biodiversity features are at risk of reaching their limits of acceptable change. If land use activities are unavoidable in these areas, and depending on the condition of the site, set-aside areas must be designed in the layout and implemented. If site specific data confirms that biodiversity is significant, unique and/or highly threatened or that a Critically Endangered or Endangered species is present, Biodiversity Offsets must be implemented. Ecological Functional Maintain ecological function within the localised and broader landscape. A Support functional state in this context means that the area must be maintained in a

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Area 1 semi-natural state such that ecological function and ecosystem services are maintained. For areas classified as ESA1, the following objectives apply:  These areas are not required to meet biodiversity targets, but they still perform essential roles in terms of connectivity, ecosystem service delivery and climate change resilience.  These systems may vary in condition and maintaining function is the main objective, therefore: o Ecosystems still in natural, near natural state should be maintained. o Ecosystems that are moderately disturbed/degraded should be restored

The proposed expansion falls within a terrestrial CBA 2 area as well as a protected area and within an aquatic ESA 1 area, as shown respectively in Figure 9-10 and Figure 9-11 below.

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Figure 9-10: ECBCP Terrestrial CBA Map of the study area

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Figure 9-11 ECBCP Aquatic CBA Map of the study area

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9.8.4 PLANT SPECIES OF CONSERVATION CONCERN

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

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

Table 9-2 below lists all potential plant and tree species likely to be found within the broader study area. A detailed site investigation will be conducted by the Ecological specialist for plant and tree SCC’s that may be located within the development footprint during the EIA phase of the project.

Table 9-2: Potential plant SCCs likely to occur within the study area

GENUS AND SPECIES ENGLISH COMMON NAMES STATUS

Asclepias praemorsa Milkweed SANBI Red List: Least Concern PNCO Protected

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

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

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

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

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

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

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

Umtiza listerana Umtiza SANBI Red List: Vulnerable

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

9.8.5 ALIEN INVASIVE PLANT SPECIES

Table 9-3 details potential alien invasive vegetation likely to occur within the study area.

Table 9-3: Potential alien invasive plants found within the study area FAMILY GENUS SPECIES STATUS Araceae Pistia stratiotes - NEMBA Category 1b - CARA: Category 1; Asteraceae Cirsium vulgare - NEMBA – Category 1b Boraginaceae Echium plantagineum - CARA: Category 1; - NEMBA – Category 1b Cactaceae Opuntia Several species - CARA: Category 1; - NEMBA – Category 1b Convolvulaceae Ipomoea indica - CARA: Category 2; - NEMBA – Category 1b Convolvulus arvensis - CARA: Category 1; - NEMBA – Category 1b Fabaceae Acacia mearnsii - NEMBA – Category 2 Acacia longifolia - CARA: Category 1; - NEMBA – Category 1b Senna didymobotrya - CARA: Category 1; - NEMBA – Category 1b Myrtaceae Psidium guajava - CARA: Category 2; - NEMBA – Category 3 Solanaceae Cestrum laevigatum - CARA: Category 1; - NEMBA Category 1b Solanum Several species - NEMBA Category 1b Verbenaceae Lantana camara - NEMBA Category 1b

9.8.6 GREAT KEI LOCAL MUNICIPALITY SPATIAL DEVELOPMENT FRAMEWORK (SDF) AND STRATEGIC ENVIRONMENTAL FRAMEWORK (SEA)

The Great Kei Local Municipality (GKLM) SDF, which incorporates environmental guidelines from the GKLM Strategic Environment Framework (SEA), provides guidelines for spatial planning within the GKLM. Table 9-4 below summarises these environmental guidelines.

The GKLM SDF and SEA identifies aquaculture as a potential tool for coastal economic development. The site in consideration falls within a coastal corridor, on the edge of a protected area (Double Mouth Nature Reserve), and outside of the urban edge of Haga Haga in terms the Spatial Development Framework.

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Table 9-4: Summary of GKLM Environmental Guidelines for spatial planning NO-GO Areas GO-BUT Areas Limited Development Areas No Development Inside Urban Edges Adjacent to Urban Edge or Areas Away from Urban Edge within Transitional Area Areas of high Urban Settlement: Limited by: Limited by: environmental  Residential  EIA process;  EIA process; sensitivity and  Public-Funded  Low density;  Low density; conservation value: Housing  Density/footprint/impact  Density/footprint/impact  Primary dune  Resort restrictions; restrictions; systems Development  Not in areas of  Not in areas of  Indigenous forests  Business and environmental sensitivity; environmental sensitivity;  Proclaimed nature Trade  Unique & Sustainable  Unique & Sustainable reserves;  Other Developments; Developments;  STEP Protected,  Must show tangible  Must show tangible Process and Develop from Inside- economic benefits to economic benefits to Critically Outward (Phasing) broader community; broader community; Endangered areas;  Clustering of built form;  Clustering of built form;  Rivers, estuaries BUT, no for:  Aesthetic controls;  Aesthetic controls; and undisturbed  Environmentally  Mitigate impacts;  Mitigate impacts; riparian zones of sensitive areas  Show net gains for the  Show net gains for the rivers; within the urban environment; environment;  Diverse coastal edge Limited  Appropriateness of  Appropriateness of grasslands and development in development in Coastal development in Coastal coastal thicket Coastal Buffer Buffer Zone; and Buffer Zone; and vegetation types; Zone  Provision of services  Provision of services and  Lack of services  Dynamic coastal areas including primary and mobile dunes and areas within 50m of the high water mark, including coastal cliffs. Zoning: Open Space Zoning: Various Zoning: Mixed – Agriculture Zoning: Mixed – Agriculture Zone III (nature Zone I/Resort Zone I or Zone I/Resort Zone I or reserve) or Special II/Residential/Open II/Residential/Open Zone: Conservation Space/Special Zone Space/Special Zone

Refer to Appendix E for additional information regarding applicable spatial planning guidelines within the GKLM.

9.9 SOCIO-ECONOMIC PROFILE

The proposed expansion of the Wild Coast Abalone Facility falls within ward 5 of the GKLM, of the Amathole District Municipality (ADM), within the Eastern Cape Province. The GKLM is covers an area of 1 421 square kilometres (km²).

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9.9.1 POPULATION

According to StatsSA (2011) the total population in the GKLM is 31 692, of which 52 % are female and 48 % are male of the population. The GKLM age distribution pyramid shows that there is a larger young generation as per the 2016 community survey by Statistics South Africa. About 66 % of the populations fall between 15-64 years, whilst 6 % are in the pension group (over 65 years) and only 27 % are less than 15 years.

9.9.2 EMPLOYMENT

The GKLM has an employment rate of 29 % of the total population and an unemployment rate of 23 % of the total population, with the remaining population not being economically active (SSA, 2011).

9.9.3 EDUCATION

Illiteracy levels have significantly improved over the years. In 2011, 15 % of the total population had no schooling in comparison to 8 % in 2016. 59.4 % of the population have completed grade 9 or higher, with 23.4 % of the population have completed matric or higher.

9.9.4 LIVING CONDITIONS

There are 10 310 households in the municipality, with an average household size of 3.4 persons per household. Approximately 20.6 % of households have no access to electricity, 8 % of households have access to piped water inside the dwelling, and 20 % of households have no access to any toilets (SSA, 2011).

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10 PRELIMINARY SENSITIVITY ANALYSIS

The following section provides a preliminary assessment of the sensitivity of the study area.

10.1 CONSERVATION AND SPATIAL PLANNING TOOLS

Several conservation planning tools are available for the study area. These tools allow for the potential identification of any sensitive and important areas from an ecological perspective at the early stage of a development and allow for the fine-tuning of plans and infrastructure layouts.

The following tools identified as relevant to the project are summarised below:  NBA (2018) ecosystem threat status;  Land cover;  Rivers and wetlands;  NEMBA Threatened Ecosystems; and  ECBCP CBA’s.

10.1.1 NBA (2018) ECOSYSTEM THREAT STATUS

The NBA (2018) has classified the Hamburg Dune Thicket vegetation unit as least concern in terms of its ecosystem threat status. The vegetation within the expansion footprint of roughly 50 ha can be classified as near-natural thicket and grassland of the Hamburg Dune Thicket, with some areas being somewhat disturbed from livestock grazing.

10.1.2 LAND COVER

The following land covers have been identified:  Transformed/developed areas;  Natural thicket;  Near-natural grassland; and  Waterbodies.

The proposed expansion area is zoned as agricultural land and is currently used as grazing land. The natural vegetation is largely intact with some areas being somewhat disturbed from livestock grazing and activities relating to the existing abalone facility. Several alien invasive vegetation species were observed. A large wetland is located within the proposed expansion area, to the east of the existing facility.

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10.1.3 RIVERS AND WETLANDS

Water is considered as a scarce resource in South Africa. All identified rivers (including drainage lines) and wetlands (artificial and natural) are protected by legislation and requires licencing from DWS to impact on them. The surrounding watercourses and wetlands within the study area are considered to be highly sensitive.

10.1.4 ECBCP CBA’S

The proposed expansion falls within a coastal corridor 1 (T1) of a terrestrial CBA 2 area, with some service infrastructure (seawater inlet pipeline and discharge channel) proposed to be developed within a protected area (Double Mouth Nature Reserve and the Amathole MPA).

10.2 SENSITIVITY ALLOCATION

The preliminary sensitivity map was developed based on the methodology presented in Table 10-1 below, for the study area. The allocation of criteria was based on both the desktop biophysical description of the site as well as observations made during the initial site visit.

Table 10-1: Sensitivity criteria CRITERIA LOW SENSITIVITY MODERATE SENSITIVITY HIGH SENSITIVITY 1 Topography Level or even Undulating; fairly steep Complex and uneven with slopes steep slopes 2 Vegetation - Extensive Restricted to a particular Restricted to a specific Extent or habitat throughout the region / zone locality / site type in the region region 3 Conservation Well conserved/ Not well conserved, Not conserved - has a high status of fauna / independent of moderate conservation conservation value flora or habitats conservation value value 4 Species of None, although No Species of Conservation One or more Species of conservation occasional regional Concern, some Conservation Concern, or concern - endemics indeterminate or rare more than 2 endemics or Presence and endemics rare species number 5 Habitat Extensive areas of Reasonably extensive areas Limited areas of this fragmentation preferred habitat of preferred habitat habitat, susceptible to leading to loss of present elsewhere elsewhere and habitat fragmentation viable in region not susceptible to fragmentation populations susceptible to fragmentation 6 Biodiversity Low diversity or Moderate diversity, and High diversity and species contribution species richness moderately high species richness richness

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

8 Rehabilitation Site is easily There is some degree of Site is difficult to potential of the rehabilitated difficulty in rehabilitation of rehabilitate due to the area or region the site terrain, type of habitat or species required to reintroduce 9 Disturbance due Site is very There is some degree of The site is hardly or very to human disturbed or disturbance of the site slightly impacted upon by habitation or degraded human disturbance other influences (alien invasive species) 10 Ecological Habitat widely Intermediate role in Key habitat involved in function represented in the ecological function ecological processes landscape not (ecological corridors and specifically network areas or key niche harbouring any habitats) unique habitat features…etc. 11 Ecological Little to no Some ecological services. Various ecological services. Services ecological services Areas should be conserved.

The proposed Wild Coast Abalone Facility expansion falls within areas of HIGH to LOW sensitivity, as explained in Table 10-2 below and Figure 110-1 below. Findings from the specialist studies during the EIA phase of the assessment will provide a more accurate description of the sensitivity of the proposed expansion area.

Table 10-2: Sensitivity assessment of the study area SENSITIVE ENVIRONMENT DESCRIPTION RISK

Aquatic Environment  Watercourses HIGH  Wetlands

Double Mouth Nature Reserve HIGH Protected areas Amathole MPA

Natural Vegetated Areas – Thicket Disturbed areas of natural vegetation MODERATE 50 m river buffer areas MODERATE Aquatic buffer areas 500 m wetland buffer areas Near-Natural Vegetated Areas – Grassland Natural areas, currently used as grazing LOW

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SENSITIVE ENVIRONMENT DESCRIPTION RISK land.

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Figure 110-1: Preliminary Sensitivity Map

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11 IMPACT IDENTIFICATION AND PRELIMINARY ASSESSMENT

According to Appendix 2, Section 2 (1), of the EIA Regulations 2014 (as amended) a “scoping report must contain the information that is necessary for a proper understanding of the process, informing all preferred alternatives, including location alternatives, the scope of the assessment, and the consultation process to be undertaken through the environmental impact assessment process, and must include:

(g) a full description of the process followed to reach the proposed preferred activity, site and location of the development footprint within the site, including— (v) the impacts and risks which have informed the identification of each alternative, including the nature, significance, consequence, extent, duration and probability of such identified impacts, including the degree to which these impacts— (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be avoided, managed or mitigated; (vi) the methodology used in identifying and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks associated with the alternatives; (vii) positive and negative impacts that the proposed activity and alternatives will have on the environment and on the community that may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects; (viii) the possible mitigation measures that could be applied and level of residual risk; (ix) the outcome of the site selection matrix.

During the scoping phase, impacts are assessed and rated on a broader issue level and are regarded as preliminary. This is because, at the scoping phase of the EIA process, a limited amount of information on project-related detail is available, and baseline data on the project affected environment and social systems has not yet been gathered other than from the initial site visit. This information requires input from the specialist assessments, which are only undertaken at the completion of the scoping phase and therefore a definitive assessment of project specific impacts cannot be completed at this stage. The environmental and social consequences of the project and alternatives are discussed more broadly than what is required in the EIR.

11.1 PRELIMINARY IMPACTS IDENTIFIED

The technical scope (Table 11-1 below) maps out, at a high level, the categories or types of impacts that are expected under various themes for all phases of the proposed development.

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Table 11-1: Technical Scope of Issues identified during all phases of the proposed expansion of the Wild Coast Abalone Facility. THEME POTENTIAL ISSUES SOURCE OF ISSUE POTENTIAL RECEPTORS PROJECT PHASE ASSESSMENT PLANNING CONSTRUCTION OPERATIONAL ACTIONS AND DESIGN General EIA and  ECPTA Environmental Legal and policy obtaining  Licensing and Authorisations  DWS X X X policy compliance authorisation from  DEDEAT relevant CA  Terrestrial environment  Aquatic environment  Siting and placement Site establishment  Heritage and X General EIA  Footprint creep paleontological resources  Surrounding landowners  Terrestrial environment  Siting and placement  Aquatic environment  Earthworks Roads  Heritage and X X X General EIA  Runoff and sedimentation paleontological resources  Dust  Surrounding landowners  Terrestrial environment Bulk service  Aquatic and marine  Siting and placement infrastructure environment X General EIA  Earthworks installation  Heritage and Built paleontological resources environment  Siting and placement  Terrestrial environment  Runoff and sedimentation Material stockpiling  Aquatic environment X General EIA  Alien vegetation  Surrounding landowners  Dust General EIA; Stormwater  Inappropriate infrastructure  Terrestrial environment X X X Stormwater management  Poor maintenance  Aquatic environment Management Plan  Poor planning for storage, handling and disposal of  Terrestrial environment general and hazardous  Aquatic and marine Waste management waste X X X General EIA environment  Construction rubble  Surrounding landowners  General refuse  Sewage waste

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THEME POTENTIAL ISSUES SOURCE OF ISSUE POTENTIAL RECEPTORS PROJECT PHASE ASSESSMENT PLANNING CONSTRUCTION OPERATIONAL ACTIONS AND DESIGN  Hazardous wastes  Inappropriate disposal of organic (flesh and non-flesh) waste produced the facility.  Ineffective planning and  Terrestrial environment Sewage package plant design for the management  Aquatic and marine Sanitation Protocol X X design and operation and treatment of sewage environment Assessment effluent  Surrounding landowners  Construction activities  Terrestrial and aquatic Soil erosion  Inadequate erosion X environment management/rehabilitation Loss of natural  Flora in study area  Vegetation clearance X vegetation  Hamburg Dune Thicket Invasion of alien  Fauna and flora in study  Habitat destruction X X X vegetation species area Terrestrial Ecological Impact Loss of Species of environment  SCCs in development Assessment Conservation Concern  Vegetation clearance X X X footprint (SCC)  Fauna within the Wildlife disturbances  Construction activities and development site and X and mortalities operations surrounds Loss/Fragmentation  Habitats within  Clearance of vegetation X of Habitats development footprint Changes to fluvial  Vegetation clearance geomorphology and  Earthworks  Aquatic environment X hydrology  Siting and placement of Ecological Impact Disturbance of infrastructure Assessment; aquatic and wetland  Construction and Aquatic  Aquatic environment X Aquatic/Wetland vegetation and operational activities environment Impact Assessment; habitat  Waste management and Sanitation  Hazardous substances  Aquatic, Marine and protocol  Erosion and sedimentation Terrestrial environment Water quality X X  Sewage treatment and  Neighbouring residents discharge on site.

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THEME POTENTIAL ISSUES SOURCE OF ISSUE POTENTIAL RECEPTORS PROJECT PHASE ASSESSMENT PLANNING CONSTRUCTION OPERATIONAL ACTIONS AND DESIGN  Earthworks and excavations Disturbance to the  Blasting  Marine environment dune, beach and X  Installation of infrastructure  Surrounding residents inter-tidal zones Ecological Impact Seashore and Assessment; Marine Erosion and  Channelling from discharge Marine Impact Environment channelling of  Marine environment X outlet Assessment seashore Discharge of enriched  Marine biodiversity impact  Marine environment X seawater effluent Environmental Biosecurity risk to the  Abalone facility Biosecurity Risk  Spread of infectious diseases X Biosecurity marine environment  Marine environment Assessment  Operation of the Abalone Stimulation to the facility  Local Economy Socio-Economic local and national X X  Growth of the aquaculture  National Economy Impact Assessment economy industry in South Africa  Planning and design,  Local community Job creation construction and X X X  General public operational activities  Staff  Use, transport and storage  Labourers of hazardous substances Health and safety  Surrounding residents and X X X  Machinery and excavations tourism  Fire risks Socio-economic  Wild Coast Abalone facility  Inadequate supply causing  Surrounding residents Economic Impact Water supply X X strain on water supply  Aquaculture facility Assessment; and  Vegetation clearance  Surrounding landowners General EIA Air quality and dust  Earthworks and community X control  Construction activities  Staff and labourers  Construction activities  Surrounding landowners Noise  Operation of the expanded and community X X Abalone facility  Staff and labourers  Inappropriate disposal of  Surrounding landowners Odours and nuisance organic and inorganic waste and community X pests  Storage of abalone feed can  Staff and labourers

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THEME POTENTIAL ISSUES SOURCE OF ISSUE POTENTIAL RECEPTORS PROJECT PHASE ASSESSMENT PLANNING CONSTRUCTION OPERATIONAL ACTIONS AND DESIGN attract vermin  Construction activities  Buildings and infrastructure  Surrounding landowners Visual  Operation of the Abalone X X X and community facility  Light pollution  Construction activities  Surrounding landowners Traffic  Increased number of X X and general public transport vehicles Loss of cultural,  Siting and placement  Heritage resources and Heritage and heritage and  Paleontological findings Heritage Impact paleontological Earthworks X X paleontological Assessment environment resources  Inadequate planning and  Aquatic, marine and Rehabilitation Inadequate provisioning terrestrial environment and rehabilitation and X X X General EIA  Lack of maintenance of  Surrounding landowners maintenance maintenance infrastructure and general public

In addition to these preliminary impacts, Interested and Affected Parties have raised concerns over property values, odours and privacy.

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11.2 PRELIMINARY IMPACT ASSESSMENT

The tables below provide a preliminary assessment of potential impacts relating to the various project alternatives through all project phases. The impact rating methodology detailed in section 12.7 below was used to determine pre- and post-significance of potential impacts. The implementation of the ‘No-Go Alternative’ will result in the status quo being maintained (current land use being that of grazing land), and unless stated otherwise below, will result in a ‘No Effect’ significance for potential impacts identified. A summary of significant preliminary impacts identified is provided in the section 13.2 below.

11.2.1 PLANNING AND DESIGN PHASE IMPACTS

Table 11-1-1: Planning and Design Phase Preliminary Impact Assessment

PLANNING AND DESIGN PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES CAUSE AND COMMENT ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION IMP IMP BABILITY OF BABILITY OF NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

Environmental Policy  All relevant legislation and policy must be consulted, and the During the planning and design phase, failure to adhere to proponent must ensure that the project is compliant with such existing policies and legal obligations and obtain the necessary legislation and policy. All  These should include (but are not restricted to): NEMA, ICMA,

authorisations could lead to the project conflicting with local, e Legal and policy Alternatives HIGH MLRA, ECBCP, and Local Municipal bylaws.

provincial and national policies, legislation, etc. This could rsible LOW NEGATIVE compliance (excluding No- NEGATIVE  All relevant permits and authorisations including Water Use Direct Direct result in lack of institutional support for the project, overall Severe National National Negativ Long-term Long-term Reve License (WUL), Coastal Lease Agreements, Coastal Waters May Occur Occur May Go) Achievable project failure and undue disturbance to the natural Discharge Permits (CWDP), Building Plan Approvals and Plant environment. removal/TOPS permits must be in place prior to commencement

Resource will be partly lost partly be will Resource of construction/the activity in question. Built Environment  The design and location of the construction site must adhere to

All During the planning and design phase, inadequate planning for aquatic and coastal buffers and ensure minimal impacts to the Alternatives the placement of the construction site camp, storage or e MODERATE surrounding environment and residential houses surrounding

Site establishment rsible LOW NEGATIVE (excluding No- materials, etc. can lead to the damage and degradation of NEGATIVE evable the site. Easily Easily Direct, Direct, Negativ

Moderate Moderate lost partly 

Reve The placement of the construction camp should be sited in an Study area area Study May Occur Occur May Go) surrounding natural areas. Achi Cumulative Cumulative Medium-term Medium-term

Resource will be be will Resource area already disturbed, if possible.  A Stormwater Management Plan must be developed by a All qualified engineer and implemented during the construction and

During the planning and design phase, the inappropriate e Stormwater Alternatives MODERATE operation phase of the facility expansion.

design of storm water infrastructure will lead to stream rsible LOW NEGATIVE Management (excluding No- NEGATIVE  An Aquatic Impact Assessment must be undertaken to Direct, Direct, sedimentation and erosion of the surrounding area. Severe Negativ Probable Probable partly lost partly

Reve determine the potential impacts that rerouting of stormwater Study area area Study

Go) Achievable Cumulative Cumulative Medium-term Medium-term

Resource will be be will Resource may have on the surrounding aquatic environment.  A Waste Management Plan must be compiled prior to the commencement of construction for all waste streams generated during construction and, to be implemented during construction All During the planning and design phase, inadequate planning for and operation of the proposed development. Alternatives the management of waste streams, including solid waste, e MODERATE  A WUL must be obtained for the discharge and/or irrigation with

Waste Management rsible LOW NEGATIVE (excluding No- sewage and effluent, could lead to pollution in the study area NEGATIVE treated effluent on site, prior to the construction and operation Severe Severe

Negativ of the activity. Reve Study area area Study May Occur Occur May

Go) and surrounding areas. Short-term  A CWDP must be obtained for the proposed discharge of Easily Achievable Achievable Easily Direct, Cumulative Cumulative Direct, additional treated abalone effluent into the marine

Resource will be partly lost partly be will Resource environment, prior to the commencement of that activity.

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PLANNING AND DESIGN PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES CAUSE AND COMMENT ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION BABILITY OF BABILITY OF IMP IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

 An appropriate sewage treatment system must be designed and implemented by a qualified engineer with input from a geo- hydrologist, where required.  The findings of the Groundwater Protocol assessment must be adhered to. All During the planning and design phase, ineffective planning and Sewage Package e  Sewage treatment systems must be located above any 1:100- Alternatives design for the management and treatment of sewage effluent HIGH MODERATE

Plant Design & rsible year flood line and located at least 100m away from the high- (excluding No- can result in contamination of soil, groundwater and surface NEGATIVE NEGATIVE

Operation Severe water tide mark and 500m away from a wetland. Negativ water (rivers and streams). area Study Reve May Occur Occur May Go) Achievable Medium-term Medium-term  A water quality monitoring programme must be established

Direct, Cumulative Cumulative Direct, prior to the operation of the sewage treatment system and must be implemented during the operation phase of the facility Resource will be partly lost partly be will Resource expansion to ensure that the discharge of treated effluent meets the required standards. Terrestrial Environment

During the planning and design phase, inadequate planning All  An Alien Vegetation Management Plan must be developed prior

and provisioning for the removal and management of alien e Invasion of alien Alternatives MODERATE to construction and must be implemented throughout

vegetation throughout all phases of the development could rsible LOW NEGATIVE vegetation species (excluding No- NEGATIVE construction and operation to mitigate the establishment and result in the invasion of alien vegetation in both terrestrial and Negativ Probable Probable Moderate Moderate partly lost partly spread of undesirable alien plant species. Reve Go) area Study

riparian areas. Medium-term Resource will be be will Resource Easily Achievable Achievable Easily Direct, Cumulative Cumulative Direct,  A walkthrough must be done by a suitably qualified individual to identify and confirm the occurrence of plant/tree SCC’s within All During the planning and design phase, the inappropriate the study area prior to any vegetation clearing.

Loss of Species of e Alternatives provisions made for the identification of plant SCCs onsite HIGH  Protected plants and/or trees which need to be relocated/ MODERATE

Conservation rsible (excluding No- prior to vegetation clearing will lead to the loss of identified NEGATIVE destroyed, must obtain the relevant DEDEAT/TOPS permits prior NEGATIVE

Concern (SCC) Severe Negativ Localised Localised

partly lost partly the removal/destruction of protected plant/tree species. Reve May Occur Occur May Go) and unidentified plant and animal SCC. Achievable Medium-term Medium-term

Resource will be be will Resource  Plant SCCs must be relocated to outside of the construction Direct, Cumulative Cumulative Direct, footprint, as identified by a suitably qualified individual. Socio-Economic Environment  A health and safety plan in terms of the Occupational Health and All During the planning and design phase, inadequate planning Safety Act (Act No 85 of 1993) must be drawn up by and HSE Alternatives and provisions for ensuring compliance with the Health and e HIGH officer prior to construction to ensure workers safety.

Health and safety rsible  An Emergency Preparedness Plan for fire safety and the use, LOW NEGATIVE (excluding No- Safety Act could result in injury or death, and/or NEGATIVE

Severe Severe handling, storage and disposal of hazardous substances must be Negativ Localised Localised partly lost partly Reve May Occur Occur May Go) contamination of the surrounding environment. Achievable developed for the construction and operation phase prior to Medium-term Medium-term Resource will be be will Resource

Direct, Cumulative Cumulative Direct, construction commencing.

Alternative 4: Combination During the planning and design phase, inadequate planning for  Borehole and rainwater yields must be determined to ensure the supply will be sufficient for the facility’s potable water needs.

of rainwater obtaining water use licensing and investment in infrastructure e HIGH  Should borehole water be used as drinking water, provisions

Water supply harvesting to ensure a self-sustaining fresh water supply for the facility rsible LOW NEGATIVE NEGATIVE must be made for treating the water to standard.

(primary) and may result in supply constraints during the operational phase Severe Negativ

Reve  The findings and recommendations of the Groundwater May Occur Occur May Study Area Area Study Achievable

use of the of the facility. Medium-term Protocool must be adhered to. boreholes Cumulative Direct, Resource will not be lost be not will Resource

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PLANNING AND DESIGN PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES CAUSE AND COMMENT ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION BABILITY OF BABILITY OF IMP IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

All During the planning and design phase, inadequate  Screening measures, such as indigenous tree species must be Alternatives consideration given towards mitigating the visual obtrusion of e HIGH planted to create a visual screen to minimise the visual intrusion

Visual rsible to the surrounding residents. LOW NEGATIVE (excluding No- the development may visually impact on the surrounding NEGATIVE Direct, Direct, Severe Severe  An ecologist/botanist must recommend which tree species will Negativ Localised Localised Reve May Occur Occur May Go) community, affecting ones ‘sense of place’ within the area. Achievable Cumulative Cumulative be partly lost partly be Resource will will Resource be appropriate for the area in question. Medium-term Medium-term Heritage and Paleontological environment  Any comments and/or instructions received from the Eastern Cape Provincial Heritage Resources Authority (ECPHRA) and the South African Heritage Resource Agency (SAHRA) must be taken into consideration prior and during construction.  All necessary permits must be in place prior to the removal/destruction of any potential heritage or paleontological During the planning and design phase, failure to identify All resources, if found on site during the site walkthrough by the

Loss of heritage and culturally important artefacts, graves and various other e Alternatives HIGH ECO.

paleontological heritage/archaeological aspects could potentially result in the rsible  Prior to construction, the ECO and contractor must be made LOW NEGATIVE (excluding No- NEGATIVE Direct Direct resources potential loss of sites of archaeological, cultural and Severe aware of potential new fossil findings. They must familiarise Negativ Localised Localised Reve May Occur Occur May Go) Achievable paleontological significance due to poor planning. Permanent themselves with the sort of fossils they may be found in this area.  Should any graves be identified prior to construction, the area Resource will be partly lost partly be will Resource must be demarcated and considered a No-Go area. The local heritage authority must be notified.  A full grave relocation process must be followed in accordance with the applicable regulations, should this be required. Rehabilitation and maintenance  A Rehabilitation & Maintenance Plan must be compiled during the planning and design phase and must be implemented during All the construction and operational phase of the development.

Inadequate During the planning and design phase, inadequate planning for e Alternatives HIGH  The plan must detail measures that ensure the day-to-day

rehabilitation and rehabilitation could lead to degradation of the study area and rsible construction activities and operations of the development do LOW NEGATIVE (excluding No- NEGATIVE Direct Direct maintenance surrounding areas. Severe not cause unnecessary degradation to the surrounding Negativ Localised Localised Reve May Occur Occur May Go) Achievable environment and to ensure on-going maintenance of all service Medium-Term Medium-Term infrastructure is undertaken at regular intervals to minimize risks

Resource will not be lost be not will Resource to the surrounding environment.

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11.2.2 CONSTRUCTION PHASE IMPACTS

Table 11-1-2: Construction Phase Preliminary Impact Assessment

CONSTRUCTION PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES CAUSE AND COMMENT ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION BABILITY OF BABILITY OF IMP IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

Environmental Policy  The developer must employ an independent Environmental Control Officer (ECO) for the construction phase to ensure that construction is implemented according to specifications in the EA and EMPr. Monthly audits must be undertaken.

During the construction phase, failure to adhere to existing e Legal and policy All Alternatives HIGH  Copies of all applicable licenses, permits and managements

policies and legal obligations could result in non-compliances rsible LOW NEGATIVE compliance (excluding No-Go) NEGATIVE plans (EA, EMPr, Water Use Licenses, Permits, etc.) must be Direct Direct resulting in legal actions taken against the developer. Severe National National Negativ available on-site at all times, and adhered to. Reve Long-term Long-term May Occur Occur May Achievable Achievable  Environmental Awareness Training must be included in site meetings/talks with all workers, and all No-Go areas must be Resource will not be lost be not will Resource clearly communicated and demarcated. Built Environment  The installation of service infrastructure (i.e. roads, pipelines,

cabling) must adhere to the conditions of all permits, such as

Bulk Service During the construction phase, failure to adhere to no-go e All Alternatives HIGH Forestry permits, Coastal Lease Agreement and WUL, should able

Infrastructure areas can lead to the damage and degradation of rsible they cross any watercourses. LOW NEGATIVE (excluding No-Go) NEGATIVE Direct Direct Installation surrounding natural areas. Severe  Sewage treatment systems must be located above any 1:100- Negativ Reve Study area area Study May Occur Occur May Achiev Short-term Short-term partly be lost be partly Resource will will Resource year flood line and located at least 100m away from the high- water tide mark and 500m away from a wetland.  Topsoil which is excavated/removed during earthwork activities must be stockpiled on site for use during rehabilitation.  No construction material is to be stored within 50 m of a

During the construction phase, placement of stockpiles e All Alternatives MODERATE watercourse or wetland system.

Material Stockpiling within sensitive no-go areas may lead to sedimentation of rsible LOW NEGATIVE (excluding No-Go) NEGATIVE  Stockpiles must be monitored for erosion and mobilisation of the surrounding aquatic environment. Negativ Moderate Moderate

Reve materials towards watercourses. Study area area Study May Occur Occur May Achievable Achievable Short-term Short-term  If this is noted by an ECO, suitable cut-off Direct, Cumulative Cumulative Direct, drains/berms/sediment traps must be placed between the Resource will not be lost be not will Resource stockpile area and the nearest watercourse.

During the construction phase, the inappropriate routing and  The conditions set out in the Storm Water Management Plan e e Stormwater All Alternatives containment of stormwater will lead to erosion and MODERATE must be implemented and adhered to.

rsible LOW NEGATIVE Management (excluding No-Go) sedimentation of wetlands and watercourses, adversely NEGATIVE  The ECO must monitor for erosion and mobilization of sediment Direct, Direct, Negativ Probable Probable Moderate Moderate Reve Study area area Study Achievable Achievable affecting the surrounding environment. Short-term and recommend appropriate remedial action, where required. Cumulative Cumulative partly be lost be partly Resource will will Resource  A Waste Management Plan must be implemented and During the construction phase, litter on site may attract adhered to.  The ECO must monitor the site camp and construction site for

vermin, detract from the visual appeal of the area, and e Waste All Alternatives MODERATE litter and waste.

pollute the surrounding areas. Construction rubble left onsite rsible LOW NEGATIVE

Management (excluding No-Go) NEGATIVE lost  All waste temporarily stored on site must be done so in closed could pollute the area and encourage the growth of Negativ

Moderate Moderate bins/covered skips and removed from the site and Reve Study area area Study May Occur Occur May Short-term Short-term opportunistic alien vegetation. transported to the closest licensed landfill site. Easily Achievable Achievable Easily Direct, Cumulative Cumulative Direct, Resource will not be be not will Resource  No waste must be disposed of on site.

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CONSTRUCTION PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES CAUSE AND COMMENT ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION BABILITY OF BABILITY OF IMP IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

 Adequate sanitary and ablutions facilities must be provided for construction workers.

During the construction phase, failure to provide adequate e MODERATE  Should portable ablutions be provided, they must not be placed

onsite sanitation for labourers may result in runoff rsible LOW NEGATIVE NEGATIVE within 50m of a watercourse/tributary. Easily Easily

transferring contaminants into the surrounding environment. Direct, Negativ Probable Probable Moderate Moderate

Reve  Portable ablutions must be serviced regularly to reduce the risk Study area area Study lost be not Achievable Achievable Short-term Short-term Cumulative Cumulative Resource will will Resource of surface or groundwater pollution. Terrestrial Environment

During the construction phase, uncontrolled earthworks and All Alternatives site clearing can result in the unnecessary loss of topsoil and e MODERATE  The ECO must monitor for erosion and mobilization of

Soil erosion rsible sediment and recommend appropriate remedial action if LOW NEGATIVE (excluding No-Go) result in erosion and degradation to the surrounding NEGATIVE Easily Easily

Direct, Direct, required. Negativ Probable Probable Moderate Moderate Reve Study area area Study not be lost be not Achievable Achievable environment. Short-term Cumulative Cumulative Resource will will Resource

During the construction phase, the expansion of the e All Alternatives MODERATE MODERATE

proposed abalone facility will result in a loss of coastal rsible (excluding No-Go) NEGATIVE NEGATIVE

grasslands. Direct,  An Ecological Impact Assessment must be undertaken during Definite Definite Negativ Localised Localised Moderate Moderate Reve Achievable Achievable Short-term Short-term Cumulative Cumulative be partly lost partly be Resource will will Resource the EIA phase to determine and assess all potential impacts associated with vegetation clearance and recommend suitable Seawater mitigation measures going forward. Abstraction  The Ecological Impact Assessment must determine the extent

During the construction phase, the construction of a new e Loss of natural Alternative 1: HIGH of loss to all vegetation types and recommended biodiversity MODERATE

pumphouse and seawater abstraction inlet will result in the rsible offsets, where required. vegetation Construction of NEGATIVE NEGATIVE

loss of coastal thicket. Severe Definite Definite Negativ Localised Localised partly lost partly Reve Achievable Achievable

new pumphouse Short-term

and inlet be will Resource Direct, Cumulative Cumulative Direct,

The status quo will be maintained. The coastal grassland within the proposed expansion footprint will be continued to e LOW  Landowner and livestock farmers to ensure overgrazing does

No Go Alternative rsible LOW NEGATIVE be leased out to surrounding livestock as grazing land, with NEGATIVE not occur. Slight Slight Direct, Direct, Negativ Probable Probable Localised Localised Reve not be lost be not

minor disturbance expected. Achievable Cumulative Cumulative Resource will will Resource Medium-term Medium-term  The approved Alien Vegetation Management Plan must be During the construction phase, the removal of natural implemented during the construction phase to reduce the

vegetation creates open habitats that favour the e Invasion of alien All Alternatives MODERATE establishment and spread of undesirable alien plant species.

establishment of undesirable alien plant species in areas that rsible  Alien plants must be removed from the site through LOW NEGATIVE vegetation species (excluding No-Go) NEGATIVE

are typically very difficult to eradicate and may pose a threat lost be appropriate methods such as hand pulling, application of Negativ Probable Probable Moderate Moderate Reve Study area area Study Achievable Achievable chemicals, cutting etc. as in accordance to the NEMBA: Alien

to neighbouring ecosystems Medium-term Resource will not not will Resource

Direct, Cumulative Cumulative Direct, Invasive Species Regulations.

During the construction phase, construction activities  The findings and recommendations of the Ecological and

Loss of Species of e All Alternatives associated with vegetation clearance may permanently MODERATE Aquatic Impact Assessment must be adhered to.

Conservation rsible  The Ecological Impact Assessment must determine the extent LOW NEGATIVE (excluding No-Go) destroy or result in the loss of plant and animal SCC present NEGATIVE

Concern (SCC) Direct, of loss to all vegetation types and recommended biodiversity Definite Definite Negativ Localised Localised Moderate Moderate Reve not be lost be not

on site. Achievable Cumulative Cumulative

Resource will will Resource offsets and rehabilitation, where required. Medium-term Medium-term

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CONSTRUCTION PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES CAUSE AND COMMENT ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION BABILITY OF BABILITY OF IMP IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

Seawater Abstraction During the construction phase, the construction of a new Alternative 1: pumphouse and seawater abstraction inlet will result in the e HIGH MODERATE Construction of clearance of coastal thicket likely to result in the loss of NEGATIVE rsible NEGATIVE Severe Severe Definite Definite Negativ Localised Localised partly lost partly Reve Achievable Achievable

new pumphouse protected tree species. Short-term

and inlet be will Resource Direct, Cumulative Cumulative Direct,

During the construction phase, construction activities,  All staff must be trained on site regarding the proper

Wildlife e All Alternatives vehicles, crew and materials may result in animal fatalities MODERATE management and response should animals be encountered.

disturbances and rsible LOW NEGATIVE (excluding No-Go) through direct fatalities, habitat destruction, opportunistic NEGATIVE  No hunting, baiting or trapping of animals must be allowed on Easily Easily mortalities Direct, Negativ Moderate Moderate

Reve site or surrounding areas. Study area area Study not be lost be not May Occur Occur May Achievable Achievable

hunting, collisions, accidents or baiting and trapping. Short-term Cumulative Cumulative Resource will will Resource

 The findings and recommendations of the Ecological Impact

Loss/Fragmentation All Alternatives During construction, the loss of vegetation coincides with the e MODERATE Assessment must be adhered to.

rsible  The Ecological Impact Assessment must determine the extent LOW NEGATIVE of habitats (excluding No-Go) loss of faunal habitat, reducing breeding and rearing locales. NEGATIVE

Direct, Direct, of loss to all vegetation types and recommended biodiversity Negativ Probable Probable Moderate Moderate Reve Study area area Study Achievable Achievable Cumulative Cumulative be partly lost partly be

Resource will will Resource offsets, where required. Medium-term Medium-term Aquatic Environment

During the construction phase, the expansion of the facility

Changes to fluvial e All Alternatives will result in the removal of a coastal wetland. The rerouting HIGH HIGH geomorphology (excluding No-Go) of stormwater will alter natural flow patterns within the NEGATIVE ersible NEGATIVE

Direct, Direct,  The findings and recommendations of the Aquatic Impact and hydrology Severe Difficult Difficult Definite Definite Negativ catchment. Localised Permanent Permanent Cumulative Cumulative Irrev Assessment must be adhered to. be partly lost partly be Resource will will Resource  The Aquatic Impact Assessment must determine the extent of Disturbance of During the construction phase, the expansion of the facility loss to aquatic habitats and recommended biodiversity aquatic and All Alternatives and indiscriminate removal or unnecessary encroachment e HIGH offsets, where required. MODERATE wetland vegetation (excluding No-Go) into riparian and wetland vegetation may lead to disturbance NEGATIVE rsible NEGATIVE Direct, Direct, Definite Definite Negativ Moderate Moderate Reve Study area area Study

and habitat of the aquatic ecosystem. Achievable Cumulative Cumulative be partly lost partly be Resource will will Resource Medium-term Medium-term

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CONSTRUCTION PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES CAUSE AND COMMENT ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION BABILITY OF BABILITY OF IMP IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

 Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practice must be adhered to. This applies to solvents and other chemicals possibly used during the construction process.  The individual(s) that will be handling hazardous materials must be trained to do so.  All hazardous chemicals must be stored properly in a secure, bunded and contained area.  Concrete must not be mixed directly on the ground, or during rainfall events when the potential for transport to the During the construction phase, improper management stormwater system is the greatest. All Alternatives (usage and storage) of hazardous substances such as cement, e HIGH  Concrete must only be mixed in the area demarcated for this MODERATE

Water Quality rsible purpose and on an impermeable surface, and not within 50m (excluding No-Go) tar bitumen, fuel and oil may result in spillages occurring NEGATIVE NEGATIVE of any river/watercourse. Negativ Moderate Moderate Reve Study area area Study May Occur Occur May Achievable Achievable leading to site contamination. Short-term  Oil trays must be placed under construction machinery to

Direct, Cumulative Cumulative Direct, avoid soil contamination.  An oil absorbent materials/spill kit must be kept at the site Resource will be partly lost partly be will Resource camp in case of a spill.  Should a spill occur, the individual responsible for (or the individual who discovers the petrochemical spill) must report the incident to the Project Coordinator, ECO and/or Contractor as soon as reasonably possible. The immediate response must be to contain the spill.  The ECO must determine the precise method of treatment of polluted soil. This could involve the application of oil absorbent materials or oil-digestive Seashore and Marine Environment

Alternative 1: During the construction phase, the construction of a new Construction of a

inlet pipeline will involve excavations, blasting and e new pumphouse HIGH  Incremental layout and routing alternatives for the proposed MODERATE

installation of the seawater inlet pipeline within the dune, rsible and inlet up NEGATIVE new pumphouse and inlet must be further assessed in the EIA NEGATIVE be lost lost be seashore and inter-tidal zones. This will result in disruptions Severe Definite Definite Negativ Localised Localised

Reve phase. Achievable Achievable current of existing Short-term to the dune thicket, seashore, and inter-tidal ecology. Disturbance to the inlet pipeline.  A Marine Impact Assessment must be conducted to determine Direct, Cumulative Cumulative Direct, Resource will partly partly will Resource the potential impacts to the seashore and marine dune, beach and environment and recommend mitigation measures to address inter-tidal zones Alternative 1: these impacts. Construction of During the construction phase, uncontrolled excavations and  A. Ecological Impact Assessment must assess the potential new outlet construction of the discharge channel within the dune, e HIGH impacts to dune thicket and recommend mitigation measures MODERATE channel down seashore and inter-tidal zones can result in degradation to NEGATIVE rsible to address these impacts NEGATIVE be lost lost be Severe Severe Definite Definite Negativ Localised Localised Reve

current of existing these zones. Achievable Permanent Permanent outlet channel. Direct, Cumulative Cumulative Direct, Resource will partly partly will Resource

Socio-Economic Environment

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CONSTRUCTION PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES CAUSE AND COMMENT ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION BABILITY OF BABILITY OF IMP IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

Stimulation and During the construction phase, there will be a temporary contribution to All Alternatives e MODERATE  The findings and recommendations of the Socio-Economic MODERATE

increase in the Gross Value Add (GVA) and production of the rsible local and national (excluding No Go) POSITIVE Impact Assessment must be adhered to. POSITIVE

national and local economies. Direct Positiv Definite Definite National National Beneficial Beneficial Reve not be lost be not

economies Achievable Moderately Moderately Resource will will Resource Medium-term Medium-term

During the construction phase, the proposed development All Alternatives e MODERATE  Where possible, individuals from the nearest local MODERATE

will create temporary skilled and unskilled employment rsible communities must be contracted for unskilled and semi- (excluding No-Go) POSITIVE POSITIVE

opportunities. Direct, skilled employment. Positiv Definite Definite Beneficial Beneficial Municipal Municipal Reve not be lost be not Achievable Achievable Short-term Short-term Cumulative Cumulative Moderately Moderately Resource will will Resource Job creation

Maintaining the status quo will result in temporary skilled e MODERATE MODERATE

No Go Alternative and unskilled employment opportunities not materialising rsible  No mitigation NEGATIVE NEGATIVE Direct, Direct, during the construction phase. lost be Difficult Difficult Definite Definite Negativ Municipal Municipal Moderate Moderate Reve Short-term Short-term Cumulative Cumulative Resource will will Resource  A health and safety plan in terms of the Occupational Health and Safety Act (Act No 85 of 1993) must be drawn up by and

All Alternatives During the construction phase, non-compliance with the e MODERATE HSE officer prior to construction to ensure workers safety.

Health and safety rsible  An Emergency Preparedness Plan for fire safety and the use, LOW NEGATIVE (excluding No-Go) Health and Safety Act could result in injury or death on site. NEGATIVE be lost lost be Severe Severe handling, storage and disposal of hazardous substances must Negativ Localised Localised Reve May Occur Occur May Achievable Achievable Short-term Short-term be developed for the construction phase prior to construction Resource will not not will Resource

Direct, Cumulative Cumulative Direct, commencing.

During the construction phase, dust (air) pollution caused by  Cleared surfaces must be dampened whenever possible, Air quality and dust All Alternatives grading and levelling exposed land can cause a nuisance to e MODERATE especially during dry and windy conditions, to avoid excessive

rsible dust generation. • Any complaints or claims emanating from LOW NEGATIVE control (excluding No-Go) nearby traffic and neighbouring community and local NEGATIVE

Direct, Direct, dust issues must be attended to immediately and noted in the Negativ Probable Probable Moderate Moderate Reve not be lost be not Study Area Area Study Achievable Achievable residents. Short-term Cumulative Cumulative

Resource will will Resource complaints register.  Construction activity close to residential settlements which includes the movement of construction vehicles, must be

During the construction phase, construction noise pollution e All Alternatives MODERATE restricted to normal working hours (7:00am – 17:00pm).

Noise could potentially be a nuisance to neighbouring residential rsible LOW NEGATIVE (excluding No-Go) NEGATIVE  There must be a complaint register on site for nearby

areas. Direct Negativ Probable Probable

Moderate Moderate residents to make complaints, if required. These must be Reve not be lost be not Study Area Area Study Achievable Short-term Short-term Resource will will Resource addressed and recorded  Visual screening measures must be implemented/established, During the construction phase, the expansion of the facility, where possible. All Alternatives as well as temporary construction related structures and e MODERATE  The site camp and temporary structures must be

Visual rsible decommissioned, and the area rehabilitated once LOW NEGATIVE (excluding No-Go) activities may impact on the aesthetic appearance of the NEGATIVE

be lost lost be construction has been completed. Negativ Probable Probable Moderate Moderate Reve Study Area Area Study Achievable Achievable surrounding area. Short-term  All waste, materials and equipment must be removed from Resource will not not will Resource

Direct, Cumulative Cumulative Direct, site on completion of construction works.  Appropriate warning signs must be in place to notify the During the construction phase, increased flow of public regarding construction activities.  Construction vehicles are to adhere to traffic regulations.

construction and vehicular traffic through neighbouring e All Alternatives MODERATE  Appropriate traffic safety measures, such as flagmen and

Traffic community areas may present a safety risk to the local rsible LOW NEGATIVE

(excluding No-Go) NEGATIVE lost speedbumps, must be used where deemed necessary. community, and further deteriorate the surface conditions of Negativ Probable Probable Moderate Moderate

Reve  Degradation to local access roads as a result of heavy Achievable Achievable Study Area Area Study Short-term Short-term the road leading to the facility. machinery/construction vehicles must be Direct, Cumulative Cumulative Direct, Resource will not be be not will Resource rehabilitated/graded.

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CONSTRUCTION PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES CAUSE AND COMMENT ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION BABILITY OF BABILITY OF IMP IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

Heritage and Paleontological environment During the construction phase, failure to conserve important artefacts, graves and various other heritage/archaeological aspects that could be present on site will result in the

Loss of heritage and potential loss of sites of archaeological, cultural and e All Alternatives HIGH  The findings and recommendations of the Heritage and

paleontological paleontological significance. rsible Paleontological Impact Assessment must be implemented and LOW NEGATIVE (excluding No-Go) NEGATIVE

resources Severe adhered to. Negativ Localised Localised Reve May occur occur May Achievable Achievable Short-term

Cumulative Direct, lost be not will Resource Rehabilitation and maintenance

During the construction phase, inadequate implementation  A Rehabilitation & Maintenance Plan compiled during the

Inadequate e All Alternatives of rehabilitation measures in areas where construction has HIGH planning and design phase, must be implemented and

rehabilitation and rsible adhered to. LOW NEGATIVE (excluding No-Go) been completed will lead to the degradation of the NEGATIVE Direct, Direct, maintenance Severe  All disturbed areas must be rehabilitated to the satisfaction of Negativ Reve May occur occur May Study area area Study not be lost be not Achievable Achievable

surrounding terrestrial environment. Short-term Cumulative Cumulative

Resource will will Resource the ECO.

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11.2.3 OPERATION PHASE IMPACTS

Table 11-3: Operation Phase Preliminary Impact Assessment

OPERATIONAL PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES SOURCE OF ISSUE ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION IMP BABILITY OF IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

Environmental Policy

During the operational phase, failure to adhere to existing policies, regulations, permits, authorisations and legal All  Operational aspects of all relevant permits and authorisations

obligations could lead to the project conflicting with local, e Legal and policy Alternatives HIGH including Water Use License (WUL), Coastal Lease Agreements,

provincial and national policies, legislation, etc. This could rsible Coastal Waters Discharge Permits (CWDP), Building Plan LOW

compliance (excluding No- NEGATIVE lost Direct Direct result in lack of institutional support for the project, overall Severe Approvals and Plant removal/TOPS permits must be adhered National National Negativ Long-term Long-term Reve May Occur Occur May Go) Achievable project failure and undue disturbance to the natural to. environment. Resource will be partly partly be will Resource

Built Environment  The conditions set out in the Storm Water Management Plan must be implemented and adhered to.  The conditions of the WUL must be adhered to.

During the operation phase, lack of monitoring and e Stormwater All  The findings and recommendations of the Aquatic Impact

maintenance of stormwater infrastructure may lead to the MODERATE rsible LOW

Management Alternatives lost Assessment regarding stormwater must be adhered to. uncontrolled runoff of stormwater. Negativ Moderate Moderate Long-term Long-term Reve 

Study area area Study Stormwater infrastructure must be regularly maintained as May Occur Occur May required, including regular monitoring for signs of erosion and Easily Achievable Achievable Easily Direct, Cumulative Cumulative Direct, Resource will not be be not will Resource sedimentation to the surrounding environment.  The Waste Management Plan must be implemented and adhered to.  No solid waste is to be disposed of on site.

During the operation phase, inadequate treatment and e All MODERATE  All waste temporarily stored on site must be done so in closed

disposal of solid waste generated from the facility may result in rsible LOW NEGATIVE

Alternatives NEGATIVE lost bins/covered skips and regularly removed from the site and contamination and pollution to the surrounding environment. Negativ Moderate Moderate Reve Long-term Long-term transported to the closest licensed landfill site. Study area area Study May Occur Occur May

Easily Achievable Achievable Easily Direct, Cumulative Cumulative Direct, Resource will not be be not will Resource  The findings and recommendations of the Groundwater Protocol Assessment must be adhered to.  The sewage treatment system installed must be operated Waste Management and/or maintained by a suitably qualified individual and/or service provider.  The water quality monitoring programme must be implemented during the operation phase of the expansion to

Alternative 3: During the operation phase, inadequate maintenance of e HIGH ensure that the discharge of treated sewage effluent meets MODERATE

Sewage sewage treatment infrastructure may result in surface and rsible NEGATIVE the required standards. NEGATIVE

Package Plant groundwater pollution to the surrounding environment. Severe Negativ  No treated sewage effluent is allowed to be discharged directly Reve Long-term Long-term Study area area Study May Occur Occur May Achievable Achievable into any freshwater or marine body. Direct, Cumulative Cumulative Direct,  Should treated effluent be used for irrigation, the effluent Resource will not be lost be not will Resource must be treated to standard as legislated for that particular end use.  Should treated effluent need to be discharged off site, this must be done so at a licensed waste management facility. Terrestrial Environment

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OPERATIONAL PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES SOURCE OF ISSUE ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION BABILITY OF BABILITY OF IMP IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

During the operation phase, inadequate planning and

provisioning for the removal and management of alien e Invasion of alien All MODERATE  The Alien Vegetation Management Plan must be implemented

vegetation throughout all phases of the development could rsible throughout operation to mitigate the establishment and LOW NEGATIVE vegetation species Alternatives NEGATIVE

result in the invasion of alien vegetation in both terrestrial and lost be spread of undesirable alien plant species. Negativ Probable Probable Moderate Moderate Reve Long-term Long-term Study area area Study riparian areas. Achievable Resource will not not will Resource Direct, Cumulative Cumulative Direct,

Loss of Species of During the operation phase, rehabilitation of the coastal All e MODERATE  The rehabilitation recommendations of the Ecological Impact MODERATE

Conservation thicket in previous disturbed areas will result in the rsible Alternatives POSITIVE Assessment must be adhered to. POSTIVE

Concern (SCC) reestablishment of certain tree and plant SCCs. Direct, Positiv Probable Probable Localised Localised Moderate Moderate Reve Long-term Long-term not be lost be not Achievable Achievable Cumulative Cumulative Resource will will Resource Aquatic Environment  Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practice must be adhered to. This applies to solvents and other chemicals possibly used during the construction process.  The individual(s) that will be handling hazardous materials must be trained to do so.  All hazardous chemicals/above ground diesel tanks must be stored properly in a secure, bunded and contained area. During the operation phase, improper management (usage and  An oil absorbent materials/spill kit must be kept on site in case of a spill.

storage) of hazardous substances, storage and disposal of solid e All HIGH  All solid waste (organic and inorganic) temporarily stored on MODERATE

Water Quality waste generated, and maintenance to sewage treatment rsible Alternatives NEGATIVE site must be done so in sealed and/or covered containers and NEGATIVE infrastructure may result in contaminated runoff into Negativ Moderate Moderate

Reve regularly removed form site by a registered service provider to Study area area Study May Occur Occur May Achievable Achievable Short-term Short-term surroundings rivers, dams and wetlands. a licensed waste facility. Direct, Cumulative Cumulative Direct,  All staff and workers at the facility must use the toilet facilities

Resource will be partly lost partly be will Resource provided. The facility must strictly monitor the movements of workers and ensure workers do not use the surrounding areas for this.  Sewage treatment infrastructure must be regularly maintained to ensure effluent is treated to the required standard prior to disposal/reuse.  The conditions of the WUL must be adhered to, including the requirements for water quality monitoring. Seashore and Marine Environment  The finding of the Ecological Impact Assessment must be During the operational phase, the high volumes of treated adhered to.

Erosion and e Alternative 1: abalone effluent being released via the discharge channel may HIGH  The findings and recommendations of the Marine Impact MODERATE

channelling of rsible Construction result in channel erosion degrading the dune and seashore NEGATIVE Assessment must be adhered. NEGATIVE

seashore Direct, Negativ partly lost partly Moderate Moderate Long-term Long-term Reve  The discharge channel must be monitored regularly for signs of Study area area Study May Occur Occur May zones. Achievable

of new outlet Cumulative

channel down be will Resource erosion, and reinforced and rehabilitated when necessary. current of Discharge of  The findings and recommendations of the Marine Impact

During the operational phase, the ineffective treatment of e enriched seawater existing outlet HIGH Assessment must be adhered. MODERATE

abalone effluent may result in nutrient rich effluent being rsible effluent channel. NEGATIVE  The conditions of the Coastal Discharge Permit must be NEGATIVE

released into the tidal zone, impacting the local marine biota. Direct, Negativ

Moderate Moderate adhered to. Reve Long-term Long-term Study area area Study May Occur Occur May Achievable Achievable Cumulative Cumulative be partly lost partly be Resource will will Resource

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OPERATIONAL PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES SOURCE OF ISSUE ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION BABILITY OF BABILITY OF IMP IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

Environmental Biosecurity

Biosecurity risk to During the operation phase, inadequate internal biosecurity e All HIGH  The findings and recommendations of the Biosecurity Risk MODERATE

the marine control measures may result in the spread of infectious rsible Alternatives NEGATIVE Assessment review must be adhered to. NEGATIVE Direct, Direct, environment diseases within the abalone facility and marine environment. Severe Regional Regional Negativ Reve Long-term Long-term May Occur Occur May Achievable Achievable Cumulative Cumulative be partly lost partly be Resource will will Resource Socio-Economic Environment

Stimulation and All During the operation phase, there will be a sustainable contribution to local Alternatives e MODERATE  The findings and recommendations of the Socio-Economic MODERATE

increase in production and GVA nationally, regionally and rsible and national (excluding No POSITIVE Impact Assessment must be adhered to. POSITIVE

locally Direct Positiv Definite Definite National National Beneficial Beneficial Reve Long-term Long-term not be lost be not

economies Go) Achievable Moderately Moderately Resource will will Resource

During the operation phase, the proposed development will All e HIGH  Where possible, individuals from the nearest local

Job creation provide a total of 1400 permanent skilled and unskilled job rsible communities must be contracted for unskilled and semi-skilled HIGH POSITIVE Alternatives POSITIVE

opportunities. Direct, employment. Positiv Definite Definite Beneficial Beneficial Municipal Municipal Reve Long-term Long-term not be lost be not Achievable Achievable Cumulative Cumulative Resource will will Resource  Conditions of the Occupational Health and Safety Act (Act No 85 of 1993) relating to safe working practices, storage/use/handling/disposal of hazardous substances, and

During the operation phase, non-compliance with the Health e All HIGH fire must be adhered to.

Health and safety and Safety Act could result in injury or death on site, risk of fire rsible LOW NEGATIVE Alternatives NEGATIVE  An Emergency Preparedness Plan for fire safety and the use,

and/or contamination to the surrounding environment. Severe Negativ Localised Localised

partly lost partly handling, storage and disposal of hazardous substances must Reve May Occur Occur May Achievable Achievable Medium-term Medium-term

Resource will be be will Resource be developed for the operation phase. All staff must be Direct, Cumulative Cumulative Direct, appropriately trained, where required. Alternative 4: Combination During the operation phase, inadequate maintenance of  The conditions of the WUL must be adhered to.

of rainwater e infrastructure to ensure a self-sustaining fresh water supply for HIGH  The findings and recommendations of the Groundwater

Water supply harvesting rsible Protocol must be adhered to. LOW NEGATIVE the facility may result in supply constraints during the NEGATIVE

(primary) and Severe  Water supply infrastructure must be regularly monitored and Negativ Localised Localised partly lost partly Reve May Occur Occur May Achievable Achievable

operational phase of the facility. Short-term use of the maintained when required. Resource will be be will Resource boreholes Cumulative Direct,

During the operational phase, inadequate provisions made  A visual screen of natural vegetation must be established in All towards mitigating the visual obtrusion of the development e HIGH areas deemed acceptable by the Ecological Impact

Visual Impacts rsible LOW NEGATIVE Alternatives may visually impact on the surrounding community, affecting NEGATIVE Assessment. Direct, Direct, Severe Severe Definite Definite Negativ  Reve

Long-term Long-term No Alien Invasive Vegetation must be used for this purpose. Study Area Area Study ones ‘sense of place’ within the area. Achievable Cumulative Cumulative be partly lost partly be Resource will will Resource Rehabilitation and maintenance

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OPERATIONAL PHASE SS SS

E OF

SIGNIFICANCE LITY SIGNIFICANCE OF F IMPACT F IMPACT F IMPACT F IMPACT POTENTIAL ISSUES ALTERNATIVES SOURCE OF ISSUE ACT ACT WITHOUT MITIGATION MEASURES IMPACT WITH GATION TYPE TYPE MITIGATION MITIGATION BABILITY OF BABILITY OF IMP IMP NATURE POTENTIAL MITI REVERSIBI PRO CONSEQUENC EXTENT O IRREPLACEABLE LO IRREPLACEABLE DURATION O DURATION

(SIGNIFICANCE WITHOUT MITIGATION) (SIGNIFICANCE WITH MITIGATION)

 A Rehabilitation & Maintenance Plan must be implemented during the operational phase of the development.  The conditions of all applicable license and permits must be adhered to.  All service infrastructure requiring maintenance must be done

Inadequate During the planning and design phase, inadequate planning for e All HIGH so in a minimally invasive manner to the surrounding MODERATE

rehabilitation and rehabilitation could lead to degradation of the study area and rsible environment, where possible. Alternatives NEGATIVE NEGATIVE

maintenance surrounding areas. Severe  All areas are to be rehabilitated and revegetated (where Negativ Localised Localised Reve May Occur Occur May Achievable Achievable previously vegetated) directly after the completion of Medium-term Medium-term

Direct, Cumulative Cumulative Direct, maintenance works.  The findings of the Aquatic and Ecological Impact assessment Resource will be partly lost partly be will Resource relating to maintenance and rehabilitation must be adhered to.

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12 PLAN OF STUDY: EIA PHASE

(h) a plan of study for undertaking the environmental impact assessment process to be undertaken, including— (i) a description of the alternatives to be considered and assessed within the preferred site, including the option of not proceeding with the activity; (ii) a description of the aspects to be assessed as part of the environmental impact assessment process; (iii) aspects to be assessed by specialists; (iv) a description of the proposed method of assessing the environmental aspects, including aspects to be assessed by specialists; (v) a description of the proposed method of assessing duration and significance; (vi) an indication of the stages at which the competent authority will be consulted; (vii) particulars of the public participation process that will be conducted during the environmental impact assessment process; and (viii) a description of the tasks that will be undertaken as part of the environmental impact assessment process; (ix) identify suitable measures to avoid, reverse, mitigate or manage identified impacts and to determine the extent of the residual risks that need to be managed and monitored.

In line with the above-mentioned legislative requirements, this Chapter sets out the Plan of Study for the EIA phase of the assessment. Consultation with DEA will be on-going throughout this EIA. However, it is anticipated that DEDEAT will provide relevant comment with respect to the adequacy of this Plan of Study for the EIA, as it informs the content of the EIR and sufficiency thereof.

12.1 EIA PHASE

The EIA phase has four key elements, namely:

 Specialist Studies: After the authority review of the Final Scoping Report (FSR), additional specialist studies may be requested by the authorities, and these will be undertaken during the initial phase of the EIA. Appropriately qualified and experienced specialists will be appointed to undertake the various assessments. Specialists will gather baseline information relevant to the study being undertaken and will assess impacts associated with the development. Specialists will also make recommendations to mitigate negative impacts and enhance benefits. The resulting information will be synthesised into the Environmental Impact Report (EIR), whilst the full specialist reports will be attached to the EIR as a Specialist Volume.

 Environmental Impact Report (EIR): The main purpose of this report is to gather and synthesise environmental information and evaluate the overall environmental impacts associated with the development, to consider mitigation measures and alternative options,

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and make recommendations in choosing the best development alternative. The EIR also identifies mitigation measures and management recommendations to minimise negative impacts and enhance benefits. The EIR and associated specialist reports are made available for public and authority review and comment. The availability of the report will be advertised in one provincial and/or one local newspaper and the report will also be made available for public review in easily accessible locations.

 The Comments and Response Report: The Comments and Responses Report (CRR) provides a detailed record of comments, issues and concerns raised by I&APs and the authorities during the review period, and also provides relevant responses to these comments.

 Environmental Management Programme (EMPr): The EMPr provides guidelines to the project proponent and the technical team on how best to implement the mitigation measures and management recommendations outlined in the EIR during the construction, operational, and decommissioning phase.

In addition to the above, the Public Participation Process (PPP) commenced during the Scoping Phase will be continued, during which I&APs are afforded further opportunities to raise their issues, concerns and comments regarding the proposed project. It is possible that some of the project details may have changed in response to the preliminary findings of the Scoping Report, and as a result of design changes made by the project proponent. I&APs and key stakeholders are given the opportunity to review the Draft EIR before it is submitted to the authorities for consideration. Comments on the Draft EIR received from I&APs are included and addressed in the submitted Final EIR.

12.2 ALTERNATIVES

The alternatives (fundamental and incremental) outlined in Chapter 7 of this report will be expanded upon in the EIA phase. In summary, the following alternatives will be further assessed:

ALTERNATIVE TYPE ALTERNATIVE FUNDAMENTAL ALTERNATIVES Location Preferred site alternative 1: Existing site The consideration of alternative localities was not considered feasible as the proposed expansion is associated to the facility’s established locality and existing infrastructure. Activity Preferred activity 1: Marine Aquaculture The consideration of alternative activities was not considered feasible as existing facility is already established for marine aquaculture, primarily abalone farming. INCREMENTAL ALTERNATIVES Fresh water supply Alternative 4: Combination of rainwater harvesting (primary) and use of the boreholes Sanitation Alternative 3: Package plant Incremental alternatives in package plant design and micro-siting will be assessed in the EIA phase of the project, as this will be dependent on the Groundwater Protocol commissioned to be completed during the EIA phase. Seawater abstraction Alternative 1: Construction of new pumphouse and inlet up current of existing inlet Micro-siting alternatives will be assessed further in the EIA phase of the project. Coastal discharge Alternative 1: Construction of new outlet channel down current of existing outlet (abalone effluent) Micro-siting alternatives will be assessed further in the EIA phase of the project. Stormwater Design alternatives and micro-siting of stormwater infrastructure will be assessed in the EIA

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ALTERNATIVE TYPE ALTERNATIVE Management phase of the project, as this will be dependent on the Stormwater Management Plan commissioned to be completed during the EIA phase. Energy Supply Alternative 1: Eskom connection Alternative 2: Renewable Energy (Wind) in combination with an Eskom connection (assessed in a separate EIA process) No-Go Alternative Status quo: The proposed expansion area is privately owned land currently zoned as agriculture, however undeveloped and unutilised.

12.3 SPECIALIST STUDIES

It is proposed that the following specialist impact studies will be required for the Wild Coast Abalone Facility Expansion:

12.3.1 ECOLOGICAL IMPACT ASSESSMENT

Due to the proposed development being located within the coastal protection zone and seashore (in terms of Section 16(1) of the Integrated Coastal Management Act (ICMA) (Act No. 24 of 2008), and the occurrence of coastal wetlands within the proposed expansion area, it is anticipated that an Ecological Impact Assessment (Terrestrial) will be required to be undertaken during the EIA phase. The following Terms of Reference (ToR) will be applicable for the ecological specialist:

• Describe the study area in terms of land cover and terrestrial habitat. This will include a full desktop analysis on fauna and flora (for the terrestrial and marine environment); • Review relevant legislation, policies, guidelines and standards; • Conduct a site survey to determine the actual ecological state of the study area and identify any species of conservation concern; • Identification of the following in terms of fauna and flora: o Areas of high biodiversity; o The presence of species of conservation concern, including sensitive, endemic and protected species; o The presence of areas sensitive to invasion by alien species; and o The presence of conservation areas and sensitive habitats where disturbance should be avoided or minimised. • Produce a sensitivity map that illustrates areas with significant developmental constraints; • Describe the likely scope, scale and significance of direct and indirect positive and negative impacts resulting from the proposed development both on the footprint and the immediate surrounding area during construction and operation as well as the no-go option; • Provide a detailed description of appropriate mitigation measures that can be adopted to reduce negative impacts for each phase of the project, where required; • Broadly describe the implications of a ‘No-Go’ option where the proposals are not established; • To broadly comment on the cumulative impacts on the ecological environment associated with the development; • Confirm if there are any outright fatal flaws to the establishment of the development; • Describe any assumptions made and any uncertainties or gaps in knowledge;

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• Any recommendations on a way forward in terms of future specialist inputs required should also be made; and • Identify any need for future permitting.

12.3.2 WETLAND AND AQUATIC IMPACT ASSESSMENT

As part of the application for a WUL (as per the requirements of Section 21 of the NWA (Act No. 36 of 1998)), the DWS will require specific specialist assessments to be conducted. This will supplement the EIA process. Therefore, it is anticipated that a Wetland and Aquatic Impact Assessment will be required to be undertaken during the EIA phase. The following ToR will be applicable for the wetland/aquatic specialist:

• Identify wetland and riparian areas surrounding and impacted by the project site; • Delineate wetlands and the riparian habitat in the areas affected by the proposals; • Describe the existing area to be directly affected by the development in terms of its wetlands and riparian zones and the general sensitivity of the riparian area and any wetlands to change. This will include a WET-Health the determination of the EIS (Environmental Importance and Sensitivity) and PES (Present Ecological State) of the wetlands (if deemed necessary); • Describe the likely scope, scale and significance of impacts on riparian areas and wetlands in the area as may be associated with the construction process; • Make recommendations on the scope of any mitigation measures that may be applied during construction to avoid/reduce the significance of the identified construction-related impacts; • Describe the likely scope, scale and significance of impacts on riparian areas and wetlands associated with the operation or use of the development, including the benefits and disbenefits; • Make recommendations on the scope of any mitigation measures that may be applied to avoid/reduce the significance of the operations-related impacts. These mitigation measures could also be design recommendations as well as operational controls, monitoring programmes, management procedures and the like; • Identify any rehabilitation measures that can be reasonably applied with the completion of the construction works; • Broadly describe the implications of a ‘No-Go’ option where the proposals are not established; • To broadly comment on the cumulative impacts on wetlands associated with the development; • Confirm if there are any outright fatal flaws to the establishment of the development; • Describe any assumptions made and any uncertainties or gaps in knowledge; • Any recommendations on a way forward in terms of future specialist inputs required should also be made.

12.3.3 MARINE IMPACT ASSESSMENT

Due to the proposed development being located within the coastal protection zone and seashore (in terms of Section 16(1) of the Integrated Coastal Management Act (ICMA) (Act No. 24 of 2008), and

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the occurrence of coastal wetlands within the proposed expansion area, it is anticipated that an Marine Impact Assessment will be required to be undertaken during the EIA phase. The following ToR will be applicable for the marine specialist:

• A determination of the abundance and distribution of key species at high, mid and low tide at three equally spaced sites on the rocky shore within the development area associated with the Wild Coast Abalone discharge point, and one site outside the development area, which is deemed to not be influenced by the Wild Coast Abalone discharge point. • A non-quantitative inspection of underwater environment in the shallow sub-tidal area (sea conditions dependent). • An assessment of potentially sensitive biota in the immediate area of both the existing seawater discharge point and proposed discharge point. • An assessment of the impacts on the marine environment from the current sea-water discharge and by extrapolation, identify likely construction and operational impacts of the expanded development, which includes the installation of an additional sea-water outlet. • Assess the significance of these impacts (using CES impact rating methodology to be supplied) in the context of the coastal and marine biodiversity and management of the receiving environments for conservation. • Identify measures likely to minimise negative impacts and enhance positive impacts on the marine environment of the expanded development.

12.3.4 BIOSECURITY RISK ASSESSMENT

As disease can be a significant risk of aquaculture, it is anticipated that a Biosecurity Risk Assessment be undertaken as part of the EIA phase. As Wild Coast Abalone have an existing Biosecurity Plan in place, this assessment will be a review of the existing plan. The following ToR will be applicable for the specialist:

• Identify and assess biosecurity risks to the expanded abalone facility; and • Review existing procedures in place to manage biosecurity risks, and recommend additional procedures if need be.

12.3.5 HERITAGE AND PALEONTOLOGICAL IMPACT ASSESSMENT

As part of the EIA for the proposed development, it is necessary to undertake a Phase 1 archaeological and historical survey to fulfil SAHRA’s requirements in accordance with the National Heritage Resources Act (25 of 1999). The National Heritage Resources Act requires that “…any development or other activity which will change the character of a site exceeding 5 000 m², or the rezoning or change of land use of a site exceeding 10 000 m², requires an archaeological impact assessment”

A Heritage Impact Assessment (HIA) and desktop Palaeontological Desktop Assessment (PIA) will therefore be conducted; the primary objective of which is to determine whether there are any indications that the proposed site is of heritage significance. This assessment will be a Phase 1 assessment and will be largely desktop although a site visit will be required to afford the specialist an

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opportunity to look for significant artefacts on the surface of the site. It is not expected that a more detailed Phase 2 assessment will be required, however this remains to be confirmed.

The ToR for the Phase 1 HIA will be to:

• Provide a summary of the relevant legislation; • Conduct a site inspection as required by national legislation; • Determine the likelihood of archaeological remains of significance in the proposed site; • Identify and map (where applicable) the location of any significant archaeological remains; • Assess the sensitivity and significance of archaeological remains in the site; • Assess the significance of direct and cumulative impacts of the proposed development and viable alternatives on archaeological and heritage resources; • Identify migratory measures to protect and maintain any valuable archaeological sites and remains that may exist within the proposed site; and • Prepare and submit any permit applications to SAHRA and Eastern Cape Provincial Resources Authority (ECPHRA).

The ToR for the desktop PIA will be to:

• Indicate the fossil sensitivity of the project area and possible impacts emanating from the proposed development on such resources; and • Include the Chance Find Procedures for palaeontological receptors. The desktop PIA will also be submitted with the HIA Report to SAHRA and Eastern Cape Provincial Resources Authority (ECPHRA).

12.3.6 SOCIO-ECONOMIC IMPACT ASSESSMENT

• Delineate the zone of influence • Describe the socio-economic character of the area to be directly affected by the proposed expansion of the production facility, and the general sensitivity of these components to change. • Describe the likely scope, scale and significance of impacts (positive or negative) on the socio-economic character of the area to be affected by the proposals associated with the investment. • Determine the affected economies and communities located in the zone of influence and identify sensitive receptors within the delineated study area, i.e. communities and economic activities that could be directly or indirectly positively/negatively affected by the proposed project. • Create profiles for the communities representing the study areas and the environmentally affected zone, which would then represent a status of the environment under the “no-go”

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alternative and would be used to assess the potential changes ensued from the proposed activity. • Evaluate the change in the size and composition of the local and regional economies that will be stimulated by the proposed development, as well as the state of local communities. • Develop a management and mitigation plan by proposing mitigation measures for negative effects and enhancement measures for positive impacts.

12.3.7 SANITATION PROTOCOL

A Sanitation Protocol (Groundwater Protocol) assessment was completed in February 2008 for the original expansion of the facility. This will need to be updated for the proposed expansion. The ToR for the Sanitation protocol update will be to:

 Produce an updated groundwater protection protocol (sanitation protocol) document that will be compliant with the standards set by Department of Water and Sanitation (DWS) in their document: “A Protocol to Manage the Potential of Groundwater Contamination from onsite Sanitation” (Edition 2 March 2003).

12.3.8 STORMWATER MANAGEMENT PLAN

The expansion of the facility will create additional hardened/artificial surfaces, altering the natural rainfall runoff pattern. A Stormwater Management Plan will be needed to assess the catchment area and propose ways in which to control such runoff as to not put the facility at risk, and how best to redirect flows. The stormwater calculations will be performed in accordance with the design guidelines as provided for in the “Guidelines for Human Settlement Planning and Design, 2019”. In terms of these guidelines the following design criteria will be used:

 Runoff rates and storm event volumes have been calculated in accordance with the Rational Design Method (as detailed in the South African Road Drainage Manual).  Stormwater storage has been designed for the on-site containment of a 1:50 year event, with a controlled release of not more than a 1:10 year event, where applicable.

12.4 PUBLIC PARTICIPATION PROCESS

I&APs and key stakeholders are given the opportunity to review the Draft EIR before it is submitted to the authorities for consideration. Comments received on the Draft EIR from I&APs will be included and addressed in the Final EIR Report.

12.4.1 IDENTIFICATION OF AND CONSULTATION WITH KEY STAKEHOLDERS

I&APs and key stakeholders will be identified during the Scoping Phase of the project. The identification and engagement if necessary, of I&APs and key stakeholders will continue through into the EIA phase of the project as the public participation process is a continuous process that runs throughout the duration of an environmental investigation.

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12.4.2 INTERESTED AND AFFECTED PARTIES DATABASE

All I&AP information (including contact details) are recorded within the I&AP database. Any communication from I&APs regarding the proposed expansion, including dates and details of consultations/issues raised, is recorded within a comprehensive Comments and Response Report (CRR). The I&AP database and CRR will be updated on an on-going basis throughout the project and will act as a record of the public participation process.

12.4.3 PUBLIC REVIEW OF THE DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT

The Draft EIR will be made available for a thirty (30) day public review period. The availability of the Draft EIR will be advertised and all registered I&APs will be notified of the availability of the Draft EIR for public comment. In addition (and if required), a public meeting will be held during this public review period.

12.4.4 PUBLIC MEETINGS

The purpose of public meeting/s is to provide an appropriate format to enable I&APs to raise concerns related to the proposed project. The intention is that I&APs are afforded the opportunity of interacting on a one-on-one basis with the technical and planning representatives of the developer as well as the environmental team. I&APs will be encouraged to complete an attendance register and a comment and registration form to assist I&APs in raising concerns and general views on the project.

12.4.5 COMMENTS AND RESPONSE REPORT

All issues, comments and concerns raised during the public participation process of the EIA Process will be compiled into a CRR and incorporated and submitted as part of the Final Scoping Report (FSR) and EIR.

12.4.6 NOTIFICATION OF ENVIRONMENTAL AUTHORISATION (EA) AND APPEALS PROCESS

Notifications (including an advertisement in a newspaper, if required) will be sent out to notify the public of the Competent Authority’s (CA) decision on the Final EIR. The notifications will inform the public of how to access a copy of the EA and it will draw their attention to their right to appeal the decision and set out the appeal procedures to be followed. The public are given 20 calendar days from the issuing of the authorisation to lodge an appeal with the authorities. 12.5 ENVIRONMENTAL IMPACT REPORT (EIR)

The main purpose of the EIR is to gather and evaluate environmental information, so as to provide sufficient supporting arguments to evaluate overall impacts, consider mitigation measures and alternative options, and make a valued judgement in choosing the best development alternative.

Overview of the structure of the EIR:

 Introduction: Detail of the environmental assessment practitioner who compiled the report and expertise of the EAP to carry out an environmental impact assessment

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 Description of the Project: A description of the property on which the activity is to be undertaken, the location of the activity on the property and a description of the types of activities that are proposed for the development.  Project Need and Desirability: A motivation for the need and desirability for the proposed development.  Description of the Environment: A description of the biophysical, biological and socio- economic environment as well as the legal, policy and planning setting.  The Public Participation Process: Steps undertaken in order to notify and involve I&APs, advertisements, meetings held, including a summary of all issues and comments raised (CRR).  Project Alternatives: Description of all alternatives considered in the EIA, initial screening of alternatives, description and comparative assessment of all alternatives identified during the EIA.  Summary of Specialist Reports: Summary of the findings and recommendations of all specialist studies.  Impacts Assessment: The methodology used to determine the significance of environmental impacts, and a detailed assessment of each identified impact and risk identified including cumulative impacts, and the nature, significance, consequence, extent, duration, probability, reversibility, degree of irreplaceable loss and mitigation potential.  Environmental Impact Statement: A summary of the key findings of the EIA and a comparative assessment of the positive and negative implications of the proposed activity and identified alternatives.

 Conclusions, EAP opinion and Recommendations: An opinion as to whether the activity should or should not be authorised and any conditions (mitigation measures) that should be adhered to.

12.6 ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR)

The EMPr informs the client and the technical team of the guidelines which will need to be followed pre-construction and during construction and operation to ensure that there are no lasting or cumulative negative impacts of the construction process on the environment. The structure of the EMPr will be as follows:

 Introduction: Overview of proposed activity, the details and expertise of the EAP who prepared the EMPr, and a detailed description of the aspects of the activity covered by the EMPr.  Mitigation Measures and Actions: Planning and design (pre-construction), construction and operational phase actions to be undertaken.  Roles and Responsibilities: An indication of the persons who will be responsible for the implementation of the impact management actions.  Environmental Monitoring: The method of monitoring the implementation of the impact management actions and the frequency of monitoring.

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 Compliance and Reporting: The time periods within which the impact management actions must be implemented, the mechanism for monitoring compliance with the impact management actions, and the program for reporting on compliance.  Environmental Awareness: An environmental awareness plan describing the manner in which the applicant intends to inform his or her employees of any environmental risk which may result from their work; and how risks must be dealt with in order to avoid pollution or the degradation of the environment.  Closure Planning: Measures for rehabilitation and post-construction audits.

12.7 IMPACT ASSESSMENT METHODOLOGY

CES has developed an evaluation criterion of impacts in accordance with the requirements outlined in Appendix 2 of the EIA Regulations (2014, as amended). This scale takes into consideration the following variables:

 Nature: negative or positive impact on the environment.  Type: direct, indirect and/or cumulative effect of impact on the environment.  Significance: The criteria in Table 12-1 are used to determine the overall significance of an activity. The impact effect (which includes duration; extent; consequence and probability) and the reversibility/mitigation of the impact are then read off the significance matrix in order to determine the overall significance of the issue. The overall significance is either negative or positive and will be classified as low, moderate or high (Table 12-2).  Consequence: the consequence scale is used in order to objectively evaluate how severe a number of negative impacts might be on the issue under consideration, or how beneficial a number of positive impacts might be on the issue under consideration.  Extent: the spatial scale defines the physical extent of the impact.  Duration: the temporal scale defines the significance of the impact at various time scales, as an indication of the duration of the impact.  Probability: the likelihood of impacts taking place as a result of project actions arising from the various alternatives. There is no doubt that some impacts would occur (e.g. loss of vegetation), but other impacts are not as likely to occur (e.g. vehicle accident) and may or may not result from the proposed development and alternatives. Although some impacts may have a severe effect, the likelihood of them occurring may affect their overall significance.  Reversibility: The degree to which an environment can be returned to its original/partially original state.  Irreplaceable loss: The degree of loss which an impact may cause.  Mitigation potential: The degree of difficulty of reversing and/or mitigating the various impacts ranges from very difficult to easily achievable. The four categories used are listed and explained in Table 12-1 below. Both the practical feasibility of the measure, the potential cost and the potential effectiveness is taken into consideration when determining the appropriate degree of difficulty.

Table 12-1: Ranking of Evaluation Criteria

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NATURE Positive Beneficial/positive impact. Negative Detrimental/negative impact. TYPE Direct Direct interaction of an activity with the environment. Impacts on the environment that are not a direct result of the project or Indirect activity. Cumulative Impacts which may result from a combination of impacts of this project and similar related projects. DURATION Short term Less than 5 years. Medium term Between 5-20 years. Long term More than 20 years. Permanent Over 40 years or resulting in a permanent and lasting change that will always be there. EXTENT Localised Impacts affect a small area of a few hectares in extent. Often only a portion of the project area. Study area The proposed site and its immediate environments. Municipal Impacts affect the municipality, or any towns within the municipality. Regional Impacts affect the wider district municipality or the Eastern Cape Province as a whole. National Impacts affect the entire country. International/Global Impacts affect other countries or have a global influence. CONSEQUENCE Slight/ Slightly Slight impacts or benefits on the affected system(s) or party(ies). Beneficial Moderate / Moderate impacts or benefits on the affected system(s) or party(ies). Moderately Beneficial Severe/ Beneficial Severe impacts or benefits on the affected system(s) or party(ies). Very Severe/ Very Very Severe impacts or benefits to the affected system(s) or party(ies). Beneficial PROBABILITY Definite The likelihood is that this impact will definitely occur Probable The likelihood of these impacts occurring is probable May Occur The likelihood of these impacts occurring is possible Unsure The likelihood of these impacts occurring is slight REVERSIBILITY Reversible The activity will lead to an impact that can be reversed provided appropriate mitigation measures are implemented. Irreversible The activity will lead to an impact that is permanent regardless of the implementation of mitigation measures.

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IRREPLACEABLE LOSS Resource will not be The resource will not be lost/destroyed provided mitigation measures lost are implemented. Resource will be partly The resource will be partially destroyed even though mitigation lost measures are implemented. The resource will be lost despite the implementation of mitigation Resource will be lost measures. MITIGATION POTENTIAL The impact can be easily, effectively and cost effectively Easily achievable mitigated/reversed. The impact can be effectively mitigated/reversed without much difficulty Achievable or cost. The impact could be mitigated/reversed but there will be some difficultly Difficult in ensuring effectiveness and/or implementation, and significant costs. The impact could be mitigated/reversed but it would be very difficult to Very Difficult ensure effectiveness, technically very challenging and financially very costly.

Table 12-2: Description of significance ratings SIGNIFICANCE DESCRIPTION RATING The impacts on this issue are acceptable and mitigation, whilst desirable, is not essential. The impacts on the issue by themselves are insufficient, even in combination with other low LOW LOW impacts, to prevent the development being approved. Impacts on NEGATIVE POSITIVE this particular issue will result in either positive or negative medium to short term effects on the social and/or natural environment. The impacts on this issue are important and require mitigation. The impacts on this issue are, by themselves, insufficient to prevent the implementation of the project, but could in MODERATE MODERATE conjunction with other issues with moderate impacts, prevent its NEGATIVE POSITIVE implementation. Impacts on this particular issue will usually result in either a positive or negative medium to long-term effect on the social and/or natural environment. The impacts on this issue are serious, and if not mitigated, they may prevent the implementation of the project (if it is a negative HIGH HIGH impact). Impacts on this particular issue would be considered by NEGATIVE POSITIVE society as constituting a major and usually a long-term change to the (natural and/or social) environment, and will result in severe effects or if positive, substantial beneficial effects.

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13 RECOMMENDATIONS AND CONCLUSIONS

13.1 SUMMARY OF PROJECT DESCRIPTION

The existing facility produces abalone (mostly known locally as perlemoen), specifically Haliotis midae, which is one of five South African endemic abalone species. The facility exports both live and dried abalone. In addition to abalone, the facility also plans to diversify into the production of other marine species, such as (but not limited to), rock lobster and sea cucumbers (Holothuria scabra).

13.2 SUMMARY OF PRELIMINARY IMPACT ASSESSMENT

Sections 11.2.1 to 11.2.3 above provided a preliminary assessment of potential issues and impacts that may result from the proposed expansion of the Wild Coast Abalone facility. The table below provides a summary of the most significant preliminary impacts (all impacts rated as ‘High’ pre- mitigation) identified, and the associated specialist assessments recommended to be undertaken during the EIA phase.

Table 13-1: Summary of Preliminary Impact Assessment Significance pre- Significance post- Impacts Further Assessment Required mitigation mitigation Planning and Design Phase HIGH Legal and policy compliance LOW NEGATIVE General EIA NEGATIVE

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Significance pre- Significance post- Impacts Further Assessment Required mitigation mitigation Sewage Package Plant Design & HIGH MODERATE Groundwater Protocol Operation NEGATIVE NEGATIVE Assessment Loss of Species of Conservation HIGH MODERATE Ecological Impact Assessment Concern (SCC) NEGATIVE NEGATIVE HIGH Health and safety LOW NEGATIVE General EIA NEGATIVE HIGH Groundwater Protocol Water supply LOW NEGATIVE NEGATIVE Assessment HIGH Visual Impacts LOW NEGATIVE General EIA NEGATIVE Loss of heritage and paleontological HIGH Heritage and Paleontological LOW NEGATIVE resources NEGATIVE Impact Assessment Inadequate rehabilitation and HIGH LOW NEGATIVE General EIA maintenance NEGATIVE Construction Phase HIGH Legal and policy compliance LOW NEGATIVE General EIA NEGATIVE Aquatic Impact Assessment HIGH Ecological Impact Assessment Bulk Service Infrastructure Installation LOW NEGATIVE NEGATIVE Groundwater Protocol Assessment HIGH MODERATE Loss of natural vegetation NEGATIVE NEGATIVE Ecological Impact Assessment Loss of Species of Conservation HIGH MODERATE Concern (SCC) NEGATIVE NEGATIVE Changes to fluvial geomorphology and HIGH HIGH hydrology NEGATIVE NEGATIVE Disturbance of aquatic and wetland HIGH MODERATE Aquatic Impact Assessment vegetation and habitat NEGATIVE NEGATIVE HIGH MODERATE Water Quality NEGATIVE NEGATIVE Disturbance to the dune, beach and HIGH MODERATE Marine Impact Assessment inter-tidal zones NEGATIVE NEGATIVE Loss of heritage and paleontological HIGH MODERATE Heritage and Paleontological resources NEGATIVE NEGATIVE Impact Assessment Aquatic Impact Assessment Inadequate rehabilitation and HIGH LOW NEGATIVE Ecological Impact Assessment maintenance NEGATIVE General EIA Operation Phase HIGH Legal and policy compliance LOW NEGATIVE General EIA NEGATIVE HIGH MODERATE Groundwater Protocol Waste Management NEGATIVE NEGATIVE Assessment Aquatic Impact Assessment HIGH MODERATE Water Quality Groundwater Protocol NEGATIVE NEGATIVE Assessment HIGH MODERATE Erosion and channelling of seashore NEGATIVE NEGATIVE Marine Impact Assessment Discharge of enriched seawater HIGH MODERATE effluent NEGATIVE NEGATIVE Biosecurity risk to the marine HIGH MODERATE Biosecurity Risk Assessment environment NEGATIVE NEGATIVE Health and safety HIGH LOW NEGATIVE General EIA

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Significance pre- Significance post- Impacts Further Assessment Required mitigation mitigation NEGATIVE HIGH Groundwater Protocol Water supply LOW NEGATIVE Assessment NEGATIVE Aquatic Impact Assessment HIGH Visual Impacts LOW NEGATIVE General EIA NEGATIVE Inadequate rehabilitation and HIGH MODERATE General EIA maintenance NEGATIVE NEGATIVE

13.3 FATAL FLAWS

No fatal flaws have been identified during the Scoping Phase of this assessment. Further specialist studies (as recommended in section 12.3 above) will be required during the EIA phase to determine the overall impact significance of the proposed development to the receiving environment.

13.4 RECOMMENDATIONS

It is recommended that the following activities form part of the EIA phase:

 Specialist impact assessments as per section 12.3 above;  Public Participation: public meetings, public review of documentation;  Evaluation of impacts pre- and post-mitigation;  Compilation of practicable and effective mitigation measures;  Provision of an EAP opinion as to whether or not the activity should be authorised;  Compilation of an environmental impact statement; and  Compilation of a Draft EMPr.

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14 REFERENCES

Census 2011: Statistics South Africa (2011) South African Population Census 2011.

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

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

Nature and Environmental Conservations Ordinance No 19 of 1974.

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

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

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

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

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

Websites:

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

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

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15 APPENDICES

• Appendix A: Curriculum Vitae of the EAP and Project Team • Appendix B: Public Participation Proof • Appendix C: Additional Information

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APPENDIX A: CURRICULUM VITAE OF THE EAP

ALAN ROBERT CARTER Curriculum Vitae

CONTACT DETAILS

Name of Company CES – Environmental and Social Advisory Services Designation East London Branch Profession Executive

Years with firm 17 (Seventeen) Years E-mail [email protected] Office number +27 (0)43 7267809 / 8313

Nationality South African

Professional Body SACNASP: South African Council for Natural Scientific Profession EAPSA: Environmental Assessment Practitioners Southern Africa IWMSA: Institute Waste Management Southern Africa TSBPA: Texas State Board of Public Accountancy (USA)

Key areas of expertise  Marine Ecology  Environmental and coastal management  Waste management  Financial accounting and project feasibility studies  Environmental management systems, auditing and due-diligence PROFILE

Alan has extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He is a member of the American Institute of Certified Public Accountants (licensed in Texas) and holds a PhD in Plant Sciences. He is also a certified ISO14001 EMS auditor with the American National Standards Institute. Alan has been responsible for leading and managing numerous and varied consulting projects over the past 25 years.

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EMPLOYMENT  October 2013 – Present: Executive (EOH Coastal & Environmental EXPERIENCE Services, East London, South Africa)  January 2002 – September 2013: Director (Coastal & Environmental Services, East London, South Africa)  January 1999 – December 2001: Manager (Arthur Andersen LLP, Public Accounting Firm, Chicago, Illinois USA)  December 1996 – December 1998: Senior Accountant/Auditor (Ernst & Young LLP, Public Accounting Firm, Austin, Texas, USA).)  January 1994 – December 1996: Senior Accountant/Auditor (Ernst & Young, Charteris & Barnes, Chartered Accountants, East London, South Africa)  July 1991 – December 1994: Associate Consultant (Coastal & Environmental Services, East London, South Africa)  March 1989 – June 1990: Data Investigator (London Stock Exchange, London, England, United Kingdom)

ACADEMIC  Ph.D. Plant Science (Marine) Rhodes University 1987  QUALIFICATIONS B. Compt. Hons. Accounting Science University of South Africa 1997  B. Com. Financial Accounting Rhodes University 1995  B.Sc. Hons. Plant Science Rhodes University 1983  B.Sc. Plant Science & Zoology Rhodes University 1982

COURSES  Environmental Management Systems Lead Auditor Training Course - American National Standards Institute and British Standards Institute (2000)  ISO 14001:2015 Implementing Changes - British Standards Institute (2015)  Numerous other workshops and training courses

CONSULTING Environmental Impact Assessment, Feasibility and Pre-feasibility EXPERIENCE Assessments  Managed numerous projects and prepared environmental impact

assessment (EIA) reports in terms of relevant EIA legislation and regulations for development proposals including: Infrastructure projects: bulk water and waste water, roads, electrical, mining, ports, aquaculture, renewable energy (solar and wind), industrial processes, housing developments, golf estates and resorts, etc. (2002 – present).  Projects have also included preparation of applications in terms of other

statutory requirements, such as water-use and mining licence /permit applications.  Managed projects to develop pre-feasibility and feasibility assessments for various projects, including various tourism developments, infrastructure projects, etc.  Managed project for the East London Industrial Development Zone (ELIDZ)

to develop a Conceptual Framework for a Mariculture Zone within the ELIDZ (2009).  Managed pre-feasibility study to establish a Mariculture Zone within the Coega Industrial Development Zone (2014).  Assisted City of Johannesburg in the process to proclaim four nature reserves in terms of relevant legislation (2015-2016).  Acted as Environmental Control Officer (ECO) for numerous projects including solar and wind farms, roads, industrial processes, etc.

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Strategic Environmental Assessment  Managed Strategic Environmental Assessment (SEA) project toward the development of a Biofuel Industry in the Eastern Cape Province of South

Africa (2014-2016)  Managed Strategic Environmental Assessment (SEA) projects for two South African ports (2006 – 2007).  Managed Strategic Environmental Assessment (SEA) projects for five (5) local municipalities in the Eastern Cape as part of the municipal Spatial Development Framework plans (2004 – 2005).

 Involved in the financial assessment of various land-use options and carbon credit potential as part of a larger Strategic Environmental Assessment (SEA) for assessing forestry potential in Water Catchment Area 12 in the Eastern Cape of South Africa (2006).

Climate change, emissions trading and renewable energy

 Provided specialist peer review services for National Department of Environmental Affairs relating to climate change impact assessments for large infrastructure projects (2017-2018).  Conducted climate change impact assessment for a proposed coal-fired power station in Africa (2017-2018).  Participated in the development of a web-based Monitoring & Evaluation

(M&E) system for climate change Mitigation and Adaptation in South Africa for National Department of Environmental Affairs (DEA) (2015-2016.  Managed project to develop a Climate Change Strategy for Buffalo City Metro Municipality (2013).  Managed projects to develop climate change strategies for two district municipalities in the Eastern Cape Province (2011).

 Conducted specialist carbon stock and greenhouse gas emissions impact and life cycle assessment as part of the Environmental, Social and Health Impact Assessment for a proposed sugarcane to ethanol project in Sierra Leone (2009 - 2010) and a proposed Jatropha bio-diesel project in Mozambique (2009 - 2010).  Managed project to develop the Eastern Cape Province Climate Change

Strategy (2010).  Managed project to develop a Transnet National Ports Authority Climate Change Risk Strategy (2009)  Participated in a project to develop a Renewable Energy roadmap for the East London Industrial Development Zone (ELIDZ) (2013).  Participated in a project for the East London Industrial Development Zone

(ELIDZ) and Eastern Cape Government to prepare a Renewable Energy Strategy (2009).  Contributed to the development of Arthur Andersen LLP’s International Climate Change and Emissions Trading Services (2001).  Conducted carbon credit (Clean Development Mechanism - CDM) feasibility assessment for a variety of renewable energy projects ranging from biogas to solar PV.  Participated in the preparation of CDM applications for two solar PV projects in the Eastern Cape.

Waste Management  Managed project to develop Integrated Waste Management Plans for six

local municipalities on behalf of the Sarah Baartman District Municipality in the Eastern Cape Province (2016).  Managed project to develop Integrated Waste Management Plans for four

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local municipalities on behalf of Alfred Nzo District Municipality in the Eastern Cape Province (2015).  Managed project to develop Integrated Waste Management Plans for eight

local municipalities on behalf of Chris Hani District Municipality in the Eastern Cape Province (2011).  Managed a project to develop a zero-waste strategy for a community development in the Eastern Cape Province (2010).  Managed waste management status quo analysis for a District Municipality in the Eastern Cape Province (2003).

 For three consecutive years, managed elements of the evaluation of the environmental financial reserves of the three largest solid waste companies (Waste Management, Inc., Republic Services, Inc., Allied Waste, Inc.) and number of smaller waste companies in the USA as part of the annual financial audit process for SEC reporting purposes. Ensured compliance with RCRA and CERCLA environmental regulations.

 Managed elements of the evaluation of the environmental financial reserves of the largest hazardous waste company in the USA (Safety-Kleen, Inc.), as part of the audit process for SEC reporting purposes. Ensured compliance with RCRA and CERCLA environmental regulations.

Environmental Due Diligence and Business Risk

 Conducted environmental due diligence projects on behalf of the German Development Bank for a forestry pulp and paper operation in Swaziland (2010) and for a large diversified South African agricultural/agro-processing company (2011)  Managed project for the Transnet National Ports Authority to identify the environmental risks and liabilities associated with the operations of the Port

of Durban as part of a broader National initiative to assess business and financial risks relating to environmental management (2006).  Managed project to determine the financial feasibility of various proposed tourism developments for the Kouga Development Agency in the Eastern Cape Province (2006)  Contributed significantly to a study to determine the financial and

environmental feasibility of three proposed tourism development projects at Coffee Bay on the Wild Coast (2004).  Conducted sustainability and cost/benefit analysis of various waste water treatment options (including a marine pipeline at Hood Point) for the West Bank of East London (2004).  Conducted analysis of permit fees and application processing costs for off-

road vehicle use on the South African coastline for the Department of Environmental Affairs and Tourism, Marine & Coastal Management (2003).  Involved in the determination of the historical cost element of environmental remediation insurance claims for a number of multinational companies, including Dow Chemicals, Inc. and International Paper, Inc.  Evaluated the environmental budgeting process of the US Army and provided best practice guidance for improving the process.

Policy and Guidelines  Development of Administration / Application Fee Structure for the Reclamation of Land, Coastal Use Permits, Coastal Waters  Discharge Permits, Dumping Of Waste at Sea, Off-Road Vehicle Regulations

Promulgated in Terms of the National Environmental Management Act: Integrated Coastal Management Act (Act No. 24 Of 2008) (2017).  Managed project to develop an Estuarine Management Plan for the Buffalo

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River Estuary for the National Department of Environmental Affairs (2017).  Managed project to develop a Coastal Management Programme for Amathole District Municipality, Eastern Cape (2015 – 2016).

 Managed project to develop a sustainability diagnostic report as part of the development of the Eastern Cape Development Plan and Vision 2030 (2013).  Managed project for the Department of Environmental Affairs and Tourism, Marine & Coastal Management to determine the cost implications associated with the implementation of the Integrated Coastal Management Act (2007).

 Managed project to develop a Conservation Plan and Municipal Open Space System (MOSS) for Buffalo City Municipality (2007)  Managed project to develop a Sanitation Policy and Strategy for Buffalo City Municipality, Eastern Cape (2004 – 2006).  Managed project to develop an Integrated Environmental Management Plan and Integrated Coastal Zone Management Plan for Buffalo City Municipality,

Eastern Cape (2004 – 2005).  Managed projects to develop and implement an Environmental Management System (EMS) for the Chris Hani and Joe Gqabi (formerly Ukhahlamba) District Municipalities in the Eastern Cape generally in line with ISO14001 EMS standards (2004 – 2005).  Managed project to develop a State of the Environment Report and

Environmental Implementation Plans for Amathole, Chris Hani, OR Tambo and Joe Gqabi District Municipalities in the Eastern Cape Province (2005 – 20010).  Conducted analysis of permit fees and application processing costs for off- road vehicle use on the South African coastline for the Department of Environmental Affairs and Tourism, Marine & Coastal Management (2003).

Environmental auditing and compliance  Conducted environmental legal compliance audit for various large Transnet Freight Rail facilities (2018).  Managed projects to develop Environmental & Social Management Systems (ESMS) in line with IFC Performance Standards for three (3) wind farms in

South Africa (2015-2018).  Managed project to develop an Environmental & Social Management System (ESMS) in line with IFC Performance Standards for a telecoms company in Zimbabwe on behalf of the German Development Bank (2013)  Participated in numerous ISO14001 Environmental Management System (EMS) audits for large South African corporations including SAPPI, BHP

Billiton, SAB Miller, Western Platinum Refinery, Dorbyl Group and others (2002 – present).  Reviewed the SHE data reporting system of International Paper, Inc. (IP) for three successive years as part of the verification of the IP SHE Annual Report, which included environmental assessments of 12 IP pulp and paper mills located throughout the USA.  Conducted Environmental Management System (EMS) reviews for a number of large US corporations, including Gulfstream Aerospace Corporation

Public financial accounting  While with Ernst & Young LLP, (USA), functioned as lead financial auditor for various public and private companies, mostly in the technology business

segment of up to $200 million in annual sales. Client experience included assistance in a $100 million debt offering, a $100 million IPO and SEC annual and quarterly reporting requirements.

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 Completed three years of articles (training contract) in fulfilment of the certification requirements of the South African Institute of Chartered Accountants which included auditing, accounting and preparation of tax

returns for many small to medium sized commercial entities.

PUBLICATIONS Refereed Publications  Carter, A.R. 1985. Reproductive morphology and phenology, and culture studies of Gelidium pristoides (Rhodophyta) from Port Alfred in South Africa. Botanica Marina 28: 303-311.  Carter, A.R. 1993. Chromosome observations relating to bispore production in Gelidium pristoides (Gelidiales, Rhodophyta). Botanica Marina 36: 253- 256.  Carter, A.R. and R.J. Anderson. 1985. Regrowth after experimental harvesting of the agarophyte Gelidium pristoides (Gelidiales: Rhodophyta) in the eastern Cape Province. South African Journal of Marine Science 3: 111- 118.  Carter, A.R. and R.J. Anderson. 1986. Seasonal growth and agar contents in Gelidium pristoides (Gelidiales, Rhodophyta) from Port Alfred, South Africa. Botanica Marina 29: 117-123.  Carter, A.R. and R.H. Simons.1987. Regrowth and production capacity of Gelidium pristoides (Gelidiales, Rhodophyta) under various harvesting regimes at Port Alfred, South Africa. Botanica Marina 30: 227-231.  Carter, A.R. and R.J. Anderson. 1991. Biological and physical factors controlling the spatial distribution of the intertidal alga Gelidium pristoides in the eastern Cape Province, South Africa. Journal of the Marine Biological Association of the United Kingdom 71: 555-568.

Published reports  Water Research Commission. 2006. Profiling Estuary Management in Integrated Development Planning in South Africa with Particular Reference to the Eastern Cape. Project No. K5/1485.  Turpie J., N. Sihlophe, A. Carter, T, Maswime and S. Hosking. 2006. Maximising the socio-economic benefits of estuaries through integrated planning and management: A rationale and protocol for incorporating and enhancing estuary values in planning and management. Un-published Water Research Commission Report No. K5/1485

Conference Proceedings  Carter, A.R. 2002. Climate change and emission inventories in South Africa. Invited plenary paper at the 5th International System Auditors Convention, Pretoria. Held under the auspices of the South African Auditor & Training Certification Association Conference (SAATCA).  Carter, A.R. 2003. Accounting for environmental closure costs and remediation liabilities in the South African mining industry. Proceedings of the Mining and Sustainable Development Conference. Chamber of Mines of South Africa, Vol. 2: 6B1-5  Carter, A.R. and S. Fergus. 2004. Sustainability analysis of wastewater treatment options on the West Bank of East London, Buffalo City. Proceedings of the Annual National Conference of the International Association for Impact Assessment, South African Affiliate: Pages 295-301.  Carter, A., L. Greyling, M. Parramon and K. Whittington-Jones. 2007. A methodology for assessing the risk of incurring environmental costs associated with port activities. Proceedings of the 1st Global Conference of

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the Environmental Management Accounting Network.  Hawley, GL, McMaster AR and Carter AR. 2009, Carbon, carbon stock and life-cycle assessment in assessing cumulative climate change impacts in the environmental impact process. Proceedings of the Annual National Conference of the International Association for Impact Assessment, South African Affiliate.  Hawley, GL, McMaster AR and Carter AR. 2010. The Environmental and Social Impact Assessment and associated issues and challenges. African, Caribbean and Pacific Group of States (ACP), Science and Technology Programme, Sustainable Crop Biofuels in Africa.  Carter, A.R. 2011. A case study in the use of Life Cycle Assessment (LCA) in the assessment of greenhouse gas impacts and emissions in biofuel projects. 2nd Environmental Management Accounting Network- Africa Conference on Sustainability Accounting for Emerging Economies. Abstracts: Pages 69-70.

CERTIFICATION

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

ALAN ROBERT CARTER Date: January 2019

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APPENDIX B: PUBLIC PARTICIPATION PROOF

APPENDIX B1: SITE NOTICE

Marshstrand

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SITE NOTICE 1: 32°45'19.89"S; 28°15'38.90"E

SITE NOTICE 2: 32°45'10.65"S; 28°16'12.55"E

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APPENDIX B2: COPY OF NEWSPAPER ADVERT

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APPENDIX B3: BACKGROUND INFORMATION DOCUMENT

ENVIRONMENTAL IMPACT ASSESSMENT: WILD COAST ABALONE FACILITY EXPANSION, MARSHSTRAND, GREAT KEI LOCAL MUNICIPALITY

BACKGROUND INFORMATION DOCUMENT (BID) & INVITATION TO COMMENT

Return address for comments:

CES

Attention: Robyn Thomson 39 Harewood Drive, Nahoon P.O Box 8145, Nahoon, East London, 5241 Tel: (043) 726 7809 Fax: (086) 410 7822 Email: [email protected]

AIM OF THIS DOCUMENT

The purpose of this document is to ensure that people that are interested in or affected by the proposed project are provided with information about the proposal, the process being followed and provided with an opportunity to be involved in the Environmental Impact Assessment (EIA) process for proposed expansion of the Wild Coast Abalone facility.

Registering as an Interested and/or Affected Party (I&AP) allows individuals or groups the opportunity to contribute ideas, issues, and concerns relating to the project. I&APs also have an opportunity to review all of the reports and submit their comments on those reports. All of the comments that are received will be included in the reports that are submitted to the Competent Authority (CA). THE PROPONENT

Wild Coast Abalone (Pty) Ltd is proposing the expansion of the existing abalone facility. Wild Coast Abalone (Pty) Ltd have appointed Coastal and Environmental Services (t/a CES) as the project Environmental Assessment Practitioner (EAP). LOCATION

The proposed expansion of the existing Wild Coast Abalone facility is located on the coastline between Marshstrand and Fish Bay, within the Great Kei Local Municipality (GKLM) within the Amathole District Municipality (ADM), in the Eastern Cape Province. The existing abalone facility is located adjacent to a strip of coastal thicket managed as the East London Coast Nature Reserve, and in the marine realm, the Amathole Marine Protected Area (MPA).

The existing abalone facility is located on Portion 1 of Farm 259, Haga Haga, Eastern Cape Province. The table below list the properties affected by the proposed expansion:

Farm name Address 21- digit Surveyor General code

Farm 459 Haga Haga, 5272 C04000000000045900000

Portion 1 of Farm 259 Haga Haga, 5272 C04000000000025900001

Farm 108 Haga Haga, 5272 C04000000000010800000

Farm 456 Haga Haga, 5272 C04000000000045600000

PROJECT DESCRIPTION

The expansion of the existing Wild Coast Abalone facility will result in an increase in abalone production from 350 tonnes per annum to 1500 tonnes per annum. This will necessitate following activities:

 Construction of additional abalone grow out tanks and seaweed paddle ponds;  Construction/expansion of the workshops, packroom and processing facility, hatchery expansion and feed factory/storage;  Construction of a new pumphouse and additional seawater inlet and outlet pipelines for seawater abstraction and discharge respectively;  Construction of an additional 24 managerial dwelling units and associated service infrastructure;  Construction of associated service infrastructure, such as internal roads, stormwater channels and attenuation dam, electric cabling, water reticulation.  Construction of onsite sewage treatment and sewage reticulation; and  Construction of two additional substations on site, and additional above-ground diesel storage tanks. Refer to the Figures 1: Locality Map and Figure 2: Detailed Site Layout Plan THE ENVIRONMENTAL ASSESSMENT PRACTITIONER

CES was established in 1990 as a specialist environmental consulting company and has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, State of Environment Reporting (SOER), Integrated Waste Management Plans (IWMP), Environmental Management Programme (EMPr), Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) processes. EOH CES has been active in all of the above fields, and in so doing have made a positive contribution towards environmental management and sustainable development in the Eastern Cape, South Africa and many other African countries. We believe that a balance between development and environmental protection can be achieved by skilful, considerate and careful planning. the environmental impact assessment Process

According to the EIA regulations (2014, as amended) promulgated under the National Environmental Management Act (NEMA) (Act No.107 of 1998; NEMA) the potential impacts on the environment will have to be assessed in terms of the listed activities. The proposed expansion of the Wild Coast Abalone Facility triggers listed activities (Table 1 below) in terms of the NEMA EIA Regulations (2014, as amended) as per Listing Notices 1, 2, and 3, and as such requires the completion of a Full Scoping and EIA Report to be undertaken in accordance with Regulation 6 of the EIA Regulations (2014, as amended). The competent authority for this application will be the Department of Economic Development, Environmental Affairs and Tourism (ECDEDEAT) (Amathole Region).

Table 1: The potential triggered listed activities in terms of the NEMA EIA regulations (2014, as amended). LISTED ACTIVITIES APPLICABILITY LISTING NOTICE 1: ACTIVITIES REQUIRING A BASIC ASSESSMENT 12 (i) (ii) (a) The development of— The proposed expansion will require the construction of (c) (i) dams or weirs, where the dam or weir, including a new stormwater attenuation dam and an earth swale infrastructure and water surface area, exceeds 100 (stormwater diversion channel), exceeding 100m2 within square metres; or a watercourse/wetland, and within 32 metres of a (ii) infrastructure or structures with a physical footprint watercourse/wetland. of 100 square metres or more; where such development occurs— (a) within a watercourse;

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LISTED ACTIVITIES APPLICABILITY (c) if no development setback exists, within 32 metres of a watercourse, measured from the edge of a watercourse. 14 The development and related operation of facilities or The combined capacity of diesel storage will be 90m3. infrastructure, for the storage, or for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80 cubic metres or more but not exceeding 500 cubic metres. 19 The excavation, removal or moving of soil, sand, shells, The proposed expansion will involve earthworks related shell grit, pebbles or rock of more than 10 cubic metres to stormwater management within a watercourse. from a watercourse.

19A The infilling or depositing of any material of more than The proposed seawater inlet pipeline and wave energy (i)(ii)(iii) 5 cubic metres into, or the dredging, excavation, pipeline will involve excavation and backfilling of removal or moving of soil, sand, shells, shell grit, sand/shells/rock (exceeding 5m3) from the seashore, 100 pebbles or rock of more than 5 cubic metres from: meters inland of the high-water mark, and sea. (i) the seashore (ii) the littoral active zone, an estuary or a distance of 100 metres inland of the high- water mark of the sea or an estuary, whichever distance is the greater. (iii) The sea. 24 (ii) The development of a road— It is proposed that the existing road to Fish Bay be (ii) with a reserve wider than 13,5 meters, or where no realigned to the north of the proposed new vehicle reserve exists where the road is wider than 8 metres; workshop, garage and offices. 34 The expansion of existing facilities or infrastructure for The proposed expansion of the abalone facility will result any processor activity where such expansion will result in the need for a coastal water discharge permit for the in the need for a permit or licence or an amended release of treated effluent (increase by more than 50m3 permit or licence in terms of national or provincial per day). legislation governing the release of emissions, effluent or pollution, excluding— (iii) the expansion is directly related to aquaculture facilities or infrastructure where the wastewater discharge capacity will be increased by 50 cubic meters or less per day. 41 (i) (ii) The expansion and related operation of facilities, The proposed expansion is for the existing abalone (iii) infrastructure or structure for aquaculture of: facility which will result in an increase of abalone (i) finfish, crustaceans, reptiles or amphibians, where (Molluscs - Haliotidae sp.) production from 350 tonnes to the annual production output of such facility, 1500 tonnes per annum. There will also be an increase in infrastructure or structures will be increased by 20,000 seaweed production (aquatic plants) of more than kg (wet weight) or more; 60,000kg. (ii) molluscs and echinoderms where the annual production output of such facility, infrastructure or In addition to abalone, the facility also plans to diversify structures will be increased by 30,000 kg (wet weight) into the production of other indigenous marine species, or more; such as (but not limited to), rock lobster and sea (iii) aquatic plants where the annual production output cucumbers (Holothuria scabra). of such facility, infrastructure or structures will be increased by 60,000 kg (wet weight) or more. 45 (i) (ii) (a) The expansion of infrastructure for the bulk The proposed expansion will require the construction of (b) transportation of water or storm water where the internal stormwater channels (earth swales) and existing infrastructure— underground water pipelines likely to exceed 120 litres (i) has an internal diameter of 0,36 metres or more; or per second (stormwater), and exceed 1000m in total, (ii) has a peak throughput of 120 litres per second or and/or have an increase in throughput capacity of more more; and than 10%. (a) where the facility or infrastructure is expanded by more than 1 000 metres

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LISTED ACTIVITIES APPLICABILITY in length; or (b) where the throughput capacity of the facility or infrastructure will be increased by 10% or more; 46 (i) (ii) (a) The expansion and related operation of infrastructure The proposed expansion will require the construction of (b) for the bulk transportation of sewage, effluent, process additional infrastructure for the transportation of sewage water, waste water, return water, industrial discharge (domestic) and abalone effluent (facility) water, likely to or slimes where the existing infrastructure— exceed 120 litres per second, and exceed 1000m in total, (i) has an internal diameter of 0,36 metres or more; or and/or have an increase in throughput capacity of more (ii) has a peak throughput of 120 litres per second or than 10%. more; and (a) where the facility or infrastructure is expanded by more than 1 000 metres in length; or (b) where the throughput capacity of the facility or infrastructure will be increased by 10% or more. 48 (i) (ii) (a) The expansion of The proposed expansion will require the construction of (c) (i) infrastructure or structures where the physical a new stormwater attenuation dam and the expansion of footprint is expanded by 100 square metres or more; the existing abalone facility and associated infrastructure (ii) dams or weirs, where the dam or weir, including (exceeding 100m2) within a watercourse/wetland, and infrastructure and water surface within 32 meters of a watercourse/wetland. where such expansion occurs: (a) within a watercourse and/or (c) within 32 metres of a watercourse. 52 The expansion of structures in the coastal public The proposed expansion will require the construction of property where the development footprint will be additional seawater inlet pipeline and discharge channel increased by more than 50 square metres within the coastal public property that, combined, are likely to exceed 50m2. 54 (v) (e) (f) The expansion of facilities: The proposed expansion will require the construction of (v) if no development setback exists, within a distance infrastructure (exceeding 50m2) within the sea, littoral of 100 metres inland of the high-water mark of the sea zone and within 100m of high-water mark of the sea. or an estuary, whichever is the greater; in respect of: (f) infrastructure or structures where the development footprint is expanded by 50 square metres or more. 57 The expansion and related operation of facilities or The proposed expansion of the abalone facility will result infrastructure for the treatment of effluent, in significant waste water being generated (more than 15 wastewater or sewage where the capacity will be 000 m3 per day), which will be treated in algal ponds increased by 15 000 cubic metres or more per day and prior to discharge, the footprint of which will exceed the development footprint will increase by 1 000 1000m2. square meters or more. The discharge of treated domestic sewage effluent will be less than the thresholds outlined in LN1 (25). LISTING NOTICE 2: ACTIVITIES REQUIRING A FULL SCOPING AND EIA 15 The clearance of an area of 20 hectares or more of The expansion of the existing Wild Coast Abalone facility indigenous vegetation. will involve the clearance of more than 20 hectares of indigenous vegetation, classified as Hamburg Dune Thicket. LISTING NOTICE 3: ACTIVITIES REQUIRING A BASIC ASSESSMENT 2 (a) (ii) The development of reservoirs, excluding dams, with a The expansion of the existing abalone facility will involve (aa) (dd) capacity of more than 250 cubic metres. the construction of additional reservoirs with a total (ff) (hh) a. Eastern Cape capacity of more than 250 m3 for abalone grow tanks and ii. Outside urban areas, in: seaweed paddle ponds, located in the Eastern Cape, (aa) National Protected Area Expansion Strategy Focus within a NPAES focus area, a critical biodiversity area, areas; within 5 kilometres (km) of a protected area, and within (dd) Critical biodiversity areas as identified in 1km inland from the high-water mark of the sea. systematic biodiversity plans adopted by the competent authority or in bioregional plans; (ff) Areas within 10 kilometres from national parks or

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LISTED ACTIVITIES APPLICABILITY world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined 4 (a) (i) (bb) The development of a road wider than 4 metres with a It is proposed that the existing road to Fish Bay be (ee) (gg) reserve less than 13,5 metres. realigned to the north of the proposed new vehicle (hh) a. Eastern Cape workshop, garage and offices. A new road linking the i. Outside urban areas: new vehicle workshop and offices to the abalone facility (bb) National Protected Area Expansion Strategy Focus is also proposed. areas; (ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core areas of a biosphere reserve, excluding disturbed areas; (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined; 12(a) (ii) The clearance of an area of 300 square metres or more The expansion of the existing abalone facility will involve (iii) (v) of indigenous vegetation the clearance of more than 300 square meters of (a) Eastern Cape indigenous vegetation located in the Eastern Cape, within (iii) Within the littoral active zone or 100 metres inland 100 metres inland from the high-water mark of the sea, from the high-water mark of the sea, whichever within a protected nature reserve managed by ECPTA. distance is the greater, or (v) On land, where, at the time of the coming into effect of this Notice or thereafter such land was zoned open space, conservation or had an equivalent zoning. 16 (a) (i) (ff) The expansion of reservoirs, for bulk water supply The existing Abalone facility will involve the expansion of (hh) (ii) excluding dams, where the capacity will be increased by reservoirs (abalone grow out tanks and seaweed ponds) more than 250 cubic metres. by more than 250 cubic meters within a watercourse, (a) Eastern Cape located in the Eastern Cape, within critical biodiversity (i) Outside urban areas: areas, within 5 kilometres (km) of a protected area, and (ff) Critical biodiversity areas as identified in systematic within 1 km of the of the high-water mark of the sea. biodiversity plans adopted by the competent authority or in bioregional plans; (hh) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; or (ii) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined. 18 (a) (i) The widening of a road by more than 4 metres, or the The expansion of the existing facility will likely require (ee) (gg) lengthening of a road by more than 1 kilometre: the lengthening of internal access roads by more than 1 (hh) (ii) (a) Eastern Cape kilometre, located in the Eastern Cape, within a critical (i) Outside urban areas: biodiversity area, within 5 kilometres (km) of a protected (ee) Critical biodiversity areas as identified in area, and within 1 km of the of the high-water mark of systematic biodiversity plans; the sea, and within 100m of a watercourse/wetland. (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from

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LISTED ACTIVITIES APPLICABILITY the core area of a biosphere reserve; (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined; (ii) Areas on the watercourse side of the development setback line or within 100 metres from the edge of a watercourse where no such setback line has been determined. 22 (a) (i) The expansion and related operation of facilities or The proposed expansion will require the installation of (ee) (gg) infrastructure for the storage, or storage and handling additional above-ground diesel storage tanks with a (hh) of a dangerous good, where such storage facilities or combined capacity of 68 000 litres (68m3), located in the infrastructure will be expanded by 30 cubic metres or Eastern Cape, outside an urban area, within a critical more but no more than 80 cubic metres. biodiversity area, within 5 kilometres (km) of a protected (a) Eastern Cape, (i) outside urban areas: area, and within 1 km of the high-water mark of the sea. (ee) Within critical biodiversity areas identified in systematic biodiversity plans; or (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; or (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined. 23 (i) (ii) (a) The expansion of: The existing abalone facility will involve the expansion of (c) (a) (i) (i) dams or weirs where the dam or weir is the existing dam and infrastructure by more than 10 (ee) (gg) expanded by 10 square metres or more; or square meters within 32m and within a (hh) (ii) infrastructure or structures with a physical footprint watercourse/wetland, located outside an urban area in of 10 square metres or more; where such development the Eastern Cape, within a critical biodiversity area, occurs: (a) within a watercourse; or (c) if no within 5 kilometres (km) of a protected area, and within development setback has been adopted, within 32 1 km of the of the high-water mark of the sea. metres of a watercourse, measured from the edge of a watercourse: (a) Eastern Cape (i) Outside urban areas: (ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; or (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined. 24 (a) (ii) The expansion and related operation of facilities of any The existing abalone facility will involve the expansion of (iii) (iv) size for any form of aquaculture. infrastructure for aquaculture located in the Eastern (a) Eastern Cape Cape, within a watercourse and within 100 metres from (ii) In a Protected Area identified in the NEMPAA; the edge of a watercourse, and within a protected nature (iii) Areas on the watercourse side of the development reserve managed by ECPTA (seawater inlet pipeline). setback line or within 100 metres from the edge of a watercourse where no such setback line has been determined; or (iv) Within a watercourse.

The proposed expansion will also include:

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• Application for a Water Use License as per Section 21 of the National Water Act (1998); • Application for a Coastal Water Discharge Permit as per Section 69 of the Integrated Coastal Management (ICM) Act (2008); • Approval from the Department of Environmental Affairs, Forestry and Fisheries (DEFF: Forestry) and Eastern Cape Parks and Tourism (ECPTA) for the construction of the additional seawater inlet pipeline through a portion of coastal thicket within the East London Coast Nature Reserve • Approval from National Department of Environmental Forestry and Fisheries (DEFF): Oceans and Coast for the construction of an outlet discharge channel within the Amathole Marine Protected Area (MPA); and • Application for a seashore lease agreement for the new inlet pipeline and outlet channel as per the Sea Shore Act (1935).

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APPROACH TO THE EIA PROCESSES

The EIA process required for the proposed expansion of the Wild Coast Abalone Facility is a Full Scoping and EIA Report. The illustration below indicates where we are currently in the EIA process:

FULL SCOPING AND EIA

We are here

Figure 1. Process of the Environmental Impact Assessment (EIA)

POTENTIAL IMPACTS AND BENEFITS

CES will assess the impacts of the proposed activity on the environment. Impacts will be assessed for various alternatives; including the preferred alternative and the “No-Go” alternative. Impacts will be assessed for the planning and design phase, construction phase, operational phase and decommissioning phase of the proposed development. HOW CAN YOU Be INVOLVED?

A Public Participation Process (PPP) is being conducted as part of the EIA process for the proposed expansion of the Wild Coast Abalone facility. The aim of the PPP is to allow everyone who is interested in, or likely to be affected by the proposed development to provide input into the process.

The Public Participation Process includes:

 Advertisement in the Daily Dispatch;  On-site signage;  Circulation of the BID (this document) to all identified I&APs and stakeholders;  Commenting periods (30 days on the Draft Scoping Report and 30 days on the Environmental Impact Assessment Report);  Review of the reports by all registered I&APs and stakeholders; and  A public meeting.

If you consider yourself an interested and/or affected person/party, it is important that you become and remain involved in the PPP. In order to do so, please follow the steps below in order to ensure that you are continually informed of the project developments and will ensure your opportunity to raise issues and concerns pertaining to the project.

STEP 1: Please register by responding to our notification and invitation, with your name and contact details (details provided on cover page and below). As a registered I&AP, you will be informed of all meetings, report reviews and project developments throughout the EIA process.

STEP 2: Register by returning the slip at the back of this document to CES.

STEP 3: Attend any meetings that may be held during the EIA process. As a registered I&AP, you will receive an invitation to attend such meetings.

CES is required to engage with all private and public parties that may be interested and/or affected by the proposed interchange construction, in order to distribute information for review and comment in a transparent manner.

In the same light, it is important for I&APs to note the following:

1. In order for CES to continue engaging with you, please ENSURE that you register on our database by contacting the person below. 2. As the EIA process is regulated by specific review and comment timeframes, it is your responsibility to submit your comments within these timeframes.

Please send your enquiries and/or comments to:

Ms. Robyn Thomson 39 Harewood Drive, Nahoon, East London P.O Box 8145, Nahoon, East London, 5241 Tel: (043) 726 7809 Fax: 086 410 7822 Email: [email protected]

Figure 1: Locality Map

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Figure 2: Detailed Site Layout Plan

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I hereby wish to register as an Interested and Affected Party (I&AP) for the proposed expansion of the Wild

Coast Abalone facility located between Marshstrand and Fish Bay, Eastern Cape Province.

Name & Surname:

Organisation:

Postal Address:

Email:

Phone #:

Fax #:

My initial comments, issues or concerns are:

Other individuals, stakeholders, organisations or entities that should be registered are:

Name & Surname:

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APPENDIX B4: COMMENTS AND RESPONSES TRAIL All proof of comments and responses are attached below

Initial Notification: Notification of EIA process Date Consultant Notification 4 December Robyn Thomson Dear Stakeholder/ Interested & Affected Party 2020 NOTICE: PROPOSED EXPANSION OF THE WILD COAST ABALONE FACILITY, LOCATED NEAR HAGA HAGA, WITHIN THE GREAT KEI LOCAL MUNICIPALITY, EASTERN CAPE PROVINCE

Proponent: Wild Coast Abalone (Pty) Ltd are proposing the expansion of the existing abalone facility onto Farms 456, 459, and 108, located between Marshstrand and Fish Bay, North of Haga-Haga, Eastern Cape. Wild Coast Abalone (Pty) Ltd have appointed Coastal and Environmental Services (Pty) Ltd (CES) as the project Environmental Assessment Practitioner (EAP) to conduct the Environmental Impact Assessment (EIA) process for the proposed expansion of the Wild Coast Abalone facility.

Activity: The Wild Coast Abalone farm was established in 1998 after the original environmental authorisation was granted. The facility was granted authorisation for expansion in 2008. Due to a further increase in demand for these high value products, the applicant, Wild Coast Abalone (Pty) Ltd, is proposing an additional expansion to the existing abalone facility. The expansion of the existing Wild Coast Abalone facility will result in an increase in abalone production from 350 tonnes per annum to 1500 tonnes per annum. This will necessitate the following activities: • Construction of additional abalone grow out tanks and seaweed paddle ponds; • Construction/expansion of the workshops, packroom and processing facility, hatchery and feed factory/storage; • Construction of a new pumphouse and additional seawater inlet pipeline and outlet channel for seawater abstraction and discharge respectively; • Construction of an additional managerial dwelling units; • Construction of associated service infrastructure, such as internal roads, stormwater channels and attenuation dam, electric cabling, and water reticulation; • Construction of a sewage package plant onsite and sewage reticulation; • Construction of two additional substations on site, and additional above-ground diesel storage tanks; and • Investigating the possibility of an offshore wave energy pump to pump pressurised seawater back to the facility for additional power generation.

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This letter of notification serves to inform you, in terms of Regulation 41(2) published in Government Notice No. R 326 under Chapter 5 of the National Environmental Management Act (No. 107 of 1998; NEMA, as amended) of the intent to submit an application for environmental authorisation to the Department of Economic Development, Environmental Affairs and Tourism (ECDEDEAT) (Amathole Region).

The proposed expansion will also include:

• Application for a Water Use License as per Section 21 of the National Water Act (1998); • Application for a Coastal Water Discharge Permit as per Section 69 of the Integrated Coastal Management (ICM) Act (2008); • Approval from the Department of Environmental Affairs, Forestry and Fisheries (DEFF: Forestry) and Eastern Cape Parks and Tourism (ECPTA) for the construction of the additional seawater inlet pipeline and outlet discharge channel through a portion of coastal thicket within the East London Coast Nature Reserve; • Approval from National Department of Environment Forestry and Fisheries (DEFF): Oceans and Coast for the construction of an offshore wave energy pump within the Amathole Marine Protected Area (MPA); and • Application for a seashore lease agreement for the new pipeline and outlet channel as per the Seashore Act (1935).

Public Participation: A critical element of the Environmental Impact Assessment (EIA) is the Public Participation process. The objective is to contact, notify and inform stakeholders and members of the community, who may be interested and/or affected by the proposed abalone facility expansion, so that any such party may fully participate in, interact with and inform the EIA process. As a stakeholder, your involvement in the public participation process is vital and thus it is very important for us, as the EAP, to maintain an open and inclusive channel of communication with you.

Please note that the Draft Scoping Report will be made available to Interested and Affected Parties on the CES website, www.cesnet.co.za on 9 December 2020 for a period of 51 days until 29 January 2021.

It would be greatly appreciated if you would provide us with the contact details of any other person(s) you are aware of, that would be interested in or affected by this development.

For more information, registration as an Interested and Affected Party (I&AP), or submission of written comments, please contact us using the phone, fax, post or email details provided below:

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CES, Ms Robyn Thomson: P.O. Box 8145, Nahoon, East London, 5241 Telephone: (043) 726 7809 | Fax: 086 410 7822 | Email: [email protected]

I&AP comments/registrations from initial notification Date I&AP I&AP Comment CES Response 5 December Dianne Williams (on behalf of Which “dam” is being referred to in the It is proposed that a stormwater retention pond be 2020 I&APs) notification documentation? Is it a new one that constructed on the property. It is proposed that  Great Kei Local Municipality needs to be built on WCA property or is it the fresh water be sourced from boreholes and Ward 5 Councillor main dam that feeds Haga Haga, Retreat and rainwater harvesting. The main dam feeding the Committee Member Marshstrand villages? Ie where will WCA fresh villages in the area was assessed as a potential  Haga Haga Ratepayers water come from? source of fresh water in the preliminary Association investigation, however it has been concluded that  Haga Haga Conservancy this option is not feasible as the dam’s capacity is limited and the impact on the surrounding water users would be too high. The proposed project services are discussed under section 4.2.3 of this report and fresh water source alternatives have been discussed in detail under section 7. What is going to be done to the main Haga Haga The potential impact on roads has been identified road MR694 and Marshstrand road DR 2766 as in the preliminary impact assessment. This will be there will be a huge impact on these roads due assessed further in the EIA phase of the project. to the vast increase of traffic. Preliminary impacts can be seen under Section 11 of this report. Is the extra housing going to be purely for The additional housing is for management staff. Management staff or is it for the general labour, which currently is transported in and out every day? Certainly would not agree to have a “township” in this area at all.’

Impact on Property Values Comment noted. This will be investigated further in the EIA phase of the project. Noise Pollution The potential noise impact has been identified in

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the preliminary impact assessment. This will be assessed further in the EIA phase of the project. Preliminary impacts can be seen under Section 11 of this report. Light Pollution The potential light pollution impact has been identified in the preliminary impact assessment under visual impacts. This will be assessed further in the EIA phase of the project. Preliminary impacts can be seen under Section 11 of this report. Security during and after construction Wild Coast Abalone currently utilises the services of a security company for the security monitoring of their facility. This will remain in place during construction and operation. Rental of houses in Marshstrand for construction It is anticipated that during construction, some and housing after construction! contractors will reside outside of the area and drive to and from the site, others will live on site and some may rent houses in Marshstrand. Living arrangements will depend on availability of the various options. This being a huge expansion. Where is It is planned that Wild Coast Abalone will continue investment coming from? Chinese? And who to operate as it is currently. It is not envisaged that would be running WCA? there will be a change to the current executive structure. 8 December Bruce and Veronica West Issues and concerns include the effect towards The potential noise, visual and odour impacts have 2020 private residential properties at Fish Bay, been identified in the preliminary impact including view, noise, privacy, smell and value. assessment and will be assessed further in the EIA phase of the project. Preliminary impacts can be seen under Section 11 of this report.

It is noted that the impact on property values will investigated further in the EIA phase of the

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project. 5 December Donald Keth The road infrastructure will be totally The potential impact on roads has been identified 2020 inadequate. in the preliminary impact assessment. This will be assessed further in the EIA phase of the project. Preliminary impacts can be seen under Section 11 of this report. Why is the sewage treatment plant so close to Alternative sewage treatment options are the sea? discussed under Section 7 of this report. The most feasible location and design alternatives for the package plant will be considered as part of the updated groundwater protocol assessment and assessed further in the EIA. The final location of the treatment plant is pending based on the updated groundwater protocol assessment. Notification of availability of the Draft Scoping Report for public review Date Consultant Notification 9 December Robyn Thomson Dear Stakeholder/ Interested & Affected Party 2020 NOTICE: AVAILABILITY OF THE DRAFT SCOPING REPORT FOR PUBLIC REVIEW - PROPOSED EXPANSION OF THE WILD COAST ABALONE FACILITY, LOCATED NEAR HAGA HAGA, WITHIN THE GREAT KEI LOCAL MUNICIPALITY, EASTERN CAPE PROVINCE

Please be advised that the Draft Scoping Report (DSR) for the proposed expansion of the existing Wild Coast Abalone facility located between Marshstrand and Fish Bay as per the National Environmental Management Act (No. 107 of 1998; NEMA) Environmental Impact Assessment (EIA) regulations 2014 (as amended in 2017) has been made available to stakeholders and Interested and Affected Parties for review and comment for a period of 51 days from 9 December 2020 to 29 January 2021.

The report is available as follows: 1. http://www.cesnet.co.za/public-documents

Please submit written comments on or before 29 January 2021 using the phone, fax, post or email details provided below.

CES Environmental and Social Advisory Services Wild Coast Abalone Facility Expansion 146

CES, Ms Robyn Thomson: P.O. Box 8145, Nahoon, East London, 5241 Telephone: (043) 726 7809 | Fax: 086 410 7822 | Email: [email protected]

I&AP comments during 30-day public review period of the Draft Scoping Report

To be included in the Final Scoping Report

AUTHORITY PRE-APPLICATION MEETINGS & CORRESPONDENCE Date Authority Meeting Minutes 22 July 2019 Department of Economic Development, Environmental Affairs and Tourism Refer to meeting minutes below in Appendix B6 (DEDEAT); below Department of Agriculture, Forestry and Fisheries (DAFF); and Eastern Cape Parks and Tourism Agency (ECPTA)

30 July 2019 Department of Water Affairs and Sanitation (DWS): Pre-Consultation Meeting Refer to meeting minutes in Appendix B6 below 27 May 2020 – 9 Email correspondence with National Department of Environment, Forestry and Refer to email correspondence in Appendix B6 June 2020 Fisheries (DEFF): Oceans and Coast below

CES Environmental and Social Advisory Services Wild Coast Abalone Facility Expansion 147

APPENDIX B5: PROOF OF NOTIFICATIONS, COMMENTS AND RESPONSES

CES Environmental and Social Advisory Services Wild Coast Abalone Facility Expansion 148

Robyn Thomson

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Greer Hawley Mcmaster Delivered: 2020/12/04 15:35

3 Dear Stakeholder/ Interested & Affected Party

NOTICE: PROPOSED EXPANSION OF THE WILD COAST ABALONE FACILITY, LOCATED NEAR HAGA HAGA, WITHIN THE GREAT KEI LOCAL MUNICIPALITY, EASTERN CAPE PROVINCE

The proposed expansion will also include:

• Application for a Water Use License as per Section 21 of the National Water Act (1998); • Application for a Coastal Water Discharge Permit as per Section 69 of the Integrated Coastal Management (ICM) Act (2008); • Approval from the Department of Environmental Affairs, Forestry and Fisheries (DEFF: Forestry) and Eastern Cape Parks and Tourism (ECPTA) for the construction of the additional seawater inlet pipeline and outlet discharge channel through a portion of coastal thicket within the East London Coast Nature Reserve; • Approval from National Department of Environment Forestry and Fisheries (DEFF): Oceans and Coast for the construction of an offshore wave energy pump within the Amathole Marine Protected Area (MPA); and • Application for a seashore lease agreement for the new pipeline and outlet channel as per the Seashore Act (1935).

It would be greatly appreciated if you would provide us with the contact details of any other person(s) you are aware of, that would be interested in or affected by this development.

4 For more information, registration as an Interested and Affected Party (I&AP), or submission of written comments, please contact us using the phone, fax, post or email details provided below:

CES, Ms Robyn Thomson: P.O. Box 8145, Nahoon, East London, 5241 Telephone: (043) 726 7809 | Fax: 086 410 7822 | Email: [email protected]

I look forward to hearing from you.

CES shutdown: Please note our offices will be closed from 21 December 2020, reopening 4 January 2021

5 Robyn Thomson

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4 Subject: NOTICE: PROPOSED EXPANSION OF THE WILD COAST ABALONE FACILITY, LOCATED NEAR HAGA HAGA, WITHIN THE GREAT KEI LOCAL MUNICIPALITY, EASTERN CAPE PROVINCE

5 Robyn Thomson

From: Microsoft Outlook To: [email protected]; [email protected]; [email protected] Sent: Monday, 07 December 2020 12:32 Subject: Relayed: NOTICE: PROPOSED EXPANSION OF THE WILD COAST ABALONE FACILITY, LOCATED NEAR HAGA HAGA, WITHIN THE GREAT KEI LOCAL MUNICIPALITY, EASTERN CAPE PROVINCE

Delivery to these recipients or groups is complete, but no delivery notification was sent by the destination server: [email protected] ([email protected]) [email protected] ([email protected]) [email protected] ([email protected])

Subject: NOTICE: PROPOSED EXPANSION OF THE WILD COAST ABALONE FACILITY, LOCATED NEAR HAGA HAGA, WITHIN THE GREAT KEI LOCAL MUNICIPALITY, EASTERN CAPE PROVINCE

APPENDIX B6: AUTHORITY MEETING MINUTES/CORRESPONDENCE

CES Environmental and Social Advisory Services Wild Coast Abalone Facility Expansion 149

CES

PRE-APPLICATION MEETING WITH DEDEAT, DAFF & ECPTA TITLE Wild Coast Abalone Expansion

East London DATE 22 July 2019 25 Tecoma Street, Berea East London, 5201 Tel: +27 (43) 726 7809; VENUE CES Offices Fax: +27 (43) 726 8352 Email: [email protected] TIME OF MEETING 10:00am Website: www.cesnet.co.za

BACKGROUND

The purpose of the pre-application meeting is to provide the relevant Departments with an overview of the proposed project, and request feedback and comment regarding the proposed environmental authorization process to be followed, as well as permit/licensing requirements.

Project Overview:

The Wild Coast Abalone farm was established in 1998 after the original environmental authorisation was granted. The facility was granted authorisation for expansion in 2008. Due to a further increase in demand for these high value products, the applicant, Wildcoast Abalone (Pty) Ltd, is proposing an additional expansion to the existing abalone facility. The proposed expansion is expected to increase production from 350 tonnes per annum to 1500 tonnes per annum.

This will necessitate following activities:

• Construction of additional abalone grow out tanks and seaweed paddle ponds; • Construction/expansion of the workshops, packroom & processing facility, hatchery and feed factory/storage. • Construction of a new pumphouse and additional seawater inlet and outlet pipelines for seawater abstraction and discharge respectively; • Construction of an additional managerial dwelling units and associated service infrastructure (septic tanks); • Construction of associated service infrastructure, such as internal roads, stormwater channels and attenuation dam, electric cabling, water and sewage reticulation. • Two substations on site, and a proposed offshore wave energy reverse osmosis pump (WEROP) that uses wave energy to pressurise and pump seawater for electrical power production and high volume/low pressure seawater supply.

Parameters WCA WCA expansion WCA Combined Unit Current Total

Production of abalone 350 1140 1500 tonnes/annum Staff 432 1368 1800 persons

Abalone tanks 1470 4655 6125 tanks Seaweed paddle ponds 107 339 445 ponds Seaweed usage 127 373 500 tonnes/month

Seawater Abstraction 2500 7368 9868 Liter/second Seawater Effluent 9868 Liter/second

Solid Waste - general 2 5 7 31m3 skips/month Biological waste 7 23 30 m3/month

Housing 8 24 32 Houses

Minutes of Meeting Page 1 of 5

Existing seawater inlet/abstraction pipeline lies 7m below the ground leading to the sump and pumphouse (left). Proposed location of new seawater inlet pipeline (right).

Proposed location of new seawater inlet pipeline looking offshore (left). Proposed location of outlet pipeline (right)

Minutes of Meeting Page 2 of 5

CES

MEETING MINUTES

Introductions: General introductions were made, and attendance register circulated.

Project Overview: CES will provide an overview of the proposed expansion as per the printed A3 site plan provided in the meeting.

Specialist studies: The following specialist studies will be included in the EIA process:

• Ecological (terrestrial and marine) Impact Assessment • Wetland/Aquatic Impact Assessment • Biosecurity Risk Assessment • Heritage, Archaeological and Paleo Impact Assessment

CES stated that a separate pre-application meeting with Department of Water Affairs and Sanitation (DWS) is in the process of being arranged, as per their online eWULA system. The relevant water use licensing requirements will be confirmed during this meeting.

DISCUSSION COMMENT RESPONSE ECPTA ECPTA will require a letter to be sent to the CEO to formally engage with ECPTA regarding the proposed development.

DEDEAT: Various processes that are required which all CES: Noted. These processes will run Oceans & require public participation process to be concurrently with the EIA process. Coast followed: • Coastal waters discharge permit • Seashore lease agreement • EIA process Can the existing pipelines not be upgraded to Wild Coast Abalone (WCA): Technical issues additional pipelines? that need to be considered. • Inlet needs to be upstream of outlet due to inshore currents and biosecurity risk from effluent released. • Construction/upgrade of existing pipelines and pumphouse will pose a serious threat the abalone due to water quality disturbance over the long construction period. We would require the following information WCA: (existing and proposed) to be included in the • There is a water treatment and EIA report: monitoring system in place as well as a • Water treatment and monitoring biosecurity plan, so this can be made system– nutrients and parasites at available. outlet; • The flow rates (recirculatory system) are • Dimensions of pipelines; so high that there isn’t much difference • Biosecurity monitoring; in water quality coming in and out. • Brine discharge – should this be applicable from the wave energy generation.

Seashore lease agreement will require: • Dimensions of pipelines • Lease fee

Restrictions regarding MPA: CES: • Noted. National will be engaged with.

Minutes of Meeting Page 3 of 5 • No discharge in the MPA, but the facility Aquaculture is a strategic project, and socio- was established before the MPA was economic impact of the development will be established. assessed. • Input will be required from National Oceans & Coast. • Economic Assessment is recommended - proof of economic benefits. DEDEAT: The use of septic tanks are not favoured in CES: Noted. A groundwater protocol is being Oceans & the coastal zone. done for the proposed development, and Coast alternative treatment options will be investigated. ECPTA • Alternative energy options must be WCA: investigated, as we need to protect the • Renewable energy sources need to be MPA. investigated in order to become green • Is there a sieve at the inlet pipeline? certified, as this is being requested from • Visual impacts must be considered. our buyers. • Important to note the different zonings of • Are investigating wind energy (separate the MPA and the associated restrictions. application process) • Hydro power – turbine at outlet is not viable as the height difference between the outlet and sea level is too small. • There is a course grid sieve, and divers remove blockages/obstructions regularly. • Visual – only the pumphouse is visible from the seashore. WCA have received authorisation to rehabilitate and revegetate the area where the existing inlet is located. The same will be done for the proposed new inlet. • A vegetation screen is proposed using appropriate indigenous tree species on the Fish Bay side of the facility. • CES: MPA zonings will be considered. National will be engaged with. DEDEAT • Biodiversity offsets may need to be CES: Noted. This will be considered. considered for the coastal dune thicket and coastal grasslands. • DAFF will need to provide input regarding this. DAFF • Protected tree species will require permits. CES: • We will need to know the extent of the • Aquaculture is a strategic project, and forest that will be affected. socio-economic impact of the • Site visit will be required. development will be assessed. • Need to consider the national/provincial or • Ecologist will recommend appropriate regional importance of the development species for the offset and vegetation before approval is given. screen. • DAFF will consider the offset process to be followed. DEDEAT Important to include for all activities during CES: Noted. This will be included. the operational phase, and an operational management plan will be required. Increased hardening of surfaces from the CES: Noted: A stormwater layout is being development, therefore a stormwater updated by an Engineer. A stormwater management plan will be required. management plan will form part of the EMPr. Freshwater sources? The report must detail CES: Noted. Rainwater harvesting, and all applicable services required and the existing boreholes will provide adequate sources of such. freshwater. DAFF & An internal meeting will be arranged to CES: Noted. A date for the site visit will be ECPTA discuss the proposed development. communicated. Thereafter, a site visit will be arranged.

Minutes of Meeting Page 4 of 5

CES

CES Will the application will be sent to Provincial? DEDEAT: Yes. The listed activities triggered by the proposed DEDEAT (Hlomela): Noted. Their expansion will be sent to DEDEAT for review applicability will be reviewed. MEETING CLOSURE

Minutes of Meeting Page 5 of 5 CES

PRE-CONSULTATION MEETING WITH DWS

TITLE Wild Coast Abalone Expansion

East London DATE 30 July 2019 25 Tecoma Street, Berea East London, 5201 Tel: +27 (43) 726 7809; VENUE DWS Offices Fax: +27 (43) 726 8352 Email: [email protected] TIME OF MEETING 10:00am Website: www.cesnet.co.za

BACKGROUND

The purpose of the pre-consultation meeting is to provide the DWS with an overview of the proposed project, and request feedback and comment regarding the proposed water use licensing process to be followed, as per Section 21 of the National Water Act (1998).

Project Overview:

This will necessitate following activities:

• Construction of additional abalone grow out tanks and seaweed paddle ponds; • Construction/expansion of the workshops, packroom and processing facility, hatchery and feed factory/storage, and fertilser storage; • Construction of a new pumphouse and additional seawater inlet and outlet pipelines for seawater abstraction and discharge respectively; • Construction of an additional managerial dwelling units and associated service infrastructure (septic tanks); • Construction of associated service infrastructure, such as internal roads, stormwater channels and attenuation dam, electric cabling, water and sewage reticulation; • Groundwater protocol is being updated, which will determine the best way in which to deal with sewage on site. Septic tanks (french drain) are currently used on site, as recommended by the groundwater protocol report completed in 2008 for the original expansion. However, DEDEAT are not in favour of septic tanks within the coastal zone, therefore, possible alternatives will be investigated, i.e. package plant on site; • Stormwater management plan is currently being complied by Engineers; and • Wetland/Aquatic impact assessment will be undertaken as part of the EIA process.

Minutes of Meeting Page 1 of 4 MEETING MINUTES

Introductions: General introductions were made, and attendance register circulated.

Project Overview: CES provided an overview of the proposed expansion as per the printed A3 site plan provided in the meeting.

DISCUSSION COMMENT RESPONSE DWS: Section Location of the WWTW package plant will be • CES: The layout map is a draft version 21 g – waste needed, as well as how the waste will be and will be updated once the groundwater related discharged. Should the treated effluent be protocol and engineering components discharge discharged into the river to the west of the have been completed. Septic tanks facility or coastal zone, Section 21 (f) will (french drain) are currently used on site, apply. as recommended by the groundwater protocol report completed in 2008 for the original expansion. However, DEDEAT How is the current sewage dealt with on site? are not in favour of septic tanks within the coastal zone, therefore, possible alternatives will be investigated, i.e. package plant on site. How is the waste generated on site from the • CES: EnviroServ is currently contracted abalone production dealt with? to collect organic waste (stored in sealed drums). • Wild Coast Abalone Pty Ltd (WCA): Most of the abalone is exported live, so reduces the amount of shell waste. Remaining shells are dried and sold to farmers who crush it and use it as a calcium supplement in their feed. Some shells are also exported for ornamental uses. How will the waste water from the abalone • CES: Waste water from the abalone tanks tanks be dealt with? flows into the seaweed paddle ponds, which naturally filters the seawater, before it is released into the discharge channel into the marine environment. No seawater will be released into any freshwater system. How will the fertiliser be stored? Within a • CES: It will be stored within an enclosed building, or open? building, so there will be no potential contaminated runoff. DWS: Section Will groundwater be used for the facility • WCA: There are two boreholes on the 21 a - expansion? If yes, then Section 21 (a) – south western portion of the facility which Groundwater abstraction will be applicable and will require will be used to supplement the freshwater a license. use requirements for the facility. The freshwater demand of the facility must be compared with the calculated yields of the boreholes. This will determine whether it falls within the GA limits, or whether it will be a full license.

DWS: Will the stormwater be contaminated? • CES: No, it will just be rainfall runoff. Stormwater • WCA: Engineers surveyed the area and determined the runoff and designed the existing stormwater channel accordingly. The rainfall runoff currently collects in the existing dam on site. We will then propose another stormwater channel to direct any overflows the flood attenuation dam. Minutes of Meeting Page 2 of 4

CES

The abalone grow out tanks and paddle ponds will all have their own drainage which will lead into the seawater discharge channel, so no seawater or treated wastewater from the abalone tanks/seaweed paddle ponds will be released into any freshwater system. CES: Would the proposed stormwater attenuation • DWS: Planning: The design of the dam Stormwater dam require a Section 21(b)-dam registration will be important and will require a proper and dam application? spillway. Section 21(b) will be applicable registration in this case, even though it is an off- Should WCA require to abstract water from channel balancing dam, but you have the stormwater attenuation dam proposed, created a catchment for it. would that require a 21 (a)-abstraction • Section 21 (a) – abstraction will be application? applicable if you decide to abstract surface water from the dam for use in the facility. Also, the existing dam will need to be fixed, • DWS: As the existing dam will fall part of as the dam wall has collapsed. Will this the Integrated application, so Section require a 21 (b) – dam registration 21(b) will also be applicable. application? CES: Will a wetland offset be required for the • DWS: The functionality of the wetlands Wetlands removal of a wetland, or will that be will need to be determined by the dependent on the findings of the specialist. Wetland/Aquatic Specialist? • WCA: The dam wall will need to be reconstructed, and then move the existing spillway to otherside of the dam, and construct a hardened/concrete spillway. Designs will be done by the Engineers as part of the Stormwater Management Plan. • DWS: This can be considered as part the full Integrated License DWS: In terms of the role out of this application, it • CES: Noted. Once the proposed layout Planning will be an Integrated License: has been finalised with the Engineers a- Groundwater abstraction stormwater water management plan, and (boreholes), and surface water proposed sewage treatment options abstraction from the dam (possibly) b- Dam registration/s – reconstruction of the existing dam, and proposed stormwater attenuation dam; c- impeding or diverting the flow of water in a watercourse – this will be applicable for any access roads, pipelines, stormwater channels which impede/divert a watercourse/within 500m of a wetland; f – discharging waste or water containing waste into a water resource through a pipe, canal, sewer, sea outfall or other conduit – this may be applicable depending how sewage is dealt with on site; g - disposing of waste in a manner which may detrimentally impact on a water resource - this will be applicable for the use of septic tanks and/or treated effluent from a package plant on site; and i- altering the bed, banks, course or characteristics of a watercourse – same as for (c).

Minutes of Meeting Page 3 of 4 CES: Site DAFF and ECPTA has requested to go to DWS: Yes, this will be confirmed whether a Visit site, therefore, it would we could schedule the site visit will be required. site visit for DWS on the same day. A date and time still need to be confirmed, however, this will be communicated. CES: An indigenous vegetation screen is proposed DWS: If they were to be listed alien species Revegetation on the far eastern corner of the property to which use more water, then it may have reduce the visual impact from the Fish Bay implications, but natural vegetation is fine. residents. This will require comment from However, this would be for DAFF and DAFF mainly, however, please confirm if this Environmental Affairs to assess. has any implications for the Integrated License application, as this activity will fall within 500 m of a wetland. DWS: Are you linked to the municipal water supply? WCA: Yes, we are linked. However, we Planning switch it off and only use it when supply from rainwater harvesting/boreholes is not enough. As the application is assessed, we may CES: As we are currently still engaging with require more information or additional all the relevant authorities regarding the activities to be applied for, as aspects of the proposed activities on site and waiting for the layout still need to be confirmed. findings of the Groundwater Protocol and stormwater management plan, the proposed layout will need to be updated accordingly. I can propose an additional meeting with DWS to provide the finalised layout plan or provide this information as part of the eWULA process if/when additional information is requested. DWS: Agreed. MEETING CLOSURE APPENDIX A: ATTENDANCE REGISTER

Minutes of Meeting Page 4 of 4

CORRESPONDENCE WITH DEFF: OCEANS AND COASTS

Wild Coast Abalone (PTY) Ltd Your reference: PO Box 7613 Our reference: EIA/2019/034 East London 5200

FOR ATTENTION: RICHARD CLARK Delivered: By Email ([email protected])

Dear Richard

RE: REQUEST FOR WRITTEN CONSENT TO CONDUCT THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS FOR THE PROPOSAL TO CONSTRUCT AN ADDITIONAL SEAWATER INLET PIPELINE AND OUTLET DISCHARGE CHANNEL WITHIN A SECTION OF EAST LONDON COAST NATURE RESERVE AND THE AMATHOLE MARINE PROTECTED AREA, HAGA HAGA

The Eastern Cape Parks and Tourism Agency (ECPTA) is the designated management authority for East London Coast Nature Reserve and the Amathole Marine Protected Area. As the management authority of these two Protected Areas, the ECPTA hereby grant permission to Wild Coast Abalone (PTY) Ltd to conduct an Environmental Impact Assessment process in terms of the National Environmental Management Act (No 107 of 1998, as amended) for the proposed construction of a seawater inlet pipeline and outlet discharge channel within the Marshstrand section (Farm 108, SG 24 Code C04000000000010800000) of East London Coast Nature Reserve and the adjacent section of the Amathole Marine Protected Area, Haga Haga.

Please take note that the consent granted to undertake the Environmental Impact Assessment processes should not be interpreted to mean that the Agency supports the proposed development.

Should any site visits be required, please contact the Reserve Manager, Ayaka Peter ([email protected] / 071 476 4418) for permission and assistance. Note that the ECPTA shoud be included in all future correspondence relating to this application.

Yours sincerely,

______Vuyani Dayimani Date CHIEF EXECUTIVE OFFICER EASTERN CAPE PARKS AND TOURISM AGENCY

APPENDIX B7: I&AP DATABASE

Organisation/association Name/contact person Email GOVERNMENT & KEY STAKEHOLDERS DWS Lizna Fourie (Licensing) [email protected] DWS: WUA Esmeralda van Rooyen [email protected] DWS: Groundwater Babalwa Ndlangisa [email protected] DWS: WQM Z Magodla [email protected] DWS: WQM A Dukashe [email protected] DWS: WQM Moodley Dheegan [email protected] DWS: WUA Bera Moosa [email protected] DWS: WQM Kunene Bhekokwakhe [email protected] DWS: WQM Magwentshu Lawona [email protected] ECPHRA (EC Heritage) Mzikayise L Zote [email protected] ECPHRA (EC Heritage) Mr Sello Mokhanya [email protected] South African Heritage Resource Agency Ragna Redelstorff [email protected] (SAHRA) DEDEAT Hlomela Hanise [email protected] DEDEAT (Director of Enforcement) Div De Villiers [email protected] DEDEAT Rob Stegman [email protected] DEDEAT Given Ndabambi [email protected] DEDEAT: Coastal Zone Management Ricky Hannan [email protected] DEDEAT: Coastal Zone Management Loyiso Nondlebe [email protected] DEDEAT: Coastal Zone Management Leight-Anne Kretzman [email protected] DEA Biodiversity Conservation Unit (BCU) Portia Makitla [email protected] DEA Biodiversity Conservation Unit (BCU) Thobekile Zungu [email protected] DEA EIA: Coordination, Strategic Planning Azrah Essop [email protected] and Support DEFF: Oceans and Coast Daisy Kotsedi [email protected] DEFF: Oceans and Coast Qaphela Mpotulo [email protected] DEFF: Oceans and Coast Heinrich Muller [email protected] DEFF: Oceans and Coast Nicolette Vink [email protected] DEFF: Oceans and Coast Siyabonga Dlulisa [email protected] DEFF: Oceans and Coast Gcobani Popose [email protected] DEFF: Oceans and Coast Tandiwe Njajula [email protected] DEFF: Oceans and Coast Rueben Molale [email protected] DEFF: Oceans and Coast Lauren Williams [email protected] DEFF: Oceans and Coast Alan Boyd [email protected] DEFF: Oceans and Coast Jabulile Nhleko [email protected] DEFF: Oceans and Coast Liwalam Madikiza [email protected] DEFF: Oceans and Coast: Coastal Pollution N. Baijnath-Pillay [email protected] Management DEFF: Oceans and Coast: Coastal Pollution Mr M. Tshikotshi [email protected] Management

CES Environmental and Social Advisory Services Wild Coast Abalone Facility Expansion 150

Organisation/association Name/contact person Email South African Environment Observation Angelique Brooksbank [email protected] Network (SAEON) DAFF: Fisheries: Operation Phakisa KeaganH Halley [email protected] Aquaculture Delivery Unit DAFF: Fisheries: Operation Phakisa Andrea Bernatzeder [email protected] Aquaculture Delivery Unit DAFF: Forestry Dorothy Jagers [email protected] DAFF: Forestry Mxolisi Dan Malgas [email protected] DAFF: Forestry (Permitting and inspection) Thobani Vetsheza [email protected] DAFF: Forestry J. Vuyusani [email protected] DAFF: Forestry Nomalwande Mbananga [email protected] DRPW Danie Pretorius [email protected] DRDLR Ms Thabile [email protected] Mehlomakhulu DRDLR: Amathole (Land Reform) Ms Xoliswa Nyathi [email protected] DRDLR: Manager: Eastern Cape Bahlekile Keikelame [email protected] ECDC Rory Hashick [email protected] WESSA Mike Denison [email protected] Eskom: Eastern Cape Operating Unit Xolani Wana [email protected] Eastern Cape Parks and Tourism Agency Shane Gertze [email protected] (ECPTA) Eastern Cape Parks and Tourism Agency Eleanor Van Den Berg- Eleanor.VanDenBerg- (ECPTA) McGregor [email protected] Eastern Cape Parks and Tourism Agency Dean Peinke [email protected] (ECPTA) Eastern Cape Parks and Tourism Agency Kagiso Mangwale [email protected] (ECPTA) Eastern Cape Parks and Tourism Agency Ayaka Peter [email protected] (ECPTA) Eastern Cape Parks and Tourism Agency Mzwabantu Kostauli [email protected] (ECPTA) Eastern Cape Parks and Tourism Agency Nomatile Nombewu [email protected] (ECPTA) Amathole District Municipality (ADM) Siyabulela M [email protected] Amathole District Municipality: Luyanda Mafumbu [email protected] Environmental Management Great Kei Local Municipality (GKLM) L Plika [email protected] Great Kei Local Municipality (GKLM) Municipal Manager: Mr. [email protected] L.N Mambila Great Kei Local Municipality (GKLM) Municipal Manager PA: N [email protected] Nonkasana GKLM Ward 5 Councillor Cllr Khantshashe [email protected] NKhantshashe- [email protected] GKLM Mayor Mr N Tekile [email protected] Resident, GKM ward 5 Councillor Committee Dianne Williams [email protected] Member, Haga Haga Ratepayers Association, Haga Haga Conservancy

CES Environmental and Social Advisory Services Wild Coast Abalone Facility Expansion 151

Organisation/association Name/contact person Email Kei Mouth Rate Payers Association Mike Haywood [email protected] Kei Mouth and Morgan Bay Tourism Gareth Yearsley [email protected] Haga Haga rate payers M. Brunette [email protected] Haga Haga Hotel N Chemaly [email protected] Oppie Plaas Haga Haga [email protected] Haga Haga Conservancy Connie Oosthuizen [email protected] Haga Haga Conservancy Chairperson Ingrid Preston [email protected] LANDOWNERS & NEIGHBOURING LANDOWNERS Wild Coast Abalone Pty Ltd Richard Clark [email protected] LATRODEX PTY LTD (Farm 459 and 456) Richard Clark Hillandale Trust (Farm 476) Bridgette English [email protected] Amathole District Municipality (Erf 134) Incuded above DAFF (Farm 108) Incuded above ECPTA (Farm 108) Included above IDENTIFIED I&APS Resident, GKM ward 5 Councillor Committee Dianne Williams [email protected] Member, Haga Haga Ratepayers Association, Haga Haga Conservancy Haga Haga Conservancy R. P. Ellis [email protected] Wild Coast Abalone Brendon Malan [email protected] Marshstrand property owner LJ Laidlaw [email protected] Boy Ndlangisa [email protected] Haga Haga Conservancy Sylvia Baines [email protected] Marshstrand resident Dr P & Sheryle Meyer [email protected] Chairman of Fish Bay Home Owners Andrew Hughes [email protected] Association N Hughes [email protected] A Ziemann [email protected] REGISTERED I&APS Resident Darryl Deetlefs [email protected] Resident Kilty & Estelle Williams [email protected] Resident Ingrid Preston [email protected] CDEC Consulting Engineers Peter Sharp [email protected] Fishbay Property Owner Bruce West [email protected] [email protected] Fishbay Property Owner Veronica West [email protected] Marshstrand Resident Donald Keth [email protected] APPLICANT Wild Coast Abalone Pty Ltd Richard Clark [email protected] Wild Coast Abalone Pty Ltd Sanet Smit [email protected]

CES Environmental and Social Advisory Services Wild Coast Abalone Facility Expansion 152

APPENDIX C: ADDITIONAL INFORMATION

APPENDIX C1: MARINE SPECIALIST STUDY (2008)

CES Environmental and Social Advisory Services Wild Coast Abalone Facility Expansion 153

Specialist Report on the Impact on the Marine Environment of the

Expansion of the Wild Coast Abalone Farm

Prepared by:

Enviro-Fish Africa (Pty) Ltd

For:

WILD COAST ABALONE (PTY) LTD

August 2008

PREPARED FOR:

WILD COAST ABALONE (PTY) LTD (Reg. No. 97/21825/07 Vat No. 4570170920)

PO Box 7613 Portion 1 of Farm 259 East London Haga Haga 5200 5272 South Africa South Africa

Tel: + 27 43 8411999 Fax: + 27 43 8411998 Cell: 083 232 9010 Email: [email protected]

PREPARED BY:

Enviro-Fish Africa (Pty) Ltd

22 Somerset Street Grahamstown 6139 South Africa Telephone +27 046 6228241 Fax +27 046 6227950 Email: [email protected] Authors: Peter Britz. Email: [email protected] Brian Godfrey. Email: [email protected] Guy Paulet. Email: [email protected]

Report should be cited as: Britz, P. J., Godfrey, B. P., & Paulet, T. G. 2008. Specialist Report on the Impact on the Marine Environment of the

Expansion of the Wild Coast Abalone Farm. A report for Wild Coast Abalone (Pty) Ltd. produced by Enviro-Fish Africa (Pty.) Ltd. 33p.

Table of Contents

Executive Summary...... 3 1 Introduction...... 6 2 Terms of Reference...... 8 2.1 Physical impacts ...... 8 2.2 Impact of solid organic waste from growth tanks...... 8 2.3 Chemical impacts...... 8 2.4 Microbiology ...... 9 2.5 Mitigation measures...... 9 2.6 Policy...... 9 3 Project Description ...... 9 4 Description of the Marine Environment ...... 11 5 Impacts of the Existing Abalone Farm on the Marine Environment...... 11 5.1 Physical Impacts ...... 11 5.2 Description of the Abalone Farm Effluent Stream ...... 11 5.3 Effluent Nutrient Composition ...... 15 5.3.1 Nutrient Concentration in the marine environment adjacent to the Abalone Farm. 15 5.3.2 Temporal variation of the Nutrient Composition in Abalone Farm Effluent 18 5.3.3 Assessment of the impact of abalone farm effluent on the intertidal biota .20 5.4 Summary and Conclusions of Existing Impacts...... 23 6 Potential Impacts of Abalone Farm Expansion...... 23 6.1 Construction...... 23 6.2 Physical Impacts ...... 23 6.3 Aesthetics ...... 24 6.4 Access and Safety ...... 24 6.5 Biological Impact of Dissolved Nutrients...... 24 6.6 Processing Facility Effects ...... 26 7 Microbiology...... 26 7.1 Threat of Disease to Wild Stock: Abalone...... 26 7.2 Threat of Disease to wild stock: Kob...... 26 7.3 Genetic Threat to the Wild Stock : Kob...... 27 7.4 Potential Increase of Algal Blooms ...... 27 8 Policy Implications...... 27 9 Conclusions...... 28 10 References...... 29 11 Appendix 1...... 30

Executive Summary

The potential impacts on the marine environment of the proposed expansion of the production capacity of the Wild Coast Abalone Farm from the existing 100 tons per annum to 300 tons per annum were assessed. In addition, the potential impacts of extending the abalone farm to include a 200 tons per annum Kob (Argyrosomus japonicus) farm were also assessed.

Wild Coast Abalone (Pty) Ltd. is a well established abalone farm near Haga Haga in the Eastern Cape Province that cultures South African abalone Haliotis midae, known locally as perlemoen. The farm utilizes cultured seaweed and formulated pellets to feed the abalone and will use a formulated diet to feed the Kob. The land-based farm pumps sea water ashore to its abalone hatchery, grow out facility, and seaweed ponds behind the coastal dune thicket, and returns it to the sea over the beach and intertidal rocky shore opposite the farm. The Dusky Kob Argyrosomus japonicus has been identified as a suitable candidate for aquaculture in South Africa and culture of this species is increasing rapidly. Wild Coast Abalone (Pty) Ltd. plans to purchase Kob fingerlings and grow them in ponds at the same site utilising some of the existing infrastructure.

The marine environment adjacent to this development is within the warm temperate zone of southern Africa. It is characterized by an exposed coastline subject to strong wave action and longshore currents. Species diversity is relatively high but production levels are lower than the cold temperate zone found west of Cape Point. None of the species found in this area are endangered and the conservation status of this area is not under threat.

The proposed activity which triggered a full scoping and EIA is the volume of effluent/waste water which will exceed the EIA regulation threshold of 15,000 m3/annum. It is proposed to increase the pumping volume through the farm from the current 1350 m3/h, to a maximum of 6000 m3/h. Possible impacts on the marine environment arising from the increased pumping and discharge volumes that were identified and evaluated were:

• Physical impacts associated with the farm construction phase.

• Aesthetic and public safety impacts of the increased effluent discharge across the beach.

• Increased settlement of particulate organic matter in the intertidal zone resulting in changes in the intertidal community structure and anoxic sediments.

• Increased discharge of dissolved nutrients resulting in excessive algal growth in the intertidal area adjoining the farm.

• The implications that increased stock levels may have for increased risk of disease and its effect on the marine environment.

In addition, the proposed expansion activities were evaluated for consistency with South African Policy and MCM requirements for marine aquaculture.

The significance of the impacts and suggested mitigation measures are summarised as follows:

• Physical Impacts associated with the Construction Phase. The construction activities associated with the expansion of the farm are land based and limited to within the farm property. No construction activity will take place within beach, inter-tidal zone

or marine environments. The impact is thus of LOW Significance and no mitigation measures are recommended.

• Aesthetics. The increased effluent stream across the pristine beach is an anomaly, but one which has the appearance of a natural stream. The effluent has a mild odour, particularly during tank cleaning, but one which is not offensive. The impact is thus of LOW Significance and no mitigation measures are recommended.

• Public safety. The increased volume of water flowing across the beach may pose a safety hazard to the public. The existing stepping stones and wooden footbridge are deemed appropriate mitigation measures. In addition, appropriate signage warning of the potential hazard is recommended. The impact is of LOW significance.

• Particulate Organic Matter. Increased production of particulate organic matter (POM) will result from the increased production of abalone and Kob faeces as well as from wasted feed. This is likely to result in increased settlement of POM in the intertidal area leading to a reduction of inter-tidal species diversity immediately below the effluent outfall. Observations on the existing farm effluent indicate that this impact is likely to be highly localized as the inter-tidal zone is subject to strong wave action and twice-daily tidal inundation, resulting in rapid mixing and dispersal of particulate organic matter. This risk is therefore considered of LOW significance. The seaweed ponds will result in partial settlement of POM, and no further mitigatory measures are recommended.

• Dissolved Nutrients. The increased production of abalone and additional production of Kob will result in a greater discharge of dissolved nitrogenous nutrients (ammonia, nitrite and nitrate) as well as phosphate. This is expected to promote excessive growth of green filamentous algae in the effluent stream over the inter-tidal zone, resulting in reduced species diversity immediately below the effluent outfall. Observations of the existing farm effluent indicate that this impact is likely to be highly localized. This is because the inter-tidal zone is subject to strong wave action and twice-daily tidal inundation, resulting in rapid mixing and dispersal of particulate organic matter. This risk is therefore considered of LOW significance. The seaweed ponds will result in partial absorption of the nitrogenous wastes and phosphates, and no further mitigatory measures are recommended.

• Disease risk: Abalone. The existing concentration of intensively farmed abalone may act as a vector for the spread of disease to the natural abalone population. The proposed increase in farm production from 100 to 300 tons possibly increases this risk. The farm already participates in an abalone industry health management programme which is deemed a sufficient mitigatory measure to minimize the risk of disease transfer to the natural abalone population. The significance of risk of the expanded farm operation spreading disease to the wild abalone population is thus categorized as LOW.

• Disease risk: Kob. The intensive farming of Kob may also act as a vector for the spread of disease to the natural kob population. To minimise this risk it is recommended that the proposed kob farm adopt an on-farm biosecurity protocol and health management programme. The significance of risk of farmed Kob infecting the wild population with disease is thus categorised as LOW.

• Genetic contamination. Wild Coast Abalone will maintain kob broodstock on the farm but will obtain fingerlings from Espadon Marine’s facility in the East London IDZ. Wild Coast abalone is situated within the same geographic zone as Espadon as described in MCM’s draft policy on finfish broodstock management. Obtaining fingerlings from the same geographical area as outlined in the MCM draft policy is deemed a mitigatory measure thereby minimising the risk of genetic contamination of the wild stock. In addition, Land-based rearing of Kob allows for strict control over escapees which in itself is a mitigatory control. The risk of farmed Kob polluting genetics in the wild population is considered LOW as a result.

Wild Coast Abalone (Pty) Ltd’s proposal to increase its abalone production and to initiate Kob production is consistent with South African policy on water use and marine aquaculture.

Overall, the proposed expansion of the Wild Coast Abalone Farm’s production from 100 to 300 tons of abalone and 200 tons Kob poses no significant risk to the marine environment provided the existing and proposed mitigatory measures are adhered to.

Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______

1 Introduction

Wild Coast Abalone (Pty) Ltd is in the process of applying for authorisation to expand the current abalone production from 100 tons/annum to 300 tons/annum. They are also applying for authorisation to develop a 200 tons/annum Kob farm at the site. In addition to the expansion of the abalone grow out tanks, seaweed ponds, Kob grow- out tanks, a processing facility and a number of housing units are proposed. The activity which triggers a full scoping and EIA is the volume of effluent/waste water discharge. This is expected to significantly exceed the EIA regulation threshold of 15,000m3/annum. The current specialist study addresses the potential impacts on the marine environment, and is part of a comprehensive EIA undertaken by Coastal and Environmental Services.

The farm site is approximately 45km northeast of East London and adjoins the small settlement of Marsh Strand which is largely used by holiday makers. The farm was established in the mid-nineties and utilises pumped sea water to supply its hatchery and growout tanks (Figure 1). Abalone on the farm are fed a combination of pelleted feed and cultured seaweed (Ulva and Gracilaria spp.) which is cultured in the farm effluent water (Figure 2). This serves to reduce the nutrient discharge to the sea. The cultured seaweed supplies approximately 70% of the farm’s feed requirements.

Figure 1 Growout tanks with baskets containing abalone supplied with pumped sea water.

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Enviro-Fish Africa (Pty) Ltd 6 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______

Figure 2 Seaweed culture ponds at Wild Coast Abalone situated below the growout tank section.

The development of the farm has been planned in six phases. Having achieved the objectives of phases 1 and 2, which were covered by the original environmental impact assessment, Wild Coast Abalone now plans to expand through phases 4-6 to a total production of 300 tons. This development trajectory is typical of successful abalone farms in South Africa.

The abalone farming sector is South Africa’s most successful aquaculture industry with national farmed abalone production of the order of 850 tons in 2007. The larger farms now produce between 100 and 200 tons, with most having plans to expand production. This growth is being driven by firm market demand from Asia and the expected decline in wild abalone supply as poaching decimates wild stocks. A further boost to abalone farming was the recent draft policy on abalone ranching released by Department of Environmental Affairs and Tourism, which proposes to rehabilitate poached areas by means of the release of hatchery reared abalone to the wild.

In terms of impacts on the marine environment, abalone farming is generally regarded as a fairly “clean” and well managed industry, and has not attracted any adverse publicity. The main impacts relate to the pumping and discharge infrastructure, and the organic nutrient content of the farm effluent. Other aspects with potential environmental impacts that require ongoing management are abalone farm genetics and disease.

Abalone farms are being used as a platform to develop new technologies for culturing indigenous species such as Kob (Argyrosomus species), seaweeds, scallops and baitworms. Wild Coast Abalone’s plans to install a processing facility in addition to Kob aquaculture are thus in line with industry trends to add value to the current production operations. The diversification of the number of indigenous species cultured in South Africa is also a policy objective of South Africa’s Marine Aquaculture Policy (DEAT, 2008). The South African mariculture industry is developing production technology for indigenous finfish species such as the Dusky Kob (A. japonicus), which has high quality flesh and good market demand. The rearing of fish on high protein diets and

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Enviro-Fish Africa (Pty) Ltd 7 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______the mobility of fish intensifies the risks of pollution and biological interaction with wild stocks. However, the draft guidelines for finfish farming in South Africa provide a management tool with which to mitigate these potential problems. Land-based aquaculture provides considerable scope to eliminate many of the environmentally degrading effects of intensive culture. As such, seawater from West Coast Abalone farm is passed through seaweed ponds which remove much of the nitrogenous waste from the water before returning it to the sea. Land-based aquaculture also provides the opportunity of control over contact between wild and cultured individuals thus reducing the risks of disease and genetic interaction.

Procedures for the environmental management of abalone farms are fairly well established, both in terms of existing EIA legislation and through the responsible government agency Marine and Coastal Management (Department of Environmental Affairs and Tourism) which actively manages the sector by means of various protocols and permit conditions. Draft guidelines for finfish farming and genetic best management guidelines for finfish hatcheries have been introduced by DEAT (Department of Environmental Affairs and Tourism) and the Biodiversity Act, together with the Genetically Modified Organisms Act (Act No. 15 of 1997) makes provision for control over the release of transgenics. This allows for the orderly development of the aquaculture sector so that socio-economic benefit is created in a sustainable manner.

The terms of reference for the specialist study on the abalone farm impacts on the marine environment were drafted by Coastal and Environment Services (Pty) Ltd., the company responsible for the overall EIA for the proposed expansion, in consultation with Enviro-Fish Africa (Pty) Ltd.

2 Terms of Reference

The items below need to be addressed, sampled, processed, analysed and assessed in relation to the relevant Water Quality Standards in South Africa. The objective of the specialist report is to determine:

2.1 Physical impacts • With particular reference to the marine environment around the outlet.

2.2 Impact of solid organic waste from growth tanks • Determine current organic composition in all identified waste/effluent streams (outlets) and compare with inlet water.

• Determine estimated organic waste production resulting from the expansion and the capability of the additional seaweed ponds to adequately treat the increased waste production.

• Determine estimated solid waste produced by the processing facility (found in waste water).

2.3 Chemical impacts • Determine chemical content (nitrogen and phosphorus) of current outlets of waste water/effluent streams, which can be elevated by excrement and feed.

• Determine estimated effect of the expansion of the growth tanks on waste water characteristics.

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Enviro-Fish Africa (Pty) Ltd 8 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______

• Determine the possible effect of the processing facility on water chemical composition.

2.4 Microbiology • Determine the potential risk of disease to spread to wild stock (e.g. Vibrio spp. contamination at the outlet).

• Assess the potential risk of increased nutrient levels that may lead to algal blooms etc., as a result of, a) growth tank expansion, b) the processing facility.

2.5 Mitigation measures • Impacts resulting from the various activities in terms of waste and effluent should be assessed. The report should also contain mitigation measures that could be used to minimise any negative effects/impacts on the environment.

2.6 Policy • Evaluate the consistency of the activities with South African Policy and MCM requirements relating to marine aquaculture in South Africa and suggested steps that will ensure compliance with regulations.

• Provide guidance on MCM policy requirements with respect to waste water/effluent discharge.

3 Project Description

Wild Coast Abalone (Pty.) Ltd. development plan follows a 6 phase series, of which they have completed phases 1 and 2 (Table 1). The farm currently pumps 1350m3/hr of seawater to sustain a total biomass of 108t of abalone. The abalone are fed on 36t of artificial pellets and 600t of seaweed per annum (which is grown on site). The farm plans to increase their production of abalone from the current 100t per annum to a maximum of 300t/yr, in phases 4-6 (150t/yr for the 3rd phase). In addition, they have plans for the culture of Dusky Kob and plan to produce up to 200t/yr of this species in phases 4-6. The present specialist study evaluates the impacts of expansion of the abalone production, building of the Kob grow-out facilities, and the associated processing plant, on the marine environment.

This increase in abalone production will require an increase in the amount of food used (Table 1) and hence an increase in the amount of waste produced by the farm. Faecal matter which accumulates in the tanks is flushed into the outfall water during weekly tank cleaning. Metabolic wastes, containing nitrogenous compounds and phosphates, will also increase in proportion to the increase of abalone biomass on the farm. A significant portion of these organic waste nutrients will be absorbed by the expanded seaweed culture ponds which provide food for the abalone. Due to the nature of finfish (Kob) aquaculture, the level of waste products will be further increased and flushed from the farm via the effluent water. The increased levels of nitrogenous waste will largely be absorbed by the expanded seaweed culture ponds.

A processing facility is also under construction which will have the capacity to can or dry 20 tons of abalone per month. This facility is expected to produce up to 6000l of waste seawater per day which will be added to the rest of the farm’s seawater effluent. Apart from slime produced by the abalone during processing, all solids generated during processing will be excluded from the effluent water.

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Enviro-Fish Africa (Pty) Ltd 9

Table 1 Basic information relevant to the expansion of Wild Coast Abalone (Pty) Ltd. (Reproduced with permission of R. Clarke – WCA)

Original EIA Current Current Future Notes: Infrastructure Development Development Phase 1 Phase 2 Phase 1 and 2 Phase 3 Phase 4 to 6 EXISTING ACTIVITIES Species Abalone Abalone (Haliotis Abalone (Haliotis Abalone Abalone WCA currently farm with (Haliotis midae), midae), Pacific midae), Sea (Haliotis midae), (Haliotis abalone and seaweeds and Pacific Oyster Oyster spaghetti Sea spaghetti midae), Sea plan to do some Dusky Kob. (crassostrea (crassostrea (Gracilaria (Gracilaria spaghetti pacificus), Sea pacificus), Sea verrucosa), Sea verrucosa), Sea (Gracilaria spaghetti spaghetti Lettuce (Ulva Lettuce (Ulva verrucosa), (Gracilaria (Gracilaria spp.), Dusky spp.), Dusky Sea Lettuce verrucosa) verrucosa) Kob Kob (Ulva spp.), (Argyrosomus (Argyrosomus Dusky Kob japonicus) japonicus) (Argyrosomus japonicus) Production

Abalone 50 t pa 100 t pa 100 t pa 150 t pa 300 t pa This is the calculated maximum capacity of the site for Abalone. Dusky 200 t pa This is the calculated Kob maximum capacity of the site for Dusky Kob. Abalone biomass on the farm Not specified Not specified 108 t 189 t 378 t Ave 13.5 kg per basket.

Seawater 600 m cu / hr 1200 m cu / hr 1350 m cu / hr 3000 m cu / hr 6000 m cu / hr Feedusage supply Abalone Grown Grown seaweed, Grown seaweed Grown seaweed Grown Feed conversion of 1:11 wet seaweed, 400t 800t pa - 600t pa, - 920t pa, seaweed - feed and 1:1.5 on dry. pa Artificial pellets - Artificial pellets - 1800t pa, 36 t pa 45 t pa Artificial pellets - 90 t pa Dusky Artificial Feed conversion of 1:1.1 on Kob Pellets - 220 t dry. pa

Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______

4 Description of the Marine Environment

The marine environment that exists in this area is part of the warm temperate region (South Coast) of southern Africa that extends from approximately Port St. Johns in the north to Cape Point in the south (Branch & Branch 1981). Although the Agulhas current runs along this section of coast its influence is not generally felt directly since the continental shelf tends to move offshore as one goes progressively southwards. As a result cooler coastal water usually occurs in this region. The east coast of southern Africa is characterized by high species diversity but lower overall production than the west coast owing primarily to differences in nutrient availability. The South African abalone or “perlemoen” Haliotis midae occurs naturally off the farm site in the shallow sub-tidal zone. H. midae’s natural distribution extends from the Mbashe River in Transkei to St Helena Bay on the West coast. The Dusky Kob, Argyrosomus japonicus, occurs along the eastern seaboard of southern Africa, to India and Pakistan and the south coast of Australia. Its South African range extends from Cape Point eastwards into Mozambique.

5 Impacts of the Existing Abalone Farm on the Marine Environment

As the existing abalone farm is fully operational, the existing physical impacts and biological impacts associated with the effluent stream provided an opportunity to gather quantitative baseline data which could be used to project what the impacts of the expanded farm would be.

5.1 Physical Impacts The existing physical impacts of the farm on the marine environment include: • A buried influent pipe which leads water from the sub-tidal zone to a sump and pump house (Figure 3) within the abalone farm boundary. • The discharge of 1350m3/h of abalone farm effluent across the beach and rocky intertidal area (Figure 4). • The installation of 1) stepping stones across the effluent stream on the beach and 2) a foot bridge at the top of the beach, just above the high water mark (Figure 5 a&b).

5.2 Description of the Abalone Farm Effluent Stream At present, the effluent stream leaves the farm site on the landward side of the primary dune, which is in a stable state (covered by dune vegetation). The effluent stream cuts a path approximately 5m wide through the dune for about 15m. It then flows under a footbridge constructed by the farm to facilitate the crossing of the outfall stream and flows across the sandy beach for a distance of about 60m (Figure 4, Figure 6). The beach is usually not covered by seawater except during spring high tide and rough sea conditions. The maximum width of the stream in this area is approximately 15m and apart from a 3m wide channel in the middle (which is no more than 30cm deep); the rest is mostly less than 15cm deep. The flow speed is fastest in the deepest part and was measured at 1.4m/sec. The flow has scoured away most of the sand in the stream leaving only coarse gravel and rocks. The stream then reaches the rocky intertidal zone which is approximately 50m wide at low tide. This zone consists of a series of low rocky terraces which, in the main, creates four wide low rock pools lying abreast and parallel to the coast. During low tide, the outfall water therefore spreads laterally while at the same time cascading down into the sea. To the west, lateral spread of the outfall water is restricted to within 50m by a low rocky ridge extending towards the sea. On the eastern side a low rocky ridge about 400m away also prevents the water from spreading further. At high tide the intertidal area is progressively covered to different levels depending on the height of the tide.

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Enviro-Fish Africa (Pty) Ltd 11 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______

Figure 3 Pump-house sump within the abalone farm boundary behind the coastal dune thicket. The existing pipeline and sump are large enough to accommodate the pumping capacity of the proposed abalone farm expansion.

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Enviro-Fish Africa (Pty) Ltd 12 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______

Figure 4 The existing effluent stream across the beach and rocky inter-tidal zone below the abalone farm.

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Enviro-Fish Africa (Pty) Ltd 13 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______

Figure 5a&b Stepping stones and foot bridge to accommodate public crossing of the abalone farm effluent stream over the beach.

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Enviro-Fish Africa (Pty) Ltd 14 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______

5.3 Effluent Nutrient Composition To assess the present organic and chemical composition of the farm’s water supply and effluent, samples were taken from various points within and outside the farm. Parameters that were measured were: Turbidity, Total Suspended Solids (TSS), Ammonia, Nitrate, Nitrite and Phosphate. All water samples were analysed by Pollution Control Technologies in East London.

5.3.1 Nutrient Concentration in the marine environment adjacent to the Abalone Farm. The first set of samples was taken on the 16th May 2008, and attempted to trace the effluent as it left the farm and to quantify the dilution that occurred as it flowed through the inter-tidal zone where it entered the marine environment (Figure 5a). At low tide, the outfall water, 3 rockpools below the outfall stream and water at the spring low tide mark was sampled. As the tide rose, samples were again taken in the three rock pools, as well as in the surf zone and beyond the first line of breakers (Figure 6). Results are displayed in Figures 7 and 8.

Figure 6 Aerial image of the abalone farm’s outfall stream where it enters the marine environment, showing points sampled for nutrients.

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Enviro-Fish Africa (Pty) Ltd 15 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______

Figure 7 Nutrient concentrations for ammonia, nitrate and nitrite in the abalone farm effluent stream and in the adjacent marine environment.

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Enviro-Fish Africa (Pty) Ltd 16 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______

Figure 8 Nutrient concentrations for turbidity, total suspended solids and total organic carbon in the abalone farm effluent stream and in the adjacent marine environment.

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Enviro-Fish Africa (Pty) Ltd 17 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______

The levels of nitrogenous nutrients (ammonia, nitrite and nitrate) declined as the effluent flowing from the abalone farm was diluted into the marine environment. On the day of sampling, Turbidity and Total Suspended Solids (TSS) increased slightly with distance from the abalone farm indicating that the abalone farm effluent was less turbid than the prevailing sea water condition. There was no clear trend in total organic carbon levels, indicating that the farm was not discharging a level higher than those that were found in the marine environment. The levels of phosphate were negligible both in the farm effluent and in the marine environment, suggesting that phosphate was the limiting nutrient in the algal culture ponds on the abalone farm. The addition of phosphate to the algal ponds could thus increase the efficiency of the stripping of nitrogenous compounds from the farm effluent by the cultured seaweed.

5.3.2 Temporal variation of the Nutrient Composition in Abalone Farm Effluent Water samples were taken from the abalone farm inflow, algal ponds (inflow and outflow), and farm outfall over a period of 5 days (9-13th June 2008) at 09h00, and used to determine the variation in the organic nutrient composition. The results are presented in Table 2 along with natural measurements from South African waters.

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Table 2 Nutrient concentrations (mean ± standard deviation) and range (in parentheses) in abalone farm influent and effluent water over a five day period compared with measured values in South African Waters (DWAF 1995) (Standard Deviation in Brackets).

Turbidity (NTU) Total Free & Saline Nitrate Nitrite Phosphate TOC Suspended Ammonia (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) Solids (mg/l) Incoming 2.8 ±0.8 101± 26 0.01 ±0.00 0.05± 0.03 0.01± 0.01 0.01±0.00 6.9±0.8 Water (2.0-3.9) (74-137) (0.01-0.01) (0.01-0.07) (0.01-0.03) (0.01-0.01) (6.2-8.1) Effluent 4.3± 2.0 111± 40 0.10± 0.06 0.21± 0.15 0.03 ±0.01 0.01±0.00 7.2±1.3 Water (3.2-7.8) (59-163) (0.02-0.18) (0.01-0.36) (0.01-0.04) (0.01-0.01) (5.3-8.5) Algal Pond 1.1± 0.2 123± 83 0.03± 0.02 0.06± 0.05 0.04 ±0.02 0.01±0.00 7.4±0.9 Inlet (0.8-1.4) (62-268) (0.01-0.05) (0.01-0.13) (0.02-0.05) (0.01-0.01) (6.2-8.4) Algal Pond 2.2± 1.8 201± 114 0.21± 0.35 1.42± 3.01 0.03 ±0.02 0.01±0.00 7.9±1.8 Outlet (1.1-5.3) (72-377) (0.01-0.81) (0.01-6.80) (0.01-0.05) (0.01-0.01) (5.9-9.9) Measured .0164 (but <0.07 but may Values – up to 0.28 - - be much higher 0.042 West Coast during during upwelling upwelling) Measured Values – - - <0.07 0.081 0.028 South Coast Measured Values – - - <0.07 0.047 - Durban

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A slight elevation in turbidity, total suspended solids and total organic carbon was observed in the abalone farm effluent water over the five day period. Nitrogenous compounds (ammonia, nitrite and nitrate) were significantly higher in the effluent water. A comparison of the means for nitrogenous compounds with those for South African coastal waters indicates that their concentration in the farm effluent water was similar to levels recorded during upwelling conditions on the West Coast.

The results from the algal ponds were inconclusive and seemed to indicate no stripping of nutrients from the effluent water at the time of sampling. The sampling period was short however and a longer study would be required to assess the stripping efficacy of the algal ponds. Quantitative research has however demonstrated the efficiency of seaweed ponds in stripping nutrients from abalone farm effluent. Robertson-Anderson (2003) demonstrated that ponds of Ulva lactusa stripped 50-100% of nitrogenous compounds and phosphate from abalone farm effluent.

At present there are no Target Water Quality guidelines for effluent water originating from mariculture facilities in South Africa. However, target Water Quality Ranges exist for coastal marine waters for water to be used for Mariculture (DWAF 1995). By using these as a baseline for comparison, it is possible to assess the potential impact of the substances in question (Table 3).

Table 3 Water quality targets for coastal marine waters for Mariculture use (DWAF 1995).

Parameters Marine Coastal - Mariculture Total Suspended Solids <10% increase over ambient Ammonia Waters should not contain concentrations Nitrate of dissolved nutrients that are capable of Nitrite causing excessive or nuisance growth of algae or other aquatic plants or reducing dissolved oxygen concentrations below the target range indicated for dissolved oxygen.

5.3.3 Assessment of the impact of abalone farm effluent on the intertidal biota In order to assess the impact of the farm effluent on the inter-tidal biota, a visual assessment and photographic recording was undertaken from the effluent outfall down to the low water mark, and along the shore for a distance of 400m.

During periods of tank washing, which we witnessed, the effluent water becomes noticeably more turbid but this rapidly diminished once tank cleaning was completed. The turbidity is caused by particulate organic matter (POM) comprised largely of abalone faeces and uneaten food (algae and pelleted food).

At the outfall point, where the effluent stream begins to disperse over the intertidal area, we observed localised blanketing of the intertidal biota with POM. In the rock pools immediately below the outfall we observed a few localized pockets (<2m2 in total and <15cm deep) where the accumulated POM layer was anoxic (Figure 9). Beyond the first few metres from the effluent dispersion point, we observed only a light dusting of POM on the rocks and marine biota (Figure 10). This effect diminished rapidly as flow moved towards the sea and also laterally in

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Enviro-Fish Africa (Pty) Ltd 20 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______the rock pools. Settled POM was not detectable >350m from the effluent outfall (Figure 11). As the entire area is subjected to tidal inundation twice a day, and is often subject to rough surf and strong currents, most of the POM is flushed away with each tidal cycle.

Figure 9 Pocket of accumulated POM with anoxic decomposition occurring.

Figure 10 Light dusting of particulate organic matter on rocks and seaweed.

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Figure 11 Photograph of intertidal area just beyond the influence of the effluent stream.

Inspection of the biota revealed some obvious effects in the immediate vicinity of the effluent outfall but these effects were rapidly attenuated across and along the intertidal zone. At the effluent outfall point where POM blanketing was heaviest, species diversity and abundance was noticeably lower in comparison to equivalent points along the shore. Moving from the effluent outfall down the shore (0-20m) two species of green algae (Ulva sp. and possibly Chaetomorpha sp.) were prominent in the area where the effluent stream was strongest and the numbers of invertebrates (mainly gastropods) were lower. Algal mats consisting of a mixture of upright coralline algae were also abundant. These effects gradually attenuated towards the lower intertidal zone (approximately 40m from the outfall point), and the community of biota was noticeably more “natural”. The abundance of algae owing to nutrient enrichment from the effluent water was still apparent, but signs of excessive growth which could lead to eutrophication were not apparent. A visual investigation of the subtidal community directly below the effluent stream displayed a seemingly normal marine community. In the upper intertidal zone, when moving along the shore away from the effluent stream, a similar effect was evident.

None of the invertebrate species that were observed are endangered. Juvenile fish such as mullet also appear to be attracted by the effluent water into the rock pools below the effluent stream and probably feed on detritus which is washed out of the farm. Abalone faeces, algal particles and uneaten artificial (pelleted) food will all contribute to these solids.

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5.4 Summary and Conclusions of Existing Impacts The existing abalone farm and its effluent stream have had the following impacts on the marine environment: • Physical impacts: A buried inflow pipeline has been laid from the sub- tidal zone, across the rocky intertidal zone, and through the dune thicket to a sump within the abalone farm property. The effluent stream of 1350m3/h flows across the beach and disperses over the rocky intertidal zone. A footbridge and stepping stones have been installed to facilitate the pedestrian crossing of the effluent stream. • Effluent characteristics: The effluent stream contains elevated levels of particulate organic matter (POM) and nitrogenous compounds (ammonia, nitrate and nitrite). The nutrients in the effluent were rapidly diluted across the inter-tidal zone, and elevated nutrient levels were not detectable in the high energy surf zone below the effluent outfall. • Effects on marine biota: Localised settlement of POM at the effluent outfall causes blanketing of the biota and a few pockets of anoxic sediment. This causes a reduction in species diversity. These effects attenuate noticeably within 10m and the POM is flushed regularly with tidal cycle and high sea conditions. Moving away from the effluent outfall towards the lower inter-tidal area (40m distance), excess growth of green algae corresponding with elevated nutrient levels was observed in the effluent stream. This effect gradually attenuated down the shore, with a corresponding rise in species diversity and a more “natural” community structure. There was no noticeable difference in the sub-tidal community below the effluent outfall compared to equivalent points along the shore.

The impact of the abalone farm effluent on the marine environment was thus highly localised and restricted to the intertidal zone immediately below the effluent outfall. The high energy surf zone opposite the effluent outfall rapidly disperses and mixes the effluent and no effects were visible on the sub-tidal environment.

6 Potential Impacts of Abalone Farm Expansion

6.1 Construction Cause/Comment: No construction activities will be required that will have a direct impact on the marine environment. The seawater intake infrastructure that exists for the current operations will suffice for the planned expansion of the farm. No additional structures will be required to accommodate the increased effluent flow over the beach. The existing footbridge and stepping stones will suffice to accommodate pedestrian traffic over the effluent stream. Mitigation: No mitigation is necessary. Significance Statement: These effects are of a LOW significance.

6.2 Physical Impacts Cause/Comment: The intake pipeline and the outfall stream are the only parts of the farm that have a direct physical impact on the marine environment. The intake pipeline will remain unaltered as it can accommodate the increased volume of water pumped on to the farm. The physical effects of increasing the pumping volume from 1350m3 to a potential 6000m3 need to be considered. For example, will the stream erode a channel through the beach?

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Mitigation: Monitor the physical effects of the increased water flow over the beach. If erosion becomes problematic, remedial steps may be required. Significance Statement: This effect is of LOW significance.

6.3 Aesthetics Cause/Comment: Visually, the effluent stream presents an anomaly along the otherwise pristine beach. The effluent steam is not canalised or piped, and it thus has the appearance of a natural steam, and thus is aesthetically acceptable. The increased flow rate will however heighten the visual effect of the effluent stream across the beach.

The effluent water has a mild odour, which is evident during periods of tank washing. The odour is not offensive, and disperses quickly. Increased abalone production with a concomitant increase in effluent discharge volume may increase the distance of detection, and duration of this odour. Mitigation: No mitigation is necessary. Significance Statement: This effect is of LOW significance.

6.4 Access and Safety Cause/Comment: Walkers along the beach have their direct path obstructed by the effluent stream. A foot bridge and stepping stones are provided for pedestrian to cross the stream. In addition, at low tide it is possible to cross the stream on the intertidal rocks.

The increased stream flow does have potential implications for the public as the farm increases its pumping capacity (and seawater output). The stream will increase in width (probably by up to 10m) and may also scour a deeper channel. The speed of the flow is also likely to increase. While unlikely to cause a problem, it is possible that someone may attempt to cross the stream in the high velocity flow or swim in it. Children may choose to jump off the footbridge. It is possible that such actions may lead to difficulties, and at high tide the stream could sweep someone into the sea. The potential danger is however extremely localized. Mitigation: Appropriate signage (English, Xhosa and Graphic), warning people of the potential dangers and directing them to the footbridge needs to be erected or upgraded. Significance Statement: This effect is of LOW significance.

6.5 Biological Impact of Dissolved Nutrients The concentration of total nitrogen and phosphorus present in effluent water is calculated from the input of these nutrients via the diet. Total dietary nitrogen (N) is calculated by dividing the percentage protein by 6.25 according to the Kjeldahl method. This gives a value percent N in the diet. (If the percentage protein was calculated using the Kjeldahl method originally). The percentage nitrogen in effluent is approximately 70% of dietary N. The N content of seaweed is approximately 23g /KG and the percentage protein in abalone diet is 35% (equivalent to 56g /KG). The mass of each fed to abalone is known and the totals can be calculated and presented in Table 4. The same can be done for Kob diets in order to calculate the amount of N released into the effluent water.

63% of ingested phosphorus (P) is excreted into the effluent water. The amount of dietary P in abalone diet is 12.5g /KG (Sales 2004) and around 8g /KG for many fish species (Barlow et al. 2003). Since the mass of feed required is known and the percentage excreted P is approximately 63% of the ingested P, it is

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Enviro-Fish Africa (Pty) Ltd 24 Specialist Report on the Impact of the Expansion of the Wild Coast Abalone Farm on the Marine Environment ______possible to calculate the expected amount of P in the effluent. The percentage of total nitrogen and phosphorus excreted by abalone and Kob is known and Table 4 presents the worst-case scenarios for effluent water. The concentration of these substances in the farm effluent will remain unchanged due to the increased flow rate. As the rate of seaweed growth in the culture ponds appeared to be phosphate limited, the efficiency of stripping the nitrogenous nutrients in the farm effluent could possibly be enhanced by the addition of phosphate to the algal ponds.

The biological impacts of the abalone farm effluent in the inter-tidal zone, described for the existing effluent flow in Section 5 above, are likely to be intensified in the intertidal zone. However, in the high energy, highly mixed surf zone, the increased input of particulate organic matter and dissolved nutrients is unlikely to have a noticeable effect - due to rapid dispersal and dilution.

The footprint of settled particulate organic matter around the effluent outfall at the top of the inter-tidal zone is likely to expand. There are likely to be more pockets of hypoxic or anoxic sediment in areas of low flow at the top of the rocky shore, and an associated greater area of lower inter-tidal species diversity. The increased water flow rate may however keep a bigger percentage of the particulate organic matter in suspension and disperse it into the surf zone where it will be rapidly dispersed.

Table 4 Calculated weight in tons of total nitrogen and phosphate discharged from the farm at present and at full production capacity. Removal of nitrogen and phosphate using seaweed ponds is considered mitigatory at the most conservative estimate of 50% removal.

Parameter Discharge Discharge Discharge Total Total discharge tons/ tons/ tons/ discharge tons/ annum at annum for annum for annum for tons/ annum full capacity – existing proposed 200t Kob at full 50% mitigation farm 100t 300t production production abalone abalone capacity – no production production mitigation Total nitrogen 11.07 30.43 11.09 41.52 20.76 Phosphate 0.93 2.65 1.20 3.85 1.92

The greater discharge volume of dissolved nitrogenous nutrients, which is likely to disperse over a wider area in the inter-tidal zone, will increase the area over which excessive growth of green algae occurs. However, due to massive mixing and water movement in the surf zone, these effects are unlikely to occur in the sub-tidal zone.

Cause/Comment: The impacts of the operation of the farm on marine and shore life are extremely localized and are likely to remain so even when the farm reaches full production. The effluent water is naturally confined to a small section of coastline (~400m x 50m) and the moderate effects that were observed were confined to this area and within the intertidal area. Once the effluent water reaches the actual water level of the sea it is rapidly diluted and no longer becomes a significant factor. Further significant changes to the marine community in the vicinity of the outfall are unlikely. Mitigation: No mitigation is required Significance Statement: These impacts will be localized. They will have a LOW significance.

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6.6 Processing Facility Effects Cause/Comment: The processing facility has been designed to minimize the amount of solid organic waste that is released into the farm’s effluent water. All solid abalone flesh will either be processed for selling or disposed of at approved landfill sites. The processing of the abalone will result in 6000l of wash water and used brine to be introduced into the effluent stream at a dilution of 1:18,000. This water will also contain up to 49kg of abalone slime per day, which is produced by the abalone during handling. This effluent will be combined with the abalone farm’s effluent stream and discharged to sea. Given the very high dilution in the waste water there should be no significant effects on the marine environment.

At present, there are no development plans with respect to the processing of fish on the farm. If fish processing occurs in the future, it is presumed that similar steps to the abalone processing will be taken to prevent the introduction of solid waste into the seawater effluent. Mitigation: Since the processing facilities’ design makes provision for the collection and disposal of any abalone trimmings in a landfill site, it is suggested that the wash water is screened for any large organic particles that may enter the effluent water. Significance Statement: The significance of the processing facility within the overall context of the farm and its total effluent output is LOW.

7 Microbiology

7.1 Threat of Disease to Wild Stock: Abalone Cause/Comment: A veterinary opinion on the threat of disease to wild abalone by abalone health specialist Dr Anna Mouton is provided in Appendix 1. Dr Mouton concludes that farmed abalone may pose a disease risk to wild stocks, but that risk can effectively be mitigated by active health monitoring and management on the farm. Wild Coast Abalone already participates in the abalone culture industry’s abalone health management programme. Mitigation: Continue to participate in the existing abalone health management programme. Significance Statement: The high density culture of abalone and the associated processing facility has a potentially HIGH significance for wild abalone stocks in terms of disease spread. The risks posed by disease should not increase with an expansion of the farm, as long as the existing health program is continued. If the mitigatory measures outlined in Appendix 1 continue to be observed, the threat of disease to the wild stock will be LOW.

7.2 Threat of Disease to wild stock: Kob Cause/Comment: A veterinary opinion on the threat of disease to wild abalone by abalone health specialist Dr Anna Mouton is provided in Appendix 1. Kob, as with all fish, are exposed to a wide spectrum of pathogens and parasites that could lead to the onset of clinical disease. Susceptibility to these agents is vastly increased by stressful conditions often experienced in high density farmed fish. Farmed Kob may pose a disease threat to wild stocks but the introduction of disease can be prevented by ‘biosecuity” measures and adhering to the Draft Guidelines for Finfish Farming in South Africa (2007). Mitigation: The occurrence of disease can be prevented by means of biosecurity measures as outlined in detail by Dr Mouton in appendix 1.

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Significance Statement: The proposed culture of kob at Wild Coast poses a LOW risk to wild fish provided the farm employs good husbandry and health monitoring practises.

7.3 Genetic Threat to the Wild Stock : Kob Cause/Comment: The South African range for Dusky Kob extends from Cape Point eastwards to Mozambique. A large proportion of the adult population migrates to KwaZulu-Natal to spawn. However, there is genetic evidence of separation by distance and there are also discrete spawning areas in the Southern Cape, Eastern Cape and KZN (Initial genetic BMP Guidelines for Marine Finfish Hatcheries in South Africa). Therefore, in order to preserve the stock identity, harvesting of broodstock should occur within the same geographical area as the grow-out facility. The National Environmental Management: Biodiversity Act 2004 (Act No. 10 of 2004) regulates the movement, possession and culture of threatened and protected indigenous species, and aliens. In terms of the Act, indigenous species that are transferred out of their specific genetic zone or are artificially selected are classified as aliens. Mitigation: While Wild Coast Abalone Farm will not hold its own broodstock, fingerlings will come from broodstock caught in the same area. This will mitigate the possible effects of genetic contamination of the wild population. Significance Statement: Movement of fingerlings from broodstock outside of the same geographical area will have an unknown impact on the natural population. However, fingerlings brought to Wild Coast Abalone farm will have originated from the same geographical area and the impact is thus considered LOW.

7.4 Potential Increase of Algal Blooms Cause/Comment: Harmful algal blooms (HABs) are unknown off the east coast of SA (Pitcher & Calder 1999) and even normal algal blooms are rare or unknown east of Port Elizabeth. Given the high dilution of nutrients in the surf zone, as well as the active nature of the hydrodynamics on this coastline, it is highly unlikely that the occurrence of algal blooms will increase owing to increased nutrient loading from the farm. Mitigation: No mitigation is required. Significance Statement: The significance of this potential threat is LOW.

8 Policy Implications In terms of the Marine Living Resources Act (MLRA) of 1998, permission to undertake marine aquaculture is granted as a “right” which is equivalent to a fishing right. As the MLRA was primarily designed to regulate fisheries, it is silent on the principles and conditions governing marine aquaculture – this includes the issue of access to sea space. The recently published “Policy for the Development of a Sustainable Mariculture Sector in South Africa” (DEAT, 2007a) however, outlines principles and objectives for undertaking marine aquaculture in terms of the MLRA, and makes provision for amending the MLRA to provide for these policy objectives. A legal review of the MLRA is in progress, and a more comprehensive Act which addresses the requirements of the marine aquaculture sector will be promulgated in due course.

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Fairly comprehensive guidelines and regulations for undertaking marine aquaculture have been promulgated by MCM in response to industry needs and the requirements of the MLRA and other legislation.

These include: - Requirements for applying for a marine aquaculture permit - Water quality monitoring requirements for shellfish - Export and import permits - Shellfish health testing - Draft guidelines for marine fish farming - Draft guidelines for marine ranching - Permits to sell undersize abalone - Permits for a fish processing establishment

DEAT’s “Policy for the Development of a Sustainable Mariculture Sector in South Africa in South Africa” (DEAT, 2007) supports shore based aquaculture developments such as Wild Coast Abalone, provided they comply with existing legislation and promote socio-economic benefit. The integrated nature of this activity means that various authorities need to be consulted and permits obtained to legally operate a mariculture facility such as the one operated by Wild Coast Abalone. Wild Coast Abalone has implemented many of the “Best Practise Guidelines for Aquaculture in the Western Cape Province” contained in Hinrichson (2007a&b). These documents are presently being adapted for publication in the Eastern Cape Province. In terms of Wild Coast Abalone’s proposed kob aquaculture plans, MCM has recently issued draft guidelines on Marine Finfish Aquaculture (DEAT, 2007b), which provides guidance for development of this activity. The diversification of the indigenous species used for aquaculture is an objective of DEAT’s Policy for the Development of a Sustainable Mariculture Sector in South Africa in South Africa (DEAT, 2007).

9 Conclusions This document sets out to assess the potential impacts on the marine environment of the expansion of the Wild Coast Abalone Farm (WCA). It is expected that the most significant effect of an increase in the size of the mariculture installation will be the increase in particulate organic matter in the near-shore area around the outfall. This area is already mildly affected, and the increase is not expected to pose a significant risk. Thus no mitigatory steps will be required. While absolute loading of dissolved nutrients and ammonia will increase, the overall effect will remain the same as at present. The significance of this impact is therefore low and no mitigatory steps need to be taken.

Since the potential for a disease outbreak always exists in intensive aquaculture installations, it is essential that strict health monitoring protocols are observed. These are already in place at this farm for abalone, and as a result the risk of a deleterious effect on the natural environment is low. A similar health monitoring program will be followed for Kob culture at this site.

The aesthetic effects of the expansion are minor and as long as the suggested mitigatory steps are taken, the risks associated with these effects remain low.

In conclusion, the expansion of Wild Coast Abalone poses no significant risks to the marine environment.

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10 References Barlow, C. G., Allan, G. L., Williams, K. C., Rowland, S. J. and Smith, D. M. 2003. Aquaculture diet development sub-program: Diet validation and feeding strategies. NSW Fisheries Final Report series. No. 60. 1-199.

Branch, G. M. and Branch, M. L. 1981 - The Living Shores of Southern Africa. Cape Town: Struik: 272 pp.

DEAT, 2007a. Policy for the Development of a Sustainable Mariculture Sector in South Africa” (Government Gazette No 3062, 7 September 2007)

DEAT, 2007b. Draft Guidelines for Finfish Farming in South Africa. Version 8. 01 October 2007. Department of Environmental Affairs and Tourism, Brandh Marine and Coastal Management.

Department of Water Affairs and Forestry. 1995. South African Water Quality Guidelines for Coastal Marine Waters. Volume 4: Mariculture.

Hinrichsen, E. 2007. Guideline to the Authorisation Requirements for Aquaculture in the Western Cape: Edition 1. Division of Aquaculture, Stellenbosch University Report. Republic of South Africa, Provincial Government of the Western Cape, Department of Environmental Affairs & Development Planning, Cape Town.

Hinrichsen, E. 2007. Generic Environmental Best Practice Guideline for Aquaculture Development and Operation in the Western Cape: Edition 1. Division of Aquaculture, Stellenbosch University Report. Republic of South Africa, Provincial Government of the Western Cape, Department of Environmental Affairs & Development Planning, Cape Town.

Ramseyer, L. J. and Garling, D. L. 1994. Fish Nutrition and aquaculture waste management. Department of Fisheries and Wildlife, Michigan State University.

Robertson-Andersson, D., 2003. The cultivation of Ulva lactusa (Chlorophyta) in an integrated aquaculture system for the production of abalone feed and the bioremediation of aquaculture effluent. MSc thesis, University of Cape Town. 258p.

Pitcher, G. C. and Calder, D. 1999 - Harmful Algal Blooms of the Southern Benguela Current: A Review and Appraisal of Monitoring from 1989- 1997. Unpublished report.

Sales, J. S. 2004. Abalone. Aqua Feeds: Formulation and beyond. Volume 1 (3).23-27.

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11 Appendix 1

Potential disease risk posed by expansion of Wild Coast Abalone 10 June 2008 – Independent Report by Amanzi Biosecurity (3 pages)

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WILD COAST ABALONE (PTY) LTD Enviro-Fish Africa (Pty) Ltd (Reg. No. 97/21825/07 Vat No. 4570170920) 22 Somerset Street PO Box 7613 Portion 1 of Farm 259 Grahamstown 6139 East London Haga Haga South Africa 5200 5272 Telephone +27 046 6228241 South Africa South Africa Fax +27 046 6227950 Email: [email protected] Tel: + 27 43 8411999 Fax: + 27 43 8411998 Cell: 083 232 9010 Email: [email protected]

APPENDIX C2: EXISTING APPROVALS

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APPENDIX C3: GREAT KEI LOCALITY MUNICIPALITY STRATEGIC ENVIRONMENTAL ASSESSMENT (SEA)

The GKLM SEA provides environmental guidelines for development that have in turn been incorporated into the GKLM SDF. Elements of these guidelines for No-Go areas and Limited Development Areas which are relevant to the proposed development are provided below:

LIMITED DEVELOPMENT AREAS

Areas not falling within No Development Areas or the Urban Edge (development nodes) (including within the coastal zone) and are generally considered to be of moderate ecological sensitivity, are considered to be Limited Development Areas (LDA).

Although LDAs may be degraded or transformed agricultural lands in which little natural vegetation remains, future development within these areas should demonstrate strong linkages with:

- Socio-economic upliftment and skills development - Net environmental gains

A. General environmental guidelines for LDAs

The following environmental guidelines should be followed with respect to LDAs:

- Subtropical Thicket Ecosystem Plan (STEP): Large areas of GKM and coastal areas are classified in terms of STEP as Conservation Network Areas, and as such the general land-use recommendations of STEP should be applied.

- Aesthetic and Environmental Controls: The purpose of these controls is to ensure that new development within environmental sensitive and conservation-worthy areas, and along the coastline, do not affect the landscape quality negatively (visual intrusiveness) or result in eco-system fragmentation. Architectural style should be in keeping with and sensitive to the environmental characteristics and features of the area to minimise visual intrusion and disruption to the natural landscape. Clearing of indigenous vegetation should be limited (or prohibited altogether) for the construction of dwelling units and should be appropriate for the area required for the building footprint. Indigenous plants should be retained and/or rehabilitated back into the area if necessary. Private gardens should be limited and planting of indigenous species promoted. Onsite environmentally appropriate sanitation options should be adopted. Solar power or other alternative energy systems should be encouraged. Visual intrusion from servitudes (electricity, roads, pipelines etc.) must be taken into consideration and minimized. Appropriate provision should be made for stormwater management.

B. Other environmental principles for LDAs

The same limitations in terms of slopes, flood-lines, etc, as provided for urban development are also applicable. The following additional principles should also be considered:

- Landscape quality: All development proposals must be evaluated in terms of their effects on the landscape quality of the surrounding area. This must consider the visual absorption capacity of the surrounding land and the visual intrusion which will result from the development.

- Urban sprawl: The development should not contribute to urban sprawl as a result of “leap frogging” thereby promoting secondary development

- Carrying capacity: New tourism developments outside of the urban edge must evaluate the impacts of the

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proposed influx of tourists on the immediate natural surrounding areas as well as neighbouring natural and urban areas. A value judgement may be required to determine if the development will exceed the ecological carrying capacity of the surrounding area. This should not promote secondary development (service station; shopping centres etc.) thus creating the need for new a development node.

- Waste disposal and sanitation: Any developments outside the urban edge must be self-sufficient and have a detailed plan for solid waste disposal and on-site sanitation. Developments outside of nodes must not be reliant on the municipal sewage systems as these are planned and designed to accommodate treatment volumes from the defined nodal development areas and may not have sufficient capacity to accommodate additional volumes. In all cases the environmental impacts associated with the waste disposal and sanitation systems will need to be assessed as part of the project EIA.

- Infrastructure requirements: The impacts on the natural environment from additional infrastructure requirements must be carefully considered and must be assessed as part of the project EIA.

- Agriculture: Developments should preferably not be permitted on land designated as “prime and unique” agriculture land or significantly reduce the area of high value agriculture lands, thereby reducing the potential productivity of these areas

- Buffer zones: Development should not to be situated in a coastal buffer zone; river/estuarine buffer zone as defined.

- Biodiversity corridors: The development must not impact significantly on biodiversity corridors including STEP network areas and the “coastal green corridor”

- Pristine habitats: Developments must not be situated adjacent to rivers designated as being pristine, near pristine or stressed.

- Traditional & public access: Development must not prohibit or alter traditional access to resources or restrict public access to the coast unduly. Formal access points to rivers/estuaries & beaches are only to be constructed after specialist evaluation and authorization by authorities

C. Sub-division and rezoning guidelines

Any development within LDA’s is subject to specific legislative & environmental requirements such as subdivision, rezoning and EIA requirements, and all development proposals outside of the urban edge should be assessed in terms of the following guidelines, in addition to those already outlined above.

Business and commercial developments: The rezoning of Business / Commercial/ Industrial uses must only occur in conjunction with identified development nodes within LDAs and should not be permitted within the coastal zone (as defined) unless motivation can be given to prove that they are coastal dependent.

Residential developments in LDAs: With respect to the current context, residential development refers to “separate legal title or ownership” (e.g. Residential and Resort II zoning).

All residential development outside of the Urban Edge should be subject to the following limitations: - Intensity of uses (i.e. coverage and density) - Compliance with all relevant environmental requirements - The housing components of Golf Estates are specifically classified as Urban - Development and should not be permitted outside the Urban Edge (unless the densities are consistent with the densities recommended below).

a) Permitted Coverage

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Development should not be spread uniformly over the land, but should be appropriately clustered and should be located on portions of the land that will result in the least amount of environmental impact unless there are compelling reasons why this should not apply.

The remainder of the property should be zoned as Open Space III (nature reserve) (the use of the open space must be indicated) or Special Zone: Conservation.

A Site Development Plan for the entire development area (e.g. farm) must be provided including for any Resort I and Resort II developments (where the area for development and the remainder should be clearly shown).

The Site Development Plan should also incorporate an ecological sensitivity analysis to identify areas of low sensitivity on which developments could be situated and an agricultural potential assessment.

b) Permitted Density

Densities of residential development in LDAs or outside of the Urban Edge should in principle be low density.

While ribbon development and urban sprawl should be discouraged, there is no information to guide what might be considered to be an appropriate density for low density residential development outside of the Urban Edge.

It is thus suggested that a “precautionary” and conservative approach is adopted until empirical evidence or other guidance becomes available on the environmental consequences of permitting development in ostensibly rural and un-serviced areas outside the defined Urban Edge.

Proposed densities are discussed below for development away from and adjacent to the Urban Edge.

c) Environmental Considerations

An EIA should be required as per NEMA/ECA which must consider secondary impacts such as: - The sustainability of water supply; - Other infrastructural requirements - Aspects of long-term sustainability; and - Social impacts such as the location and extent of worker housing and associated facilities.

In coastal areas, Coastal Zone Management principles should apply.

d) Granting of additional units

For all developments in LDAs outside of the Urban Edge that have considered the environmental sensitivity of the site, are considered to be eco-friendly, involve the restoration of previously degraded environments and also comply with the proposed aesthetic and environmental guidelines; additional units for ownership may be considered over and above those indicated below.

Such development should be considered to be outside of the Urban Edge and will not be considered as creating a precedent for further development. This will require strong motivation and careful consideration of environmental aspects including plans for managing the natural environment/open space (e.g. alien control etc.). It is most likely that a full Environmental Impact Assessment would be required in order to meet these requirements.

e) Environmental gains

All developments in LDAs located outside the Urban Edge should be assessed in terms of the net environmental gains that the development can potentially contribute, including where developments can contribute to the management of conservation-worthy and coastal areas.

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The principle that appropriate environmentally sensitive development can finance conservation in certain instances should be considered when assessing development proposals.

f) Other considerations

No further units, subdivisions, developments or schemes that permit ownership of any sort (such as lease hold, share-block, sectional title, closed corporations, trusts etc.) should be permitted beyond the original authorization.

Two different types of residential development within LDAs (i.e. outside of designated development nodes and the Urban Edge) are contemplated, namely;

- Development situated away from the Urban Edge; and - Development immediately adjacent to the Urban Edge

Residential development within LDAs away from the Urban Edge (rural context)

Densities for new residential (separate title) development within LDAs but away from the Urban Edge (rural in nature) should be considered according to the following guidelines:

a) Permitted Density

Unit densities for residential developments in LDA areas away from the Urban Edge should be limited to the lower of: - Maximum of 1 (one) unit per 10 (ten) hectares - As deemed appropriate based on the carrying capacity of the environment as determined by the EIA process.

A dwelling unit should not have a footprint surface area of greater than 300m2, and subject to the environmental limitations and carrying capacity of the land, and shall not be more than 2 storeys high (ground level and one floor).

Residential development within LDAs immediately adjacent to the Urban Edge or within transitional areas identified

Densities are recommended below for new residential (separate title) development within LDAs but immediately adjacent to the Urban Edge or transitional areas identified. Two transitional areas are envisaged: - Inland and to the west of the existing Kei Mouth town - Between Chintsa and the Glenns

Densities in the areas mentioned above should be considered in a sequential manner (inside-outward) according to the following guidelines: b) Permitted Density

Unit densities for residential developments in LDA areas immediately adjacent to the Urban Edge or transitional areas should be limited to the lower of: - Maximum of 2 (two) units per 1 (one) hectare of developable land. - As deemed appropriate based on the carrying capacity of the environment as determined by the EIA process.

A dwelling unit should not have a footprint surface area of greater than 300m2, and subject to the environmental limitations and carrying capacity of the land and shall not be more than 2 stories high (ground level and one floor).

c) Applications for residential developments adjacent to the urban edge or within transitional areas should only be considered once:

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(i) The area within the relevant GKM Urban Edge has been developed substantially and the remaining area available for residential development is limited. a. A report indicating the unavailability of suitable land within the Urban Edge, including market projections and other evidence that an expansion of the Urban Edge is required to meet property demands b. Golf estates will only be considered in areas adjacent to the Urban Edge of primary, secondary and tourism nodes and then subject to the following conditions i. All the requirements in section 6 of this report are met ii. National & provincial policies and guidelines for the development of golf estates are followed (if available) iii. It is suggested that the guidelines for golf and polo estate developed for the Western Cape be considered until similar local guidelines are developed. ii. Limited expansion of the Urban Edge at second order coastal nodes (also in a sequential manner) will only be considered once the Urban Edges of the first order coastal nodes have been substantially developed.

d) Planning Considerations

Residential developments adjacent to the Urban Edge should only be considered if: - The built environment portion of any development is situated adjacent to the existing Urban Edge; - The proximity of existing urban development and/or the centre of the original node is to be considered to ensure adequate service provision - “Leap-frogging” development will only be permitted if the proposed development consists of upgrading existing development and no new developments will take place.

D. Tourism developments in LDAs

Tourism is seen as an important mechanism for promoting economic growth, poverty alleviation and skills development in GKM. Although tourism developments should ideally be confined to development nodes and within the Urban Edge, it is recognised that certain types of tourism that should be promoted in GKM (e.g. coastal resorts, eco- tourism, etc) are reliant on being located outside of the Urban Edge. This approach is confirmed in the White Paper for Sustainable Coastal Development where the basic principles for the utlization of coastal assets include the promotion of tourism and poverty alleviation.

For this reason, bona fide tourism developments located in LDAs, and outside the Urban Edge, should be considered based on the contribution that such development can make to economic growth, poverty alleviation and skills development in GKM.

The development of dense urban-type developments outside the Urban Edge and private housing developments and gated communities masquerading as tourism developments should be strongly discouraged.

Legitimate tourism developments outside the Urban Edge may include (but are not limited to): - Holiday/tourism accommodation (hotels, resorts, restaurants, etc.) reliant on being located within conservation areas or close to the coast (such as nature reserves, game farms, etc.). - Golf and other types of estates with a strong links to tourism and socio-economic upliftment.

The following principles should be considered when assessing the desirability, appropriateness or bona fides of tourism development proposals in LDAs or outside the Urban Edge.

Appropriate zoning The applicable zoning must be Resort I. Residential or other zoning that permits transfer of separate tile or private ownership should not be permitted.

Job creation and skills development Clear links to job creation and skills development must be demonstrated.

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Staff accommodation Adequate provision should be made for the accommodation of resort or other staff members

Densities Resort uses outside the Urban Edge should only be permitted at low densities. These appropriate densities should be determined on a case by case basis and on merit (i.e. environmental gains, levels of job creation, etc.).

Environmental gains Preference should be given to tourism developments outside the Urban Edge that result in net environmental gains and where developments can contribute to the management of conservation-worthy and coastal areas.

Low density and aesthetically appropriate residential development that primarily promotes conservation and also eco-tourism and community projects should be encouraged.

NO DEVELOPMENT AREAS

No Development Areas (NDAs) consist of all areas which are officially proclaimed local, provincial or national nature reserves and protected areas or state forests. However, they also include additional areas, which are deemed to be ecologically and environmentally sensitive to disturbance. This will ensure the protection of sensitive and dynamic habitats within GKM and especially along coastline. This will also promote the maintenance of a “Green Network” which will allow for maintenance of biodiversity and movement of fauna along within GKM and the coastal zone.

Sensitive areas

The identification of sensitive areas within GKM was determined based on: an ecological sensitivity analysis undertaken using aerial photography, STEP GIS data, field surveys and expert knowledge on GKM and the coastal zone. Based on this information areas of high ecological and environmental sensitivity were identified. These areas were used to define the boundaries of No Development Areas within the GKM coastal zone in conjunction with the proclaimed conservation areas. This was done in order to ensure the maintenance of sufficient areas of natural coastal capital within the GKM. The maintenance of these areas is of strategic importance to the GKM for the following reasons: 1. Ensures the maintenance of a scenic landscape for promotion of tourism 2. Allows for local tourism development due to the scenic landscape 3. Tourism will create local employment opportunities and economic development of local communities 4.Ensures protection of the dynamic coastal areas 5. Ensures conservation of the biodiversity through the formation of a coastal corridor for the maintenance of ecosystem functioning and animal movement.

Criteria for defining sensitive areas

The following criteria were used for the identification and demarcation of areas of high environmental sensitivity outside of existing proclaimed reserves. These criteria are considered to be exclusionary criteria for any future development and as a result any part of the coastline which had attributes meeting these criteria were considered to be of HIGH SENSITIVITY and are therefore NO DEVELOPMENT areas.

Criteria for NO Development Areas: - STEP High Priority Critically Endangered Areas - STEP High Priority Process Areas - Officially Proclaimed nature reserves, conservation areas or forests - Areas of pristine coastal forest/thicket - Areas of pristine and diverse coastal grasslands - Riparian and buffer areas along watercourses (rivers and estuaries) including 1:100 flood line or within 50m of watercourses - Dynamic and coastal buffer areas including:

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- Primary of mobile dune systems - Within 50m of coastal cliffs - Within 50m of the high water mark

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Wild Coast Abalone (Pty) Ltd

APPLICATION FOR A LEASE IN TERMS OF THE SEASHORE ACT

S E R V I C E S

26 May 2017

ON BEHALF OF: PREPARED BY: Wild Coast Abalone (Pty) Ltd Imithi Services P.O. Box 7613 P.O. Box 340 East London Gonubie 5200 5256

Tel: 043 841 1999 Tel: 043 740 5842 Email: [email protected] Fax: 088 043 740 5842 Email: [email protected] Mr. Richard Clark Mr Brett Dustan (Pr.Sci.Nat.) Owner

1. INTRODUCTION

In February 2017, Imithi Services was appointed by Wild Coast Abalone (Pty) Ltd to undertake the necessary Basic Assessment Report (BAR) to obtain Environmental Authorization for stabilization of the banks of the existing discharge channel, to do erosion control, to extend the timber pedestrian bridge over the channel, and to do some rehabilitation of dune areas in front of Wild Coast Abalone, at Marshstrand.

The activities will be within ECPTA managed land, and as such is in an Environmentally Sensitive Area, and is it situated in a Biodiversity Sensitive Area in terms of the Eastern Cape Biodiversity Conservation Plan (ECBCP).

The stabilization of the banks of the discharge channel will involve the installation of gabions. Erosion control and rehabilitation will involve planting of indigenous trees and shrubs in previously impacted areas on the dunes. The timber pedestrian bridge over the discharge channel, which is about 8.5m long and 0.75m wide, may have to be extended slightly to compensate for any future increase of discharge volume.

The process will conform to the Environmental Impact Assessment Regulations Listing Notices of 2014 of the National Environmental Management Act of 1998 (NEMA).

The project will be known as the ‘Rehabilitation and erosion control at Wild Coast Abalone, Marshstrand’.

Wild Coast Abalone (Pty) Ltd wishes to formalize a lease for the sea water intake pipeline, sump overflow pipeline, and the free flow discharge that falls below the high water mark (HWM) of the sea, which was approved in principle in 1997 (refer to Annexure 1).

The sea water intake pipeline has about a 95m² footprint below the HWM, the sump overflow pipeline has a 25m² footprint below the HWM, and the free flow discharge over the beach covers about 95m² below the HWM of the sea.

Erosion protection will be implemented along the course of the free flow discharge but will not extend below the HWM.

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1.1 PROPONENT

The proponent is Wild Coast Abalone (Pty) Ltd, represented by Mr. Richard Clark who is a director of the company. Contact details are as follows:

Wild Coast Abalone (Pty) Ltd P.O. Box 7613 East London 5200

Tel: 043 841 1999 Fax: 043 841 1998 Email: [email protected]

1.2 ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)

The Environmental Assessment Practitioner appointed to do the environmental studies is Imithi Services, represented by Mr Brett Dustan (Pr. Sci. Nat.). Contact details are as follows:

Imithi Services P.O. Box 340 Gonubie 5256

Tel: 043 740 5842 Fax: 088 043 740 5482 Cell: 082 377 6428 E-mail: [email protected]

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2. LOCALITY

Wild Coast Abalone

1:50 000 TOPOGRAPHICAL MAP – 3228CB&CD KEI MOUTH

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3. PROJECT DESCRIPTION

The pipelines and the free flow discharge have been operational since 1998 and were authorized under a previous EIA process (Reference No. AN 28/25/4), and the expansion of the farm was authorised after another EIA process in 2008 (Reference No. AR/12/F/1i,1p/1/08). The locations of these are represented in Image 1 below.

Image 1

The coordinates of the positions of the pipelines and free flow discharge are as follows:

STRUCTURE EXTENT BELOW THE EAST SOUTH HIGH WATER MARK Salt water intake pipe 95m² 32° 45’ 08.41” 28° 16’ 32.41” Pump house drain 25m² 32° 45’ 07.75” 28° 16’ 33.15” pipe Free flow discharge 95m² 32° 45’ 02.90” 28° 16’ 39.43”

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3.1 ACTIVITIES

3.1.1 Salt water intake pipe

The salt water intake is a large concrete pipe that transfers water from a large pool in the bedrock of the sea which is situated about 95m below the high water mark of the sea, extending into the sea. The pipe has a width of 1.2m and a height of 1.5m (see attached schematic in Annexure 2), so that it is large enough for a diver to swim up to do inspections.

The intake pipe has a cage over the opening to prevent any material or large organisms from being sucked into the pipe, and this is cleaned once a week (refer to attached maintenance program in Annexure 3).

The intake pipe is covered with rock so that it is not visible to the naked eye at any point along its length.

3.1.2 Pump house drain pipe

The pump house drain pipe is a 315mm diameter PVC that is encased in concrete, and it is simply there to drain any saltwater that may collect on the pump house floor. This pipe extends to about 25m below the high water mark of the sea, and into the intertidal zone, and there is stone pitching over the concrete encasing to make it look natural. Only about 12m of the encasing is visible above ground, and only a trickle of seawater flows out of the pipe.

The drain pipe is visible on the right in this photo.

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3.1.3 Free flow discharge

The free flow discharge is merely a continuous stream of recycled seawater being released back into the sea. The seawater passes through seaweed ponds which remove much of the nitrogenous waste from the water produced by the farm before returning it to the sea.

An extract from the specialist report compiled by Enviro-Fish Africa (Pty) Ltd in 2008, states the following” “The effluent stream cuts a path approximately 5m wide through the dune for about 15m. It then flows under a footbridge constructed by the farm to facilitate the crossing of the outfall stream and flows across the sandy beach for a distance of about 60m. The beach is usually not covered by seawater except during spring high tide and rough sea conditions. The maximum width of the stream in this area is approximately 15m and apart from a 3m wide channel in the middle (which is no more than 30cm deep); the rest is mostly less than 15cm deep. The flow speed is fastest in the deepest part and was measured at 1.4m/sec. The flow has scoured away most of the sand in the stream leaving only coarse gravel and rocks. The stream then reaches the rocky intertidal zone which is approximately 50m wide at low tide. This zone consists of a series of low rocky terraces which, in the main, creates four wide low rock pools lying abreast and parallel to the coast. During low tide, the outfall water therefore spreads laterally while at the same time cascading down into the sea. To the west, lateral spread of the outfall water is restricted to within 50m by a low rocky ridge extending towards the sea. On the eastern side a low rocky ridge about 400m away also prevents the water from spreading further. At high tide the intertidal area is progressively covered to different levels depending on the height of the tide.”

This photo shows the stream flowing over the beach

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An application for a Coastal Waters Discharge Permit in terms of Section 69 of the National Environmental Management: Integrated Coastal Management Act, 2008 (Act No. 24 of 2008), was submitted by Wild Coast Abalone (Pty) Ltd in 2016, and it is ‘in process’ with the Department of Environmental Affairs, in Cape Town (refer to Annexure 4).

4. CONCLUSION

Considering the fact that the Wild Coast Abalone (Pty) Ltd owned abalone farm has been in existence since 1998, and it received approval for a Sea Shore Act Lease in principle in 1997, it would make sense to formalize the lease now therefore it is recommended that the lease be approved and issued to Wild Coast Abalone (Pty) Ltd.

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APPENDIX C3: GREAT KEI LOCALITY MUNICIPALITY STRATEGIC ENVIRONMENTAL ASSESSMENT (SEA)

LIMITED DEVELOPMENT AREAS

Although LDAs may be degraded or transformed agricultural lands in which little natural vegetation remains, future development within these areas should demonstrate strong linkages with:

- Socio-economic upliftment and skills development - Net environmental gains

A. General environmental guidelines for LDAs

The following environmental guidelines should be followed with respect to LDAs:

B. Other environmental principles for LDAs

The same limitations in terms of slopes, flood-lines, etc, as provided for urban development are also applicable. The following additional principles should also be considered:

- Urban sprawl: The development should not contribute to urban sprawl as a result of “leap frogging” thereby promoting secondary development

- Carrying capacity: New tourism developments outside of the urban edge must evaluate the impacts of the

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- Infrastructure requirements: The impacts on the natural environment from additional infrastructure requirements must be carefully considered and must be assessed as part of the project EIA.

- Buffer zones: Development should not to be situated in a coastal buffer zone; river/estuarine buffer zone as defined.

- Biodiversity corridors: The development must not impact significantly on biodiversity corridors including STEP network areas and the “coastal green corridor”

- Pristine habitats: Developments must not be situated adjacent to rivers designated as being pristine, near pristine or stressed.

C. Sub-division and rezoning guidelines

Residential developments in LDAs: With respect to the current context, residential development refers to “separate legal title or ownership” (e.g. Residential and Resort II zoning).

a) Permitted Coverage

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The remainder of the property should be zoned as Open Space III (nature reserve) (the use of the open space must be indicated) or Special Zone: Conservation.

b) Permitted Density

Densities of residential development in LDAs or outside of the Urban Edge should in principle be low density.

Proposed densities are discussed below for development away from and adjacent to the Urban Edge.

c) Environmental Considerations

In coastal areas, Coastal Zone Management principles should apply.

d) Granting of additional units

e) Environmental gains

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The principle that appropriate environmentally sensitive development can finance conservation in certain instances should be considered when assessing development proposals.

f) Other considerations

Two different types of residential development within LDAs (i.e. outside of designated development nodes and the Urban Edge) are contemplated, namely;

- Development situated away from the Urban Edge; and - Development immediately adjacent to the Urban Edge

Residential development within LDAs away from the Urban Edge (rural context)

Densities for new residential (separate title) development within LDAs but away from the Urban Edge (rural in nature) should be considered according to the following guidelines:

a) Permitted Density

Residential development within LDAs immediately adjacent to the Urban Edge or within transitional areas identified

Densities in the areas mentioned above should be considered in a sequential manner (inside-outward) according to the following guidelines: b) Permitted Density

c) Applications for residential developments adjacent to the urban edge or within transitional areas should only be considered once:

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d) Planning Considerations

D. Tourism developments in LDAs

The development of dense urban-type developments outside the Urban Edge and private housing developments and gated communities masquerading as tourism developments should be strongly discouraged.

The following principles should be considered when assessing the desirability, appropriateness or bona fides of tourism development proposals in LDAs or outside the Urban Edge.

Appropriate zoning The applicable zoning must be Resort I. Residential or other zoning that permits transfer of separate tile or private ownership should not be permitted.

Job creation and skills development Clear links to job creation and skills development must be demonstrated.

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Staff accommodation Adequate provision should be made for the accommodation of resort or other staff members

Low density and aesthetically appropriate residential development that primarily promotes conservation and also eco-tourism and community projects should be encouraged.

NO DEVELOPMENT AREAS

Sensitive areas

Criteria for defining sensitive areas

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- Primary of mobile dune systems - Within 50m of coastal cliffs - Within 50m of the high water mark

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