Draft Basic Assessment Report: Proposed

DRAFT BASIC ASSESSMENT REPORT: PROPOSED UPGRADING OF NATIONAL ROUTE R335 BETWEEN MOTHERWELL (KM 5.600) AND ADDO (KM 37.600), WITHIN THE NELSON MANDELA BAY MUNICIPALITY AND SUNDAYS RIVER VALLEY LOCAL MUNICIPALITY, EASTERN CAPE PROVINCE

NOVEMBER 2018

Terratest (Pty) Ltd Reference No.: 41643 DEA Reference No.: Pending NEAS Reference No.: Pending

Prepared by: TERRATEST (PTY) LTD

PO Box 27308, Greenacres Port Elizabeth, 6057 Telephone: (041) 390 8730 Contact: Mrs Cherize Coetzee Email: [email protected]

DBAR: R335 Upgrade, Motherwell to Addo 41643

VERIFICATION PAGE

TITLE: PROPOSED UPGRADING OF NATIONAL ROUTE R335 BETWEEN MOTHERWELL (KM 5.600) AND ADDO (KM 37.600), WITHIN THE NELSON MANDELA BAY MUNICIPALITY AND SUNDAYS RIVER VALLEY LOCAL MUNICIPALITY, EASTERN CAPE PROVINCE PROJECT NO.: DATE: REPORT STATUS: 41643 November 2018 Draft CARRIED OUT BY: COMMISSIONED BY: Terratest (Pty) Ltd, Pietermaritzburg South African National Roads Agency SOC Ltd PO Box 27308 PO Box 24210 Greenacres Baywest Boulevard, Hunters Retreat Port Elizabeth Port Elizabeth 6057 6025

Tel: (041) 398 3249 Tel: (033) 343 6789 Fax: (041) 363 1922 Tel: (033) 343 6701 Email: [email protected] Email: [email protected] AUTHORS: CLIENT CONTACT PERSON: Ms Imke Summers Mr S Robertson SYNOPSIS: Basic Assessment Report for the proposed upgrading of the R335 road between Motherwell and Addo, within the Nelson Mandela Bay Municipality and Sundays River Valley Local Municipality KEY WORDS: R335 Road, Motherwell, Addo, Upgrade, Widening, Bridges, Culverts, Basic Assessment, Environmental Management Programme, EIA Regulations (2014, as amended), Nelson Mandela Bay Municipality, Sundays River Valley Local Municipality, SANRAL © Copyright Terratest (Pty) Ltd QUALITY VERIFICATION This report has been prepared under the controls established by a quality management system that meets the requirements of ISO9001: 2008 which has been independently certified by DEKRA Certification under certificate number 90906882.

VERIFICATION CAPACITY NAME SIGNATURE DATE Snr Environmental By Author Imke Summers 30/10/2018 Consultant Snr Environmental Checked by John Richardson 30/10/2018 Scientist Magnus van Authorised by Executive Associate 30/10/2018 Rooyen

File name: \\dcjgi01-pe\activeprojects\01 TERRATEST\41643 - Motherwell Addo Road Upgrade\07 REPORTS\BAR's and EMPr's\Road upgrade

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EXECUTIVE SUMMARY

Terratest (Pty) Ltd has been appointed by GIBB Engineering & Architecture (Pty) Ltd, on behalf of the South African national Roads Agency SOC Ltd (SANRAL), to undertake the necessary environmental services required for the proposed upgrading of the R335 (also referred to as the MR450) road between Motherwell and Addo, located within the Nelson Mandela Bay Municipality and Sundays River Valley Local Municipality, Eastern Cape. The proposed project triggers Listed Activities contained within the National Environmental Management Act (NEMA): Environmental Impact Assessment (EIA) Regulations of 2014, as amended, and requires a Basic Assessment process to be undertaken. A Water Use Licence Application authorisation will also be required prior to construction commencing.

The road crosses the Coega and Sundays Rivers. The existing Coega River Bridge will be demolished and reconstructed on a new horizontal and vertical alignment close to the existing bridge. The resulting bridge width will be 14.35m, the road width will be 13.4m and the length of the bridge will be 25m. The Sundays River bridge will be reconstructed and widened. As it will be necessary to widen the deck the existing balustrades and sidewalks shall be demolished, and a duplicate bridge will be constructed alongside the existing structure in order to accommodate the wider road profile. The new deck will accommodate a road width of 13.4 m.

Five existing culvert structures (Culverts B- F) will be expanded. The five in situ box culverts will be completed with inlet and outlet structures with 3 cell x 3400mm width x 3200mm height configuration. Two new culvert structures will be constructed along the alignment. Culvert A has a configuration of a 2-cell x 2400mm width x 2400mm height and Culvert G has a 2-cell x 2000mm width x 1800mm height.

Two precast wildlife underpasses will be constructed along the R335 road. These culvert structures will have a 1-cell x 2400mm width x 2400mm height configuration.

Additional works includes the construction of retaining walls, road and cross drainage, guardrails, signage, fencing, bus / taxi shelters and stops and road markings.

The public participation process undertaken involved consultation with the relevant authorities, non- government organisations (NGO’s), neighbouring landowners, community members and other identified Interested and Affected Parties (IAPs). A pre-application meeting was held with the Department of Environmental Affairs (DEA) on 03/10/2018. Public Participation involved the establishment of English site notices placed along the length of the alignment on 19/01/2018 to notify members of the general public of the Basic Assessment Process for the proposed development. An advert, in English, was placed in the Public Notices section of The Herald newspaper on 12/01/2018 and the Daily Dispatch on 12/01/2018.

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Background Information Documents (BID) and Notification Letters,in English, were emailed to landowners, stakeholders and IAP’s in January, September and October of 2018. Letter drops were used to disseminate the BID to members of the Motherwell community. A Public Meeting was held with members of the Motherwell community on 11 April 2018 to notify them of the proposed road upgrade. A public meeting has been scheduled in Addo, with all registered stakeholders and IAP’s, for early December 2018, during the Draft BAR public participation phase, to present the findings of the report to the communities, as well as address any queries or concerns raised.

Stakeholders and IAPs were notified of the availability of the Draft Basic Assessment (BA) Report via email and through the relevant ward councillors on 22/11/2018. Hard copies of the report were delivered on 22/11/2018 to Addo Library and the Motherwell Library, for public review. Hard copies of the reports were also delivered to the DEA, the Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT), the Department of Water and Sanitation (DWS), the DEA’s internal Protected Areas Department and Biodiversity Conservation Areas Department, the Nelson Mandela Bay Municipality and the Sundays River Valley Local Municipality. To date comments have been submitted from stakeholders and IAP’s based on the BID, notification sheets, posters and the public meeting. Comments are varied and relate primarily to job creation, impacts to the receiving biophysical environments, queries regarding impacts to infrastructure and housing etc.

Copies of correspondence submitted, notification emails, cover letters, transmittal notices, delivery and read receipts are included in Appendix 7 (Public Participation Process).

In terms of specialist input, four specialist studies were commissioned and included a Wetland Assessment, and Vegetation Assessment, a Phase 1 Palaeontological Impact Assessment and a Phase 1 Archaeological and Cultural Heritage Impact Assessment. The Wetland Assessment was undertaken by Terratest (Pty) Ltd to determine the presence of any wetlands and watercourse within 500m of the proposed upgrading as well as impacts of the upgrading on the receiving environment. A Vegetation Assessment was undertaken by Terratest (Pty) Ltd to determine the impact of the development on the biophysical environment. A Phase 1 Palaeontological Impact Assessment was undertaken by Banzai Environmental to determine whether any palaeontological resources would be impacted by the proposed development. It was noted that no resources were identified within the upgrade footprint. A Phase 1 Archaeological and Cultural Heritage Impact Assessment was undertaken along the alignment and noted two features of archaeological importance, namely the Coega and Sundays River Bridges. A Conceptual Transport Planning Study and Engineering Assessment and Design Report were also undertaken to inform the engineering design of the upgraded road.

No fatal flaws to development were identified by any of the specialists. Mitigation measures to reduce the impact of the proposed development on the receiving environment were provided by the specialists as well as the relevant permitting and search and rescue processes that need to be undertaken and included in the site specific Environmental Management Programme (EMPr).

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Comments received on the Draft BAR and EMPr will be included in the Final BAR, which will be submitted to the Department of Environmental Affairs for a decision on Environmental Authorisation (EA). Construction cannot commence until such time as a positive decision on the EA is obtained.

This Draft BAR has been drafted in accordance with the EIA Regulations (2014, as amended) and adheres to the requirements contained in Appendix 1 of GNR 982, as noted in Table 1.

Table 1-1: Content of a BAR (2014 EIA Regulations, as amended)

2014 EIA Description of EIA Regulations Requirements for BAR Location in Regulations the BAR Appendix 1, Details of – Section 3 (a) (i) The EAP who prepared the report; and the expertise of the EAP; and Section 2 & (ii) The expertise of the EAP, including a curriculum vitae. Appendix 1 Appendix 1, The location of the activity, including – Section 3 Section 3 (b) (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, coordinates of the boundary of the property or properties Appendix 1, A plan which locates the proposed activity or activities applied for at an appropriate Section 3 Section 3 (c) scale, or, if it is – (i) A linear activity, a description and coordinates of the corridor in which the proposed activity or activities is to be undertaken; or (ii) On land where the property has not been defined, the coordinates within which the activity is to be undertaken. Appendix 1, A description of the scope of the proposed activity, including – Section 4 & Section 3 (d) (i) All listed and specified activities triggered; 5 (ii) A description of the activities to be undertaken, including associated structures and infrastructure. Appendix 1, A description of the policy and legislative context within which the development is Section 4 Section 3 (e) 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. Appendix 1, A motivation for the need and desirability for the proposed development including Section 6 Section 3 (f) the need and desirability of the activity in the context of the preferred location. Appendix 1, A full description of the process followed to reach the proposed preferred activity, Section 3 (h) site and location within the site, including- (i) Details of all alternatives considered; Section 7 (ii) Details of the Public Participation Process undertaken in terms of Regulation Section 10 41 of the Regulations, including copies of the supporting documents and inputs; (iii) A summary of the issues raised by interested and affected parties, and an Section 10 indication of the manner in which the issues were incorporated, or the reasons for not including them; (iv) The environmental attributes associated with the alternatives focusing on the Section 8 geographical, physical, biological, social, economic, heritage and cultural aspects; (v) The impacts and risks identified for each alternative, including the nature, Section 12 & significance, consequence, extent, duration, and probability of the impacts, 13 including the degree to which the 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 deterring and ranking the nature, significance, Section 11 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 Section 12 have on the environment and on the community that may be affected focusing on the geographic, physical, biological, social, economic, heritage and cultural aspects; (viii) The possible mitigation measures that could be applied and level of residual Section 12 risk; (ix) The outcome of the site selection matrix; Section 13 (x) If no alternatives, including alternative locations for the activity were Section 7 &

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2014 EIA Description of EIA Regulations Requirements for BAR Location in Regulations the BAR investigated, the motivation for not considering such and; 14 (xi) A concluding statement indicating the preferred alternatives, including Section 14 preferred location of the activity. Appendix 1, A full description of the process undertaken to identify, assess and rank the impacts Section 12 & Section 3 (i) the activity will impose on the preferred location through the life of the activity, 13 including- (i) A description of all environmental issues and risks that were identified during the environmental impact assessment process; and (ii) An assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures. Appendix 1, An assessment of each identified potentially significant impact and risk, including- Section 13 Section 3 (j) (i) Cumulative impacts; (ii) The nature, significance and consequences of the impact and risk; (iii) The extent and duration of the impact and risk; (iv) The probability of the impact and risk occurring; (v) The degree to which the impact and risk can be reversed; (vi) The degree to which the impact and risk may cause irreplaceable loss of resources; and (vii) The degree to which the impact and risk can be avoided, managed or mitigated. Appendix 1, Where applicable, a summary of the findings and impact management measures Section 9 Section 3 (k) identified in any specialist report complying with Appendix 6 to these Regulations and an indication as to how these findings and recommendations have been included in the final report. Appendix 1, An environmental impact statement which contains- Section 8 & Section 3 (l) (i) A summary of the key findings of the environmental impact assessment; 14 (ii) A map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers; and (iii) A summary of the positive and negative impacts and risks of the proposed activity and identified alternatives. Appendix 1, Based on the assessment, and where applicable, impact management measures Section 15 Section 3 from specialist reports, the recording of the proposed impact management (m) objectives, and the impact management outcomes for the development for inclusion in the EMPr. Appendix 1, Any aspects which were conditional to the findings of the assessment either by the Section 15 & Section 3 (n) EAP or specialist which are to be included as conditions of authorisation. 16 Appendix 1, A description of any assumptions, uncertainties, and gaps in knowledge which relate - Section 3 (o) to the assessment and mitigation measures proposed; Appendix 1, A reasoned opinion as to whether the proposed activity should or should not be Section 15 Section 3 (p) authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation. Appendix 1, Where the proposed activity does not include operational aspects, the period for Section 16 Section 3 (q) which the environmental authorisation is required, the date on which the activity will be concluded, and the post construction monitoring requirements finalised. Appendix 1, An undertaking under oath or affirmation by the EAP in relation to- Section 17 & Section 3 (r) (i) The correctness of the information provided in the report; 18 (ii) The inclusion of the comments and inputs from stakeholders and interested and affected parties; (iii) the inclusion of inputs and recommendations from the specialist reports where relevant; and (iv) Any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested and affected parties. Appendix 1, Where applicable, details of any financial provisions for the rehabilitation, closure, - Section 3 (s) and ongoing post decommissioning management of negative environmental impacts. Appendix 1, Where applicable, any specific information required by the Competent Authority. - Section 3 (t) Appendix 1, Any other matter required in terms of section 24(4) (a) and (b) of the Act. - Section 3 (u)

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TABLE OF CONTENTS

1. INTRODUCTION ...... 1 2. DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) ...... 2 3. LOCATION OF THE ACTIVITY ...... 3 4. LEGAL CONTEXT ...... 6 4.1 APPLICABLE LISTED ACTIVITIES ...... 6 4.2 DEA PRE-APPLICATION MEETING ...... 9 4.3 NATIONAL WATER ACT (ACT 36 OF 1998) ...... 11 4.4 APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES...... 11 5. DESCRIPTION OF THE ACTIVITY ...... 13 5.1 PROJECT OVERVIEW ...... 13 5.2 PROJECT DESCIPTION ...... 13 5.2.1 Design Details1 ...... 13 6. DEVELOPMENT MOTIVATION ...... 25 6.1 NEED ...... 25 6.2 DESIRABILITY ...... 26 6.3 PLANNING CONTEXT ...... 26 6.3.1 National Development Plan ...... 26 6.3.3 NMBM Metropolitan Spatial Development Framework ...... 27 7. MOTIVATION FOR THE PREFERRED SITE, ACTIVITY AND TECHNOLOGY ALTERNATIVE ...... 28 7.1 PREFERRED SITE ALTERNATIVE ...... 29 7.2 PREFERRED LAYOUT ALTERNATIVE ...... 29 7.3 PREFERRED TECHNOLOGY ALTERNATIVE ...... 31 7.4 NO-GO ALTERNATIVE ...... 36 8. DESCRIPTION OF THE BASELINE ENVIRONMENT ...... 37 8.1 TOPOGRAPHY ...... 37 8.2 ECOLOGICAL ENVIRONMENT ...... 37 8.3 BIOREGIONAL AND LOCAL CLASSIFICATION ...... 39 8.4 PROTECTED AREAS ...... 42 8.5 NATIONAL PROTECTED AREAS EXPANSION STRATEGY ...... 42 8.6 CRITICAL BIODIVERSITY AREAS ...... 46 8.7 GEOLOGY AND SOILS ...... 51 8.8 HYDROLOGY (WATERCOURSES & WETLANDS) ...... 51 8.9 CLIMATE ...... 54 8.10 LAND USES ...... 54 8.11 CULTURAL, HISTORICAL AND ARCHAEOLOGICAL RESOURCES ...... 56 8.12 EXISTING INFRASTRUTCTURE ...... 56 8.13 SOCIO-ECONOMIC ...... 57 8.14 ECONOMICS ...... 58 8.15 TRAFFIC ...... 59 9. SPECIALIST STUDIES ...... 65 9.1 WETLAND IDENTIFICATION AND ASSESSMENT ...... 65 9.1.1 Wetland Delineation and Identification ...... 65 9.1.2 Description of Wetland Type ...... 68 9.1.3 Wetland Ecological Functional Assessment (WET-EcoServices) ...... 68 9.1.4 Ecological Importance and Sensitivity Assessment (WET-Health) ...... 68 9.1.5 Buffer determination ...... 69 9.1.6 Risk Assessment ...... 69 9.1.7 Recommendations ...... 72 9.1.8 Conclusion ...... 72 9.2 PHASE 1 ARCHAEOLOGICAL & CULTURAL HERITAGE IMPACT ASSESSMENT ...... 73 9.2.1 Site MR450-S1 – Colonial Period: Sundays River Bridge ...... 74

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9.2.2 Site MR450-S7 – Colonial Period: Coega River Bridge ...... 74 9.2.3 Site MR450-S8 – Colonial Period: Homestead ...... 75 9.2.4 Recommendations and conclusions ...... 76 9.3 PALAEONTOLOGICAL IMPACT ASSESSMENT...... 76 9.3.2. Conclusion ...... 77 9.4. VEGETATION ASSESSMENT...... 78 9.4.1. Floristic Findings ...... 78 9.4.2. Species of Conservation Concern ...... 79 9.4.3. Sensitivity mapping ...... 80 9.4.4. Impact Assessment ...... 82 9.4.5. Recommendations ...... 83 9.4.6. Ecological Statement and Opinion of the Specialist ...... 84 10. PUBLIC PARTICIPATION ...... 84 10.3 LANDOWNER NOTIFICATION LETTERS ...... 84 10.4 PUBLIC MEETING ...... 84 10.5 WARD COUNCILLOR NOTIFICATION ...... 85 10.7 SITE NOTICE BOARDS ...... 87 10.8 CIRCULATION OF DRAFT BASIC ASSESSMENT REPORT FOR COMMENT ...... 93 10.9 COMMENTS RECEIVED ...... 93 11. IMPACT ASSSESSMENT AND MITIGATION MEASURES ...... 104 11.1 IMPACT ASSESSMENT METHODOLOGY ...... 104 11.2 MITIGATION ...... 108 12. IMPACTS IDENTIFIED ...... 108 13. IMPACT ASSESSMENT ...... 121 14. ENVIRONMENTAL IMPACT STATEMENT ...... 123 15. RECOMMENDATIONS OF THE EAP ...... 124 16. CONSTRUCTION TIMEFRAMES ...... 125 17. SUBMISSION AND CONSIDERATION OF DOCUMENTATION BY THE COMPETENT AUTHORITY 126 18. UNDERTAKING ...... 126

FIGURES

FIGURE 3-1: LOCALITY MAP INDICATING THE ROUTE OF THE EXISTING R335 ROAD BETWEEN MOTHERWELL AND ADDO...... 4 FIGURE 3-2: AN AERIAL IMAGE INDICATING THE ROUTE OF THE EXISTING R335 ROAD BETWEEN MOTHERWELL AND ADDO [REF: GOOGLE EARTH, 2018] ...... 5 FIGURE 4-1: BASIC ASSESSMENT PROCESS ORGANOGRAM ...... 10 FIGURE 5-1: PROPOSED WIDENING OF THE SUNDAYS RIVER BRIDGE ...... 15 FIGURE 5-2: THE GENERAL ARRANGEMENT OF THE COEGA RIVER BRIDGE ...... 15 FIGURE 5-3: CULVERT A LAYOUT PLAN ...... 17 FIGURE 5-4: CULVERT B LAYOUT PLAN ...... 17 FIGURE 5-5: CULVERT C LAYOUT PLAN ...... 17 FIGURE 5-6: CULVERT D LAYOUT PLAN ...... 18 FIGURE 5-7: CULVERT E LAYOUT PLAN ...... 18 FIGURE 5-8: CULVERT F LAYOUT PLAN ...... 18 FIGURE 5-9: CULVERT G LAYOUT PLAN ...... 19 FIGURE 5-10: AN ILLUSTRATION OF THE EXISTING CENTRE LINE (YELLOW), PROPOSED REALIGNED CENTRE LINE (RED) AND SERVITUDE FOOTPRINT (PURPLE) BETWEEN KM29.47 AND KM32.28 BETWEEN MOTHERWELL AND ADDO...... 20 FIGURE 5-11: A TYPICAL DESIGN OF A SINGLE-CELL CULVERT STRUCTURE TO BE CONSTRUCTED FOR AS A WILDLIFE UNDERPASS ...... 21 FIGURE 5-12: TYPICAL DUAL CARRIAGE WAY FOR THE URBAN SECTION WITHIN MOTHERWELL (KM5.6 TO KM9.3) . 23

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FIGURE 5-13: TYPICAL SINGLE CARRIAGEWAY FOR THE RURAL SECTION TOWARDS ADDO (KM9.43 TO KM 37.6) ... 23 FIGURE 8-1: GRADIENT OF THE R335 FROM MOTHERWELL (KM5.6) TO MOTHERWELL (KM7.6) ...... 37 FIGURE 8-2: VEGETATION DESIGNATIONS FOR THE SITE AS PER MUCINA & RUTHERFORD (2006) ...... 38 FIGURE 8-3: LOCAL VEGETATION MAP ILLUSTRATING THE VEGETATION TYPE FOUND WITHIN THE STUDY AREA ..... 41 FIGURE 8-4: THE R335 IN LOCATION TO NEM:BA (ACT 10 OF 2004) GAZETTED PROTECTED AREAS ...... 43 FIGURE 8-5: PRIVATE NATURE / GAME RESERVES IN CLOSE PROXIMITY TO THE R553 ...... 44 FIGURE 8-6: NPAES AREAS IN CLOSE PROXIMITY TO THE R335 ...... 45 FIGURE 8-7: ECBCP DESIGNATED CBA AREAS WHICH THE R335 TRAVERSES ...... 47 FIGURE 8-8: THE LOCATION OF THE R335 IN RELATION TO THE URBAN EDGE OF THE NELSON MANDELA BAY MUNICIPALITY ...... 48 FIGURE 8-9: CRITICAL BIODIVERSITY AREAS (CBA’S), AS DESIGNATED BY THE NMBM BRP (2014) THAT ARE INTERSECTED BY THE R335 ...... 50 FIGURE 8-10: THE SURFACE GEOLOGY OF THE PROPOSED MOTHERWELL TO ADDO UPGRADE [REF: BANZAI ENVIRONMENTAL (PTY) LTD PALAEONTOLOGICAL IMPACT ASSESSMENT, 2016] ...... 52 FIGURE 8-11: WETLANDS AND WATERCOURSES WITHIN THE GREATER DEVELOPMENT FOOTPRINT ...... 53 FIGURE 8-12: TRAFFIC ACCOMMODATION METHODS FOR KM5.16 TO KM22.3 ...... 61 FIGURE 8-13: TRAFFIC ACCOMMODATION METHODS FOR KM22.3 TO KM38.400 ...... 62 FIGURE 8-14: TRAFFIC ACCOMMODATION MEASURE TYPES A TO C AS LISTED IN THE LEGEND OF FIGURE 8-10 .... 63 FIGURE 8-15: TRAFFIC ACCOMMODATION MEASURE TYPES D AND E AS LISTED IN THE LEGEND OF FIGURE 8-12 .. 64 FIGURE 8-16: ALTERNATIVE ROAD FOR STOP/GO ALLEVIATION ...... 65 FIGURE 9-1: THE LOCATION OF THE NFEPA WETLANDS ALONG THE SOUTHERN SECTION OF THE ROAD ALIGNMENT ...... 66 FIGURE 9-2: THE LOCATION OF THE NFEPA WETLANDS ALONG THE CENTRAL SECTION OF THE ROAD ALIGNMENT 67 FIGURE 9-3: THE LOCATION OF THE NFEPA WETLANDS ALONG THE NORTHERN SECTION OF THE ROAD ALIGNMENT ...... 67 FIGURE 10-1: A COPY OF THE NEWSPAPER ADVERT PLACED IN THE DAILY DISPATCH ON 12/01/2018 ...... 86 FIGURE 10-2: A COPY OF THE SITE NOTICE PLACED ALONG THE EXISTING R335 FOOTPRINT...... 88 FIGURE 10-3: THE LOCATION OF THE FIVE SITE NOTICES PLACED ALONG THE R335 ALIGNMENT...... 89

TABLES

TABLE 1-1: CONTENT OF A BAR (2014 EIA REGULATIONS, AS AMENDED)...... III TABLE 2-1: DETAILS OF THE EAP ...... 2 TABLE 4-1: APPLICABLE LISTED ACTIVITIES IN TERMS OF NEMA (ACT 107 OF 1998) ...... 6 TABLE 4-2: APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES ...... 12 TABLE 5-1: CENTRE POINT CO-ORDINATES FOR THE SUNDAYS RIVER BRIDGE ...... 14 TABLE 5-2: CENTRE POINT CO-ORDINATES FOR THE COEGA RIVER BRIDGE ...... 14 TABLE 5-3: CENTRE POINT CO-ORDINATES FOR THE FIVE CULVERT STRUCTURES ...... 16 TABLE 5-4: CENTRE POINT CO-ORDINATES FOR THE THREE UNDERPASS STRUCTURES ...... 21 TABLE 5-5: PAVEMENT STRUCTURE ...... 22 TABLE 5-6: GEOMETRIC DESIGN CRITERIA ...... 23 TABLE 8-1: LANDUSE AS PER THE ROAD CHAINAGE ...... 54 TABLE 8-2: SOCIO-ECONOMIC INFORMATION FOR THE NMBM ...... 57 TABLE 8-3: SOCIO-ECONOMIC INFORMATION FOR THE SRVLM ...... 58 TABLE 8-4: JOB CREATION AND EXPENDITURE ASSOCIATED WITH THE DESIGN AND UPGRADING OF THE R335 ...... 58 TABLE 8-5: SUMMARY OF TRAFFIC ACCOMMODATION PLAN ...... 60 TABLE 9-1: DETAILS OF SPECIALIST ...... 65 TABLE 9-2: DETAILS REGARDING THE WETLANDS FOUND WITHIN A 500M RADIUS OF THE SITE ...... 66 TABLE 9-3: MITIGATION MEASURES ASSOCIATED WITH POTENTIAL IMPACTS ON WATER RESOURCES DURING THE CONSTRUCTION PHASE ...... 70 TABLE 9-4: DETAILS OF SPECIALIST ...... 73 TABLE 9-5: DETAILS OF SPECIALIST ...... 76 TABLE 9-6: DETAILS OF SPECIALIST ...... 78

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TABLE 9-7: SCC SPECIES IDENTIFIED WITHIN THE STUDY AREA ...... 79 TABLE 9-8: GPS CO-ORDINATES OF SPECIES OF SPECIAL CONCERN (SSC) AS PER THE BOTANICAL SURVEY ...... 80 TABLE 9-9: SENSITIVITY RATING CRITERIA ...... 80 TABLE 10-1: IAP / STAKEHOLDER COMMENTS RECEIVED BASED ON THE BACKGROUND INFORMATION DOCUMENT / SITE NOTICE / NEWSPAPER ADVERT ...... 94 TABLE 10-2: COMMENTS AND RESPONSES PROVIDED AT THE MOTHERWELL PUBLIC MEETING HELD ON 11 APRIL 2018 ...... 98 TABLE 11-1: INTERPRETATION OF THE SIGNIFICANCE SCORING OF A NEGATIVE IMPACT / EFFECT ...... 104 TABLE 11-2: RATING SCALE FOR THE ASSESSMENT OF THE SPATIAL EXTENT OF A PREDICTED EFFECT / IMPACT .. 105 TABLE 11-3: RATING SCALE FOR THE ASSESSMENT OF THE SEVERITY / MAGNITUDE OF A PREDICTED EFFECT / IMPACT ...... 106 TABLE 11-4: RATING SCALE FOR THE ASSESSMENT OF THE TEMPORAL SCALE OF A PREDICTED EFFECT / IMPACT 106 TABLE 11-5: RATING SCALE FOR THE ASSESSMENT OF LOSS OF RESOURCES DUE TO A PREDICTED EFFECT / IMPACT ...... 107 TABLE 11-6: RATING SCALE FOR THE ASSESSMENT OF REVERSIBILITY OF A PREDICTED EFFECT / IMPACT ...... 107 TABLE 11-7: RATING SCALE FOR THE ASSESSMENT OF THE PROBABILITY OF A PREDICTED EFFECT / IMPACT ...... 108 TABLE 12-1: CONSTRUCTION PHASE IMPACTS IDENTIFIED AND ASSOCIATED MITIGATION MEASURES ...... 110 TABLE 12-2: OPERATIONAL PHASE IMPACTS IDENTIFIED AND ASSOCIATED MITIGATION MEASURES ...... 120 TABLE 13-1: IMPACT ASSESSMENT FINDINGS IN RELATION TO THE PROPOSED CONSTRUCTION ACTIVITIES ...... 121

PLATES

PLATE 7-1: AN EXAMPLE OF THE R335, HEADING IN THE DIRECTION OF ADDO, ALONG WHICH NO SHOULDER IS AVAILABLE FOR STOPPING OR OVERTAKING ...... 30 PLATE 7-2: THE APPROACHES TOWARDS THE KUDU RIDGE PROPERTY, ALONG WHICH THE CENTRE LINE IS BEING REALIGNED (TO THE RIGHT OF THE IMAGE) TO AVOID THE WETLAND SYSTEM TO THE LEFT OF THE ROAD ...... 30 PLATE 7-3: THE APPROACHES TO THE SUNDAYS RIVE BRIDGE WHEN TRAVELLING FROM ADDO TO MOTHERWELL 31 PLATE 7-4: A DOWNSTREAM VIEW OF THE SUNDAYS RIVER BRIDGE ...... 32 PLATE 7-5: AN UPSTREAM VIEW OF THE SUNDAYS RIVER BRIDGE ...... 32 PLATE 7-6: THE APPROACHES TO THE COEGA RIVER RIDGE, WHEN TRAVELLING FROM ADDO TO MOTHERWELL ... 33 PLATE 7-7: A DOWNSTREAM VIEW OF THE COEGA RIVER BRIDGE ...... 34 PLATE 7-8: AN UPSTREAM VIEW OF THE COEGA RIVER BRIDGE AT THE POINT THAT THE NEW BRIDGE IS PROPOSED ...... 34 PLATE 7-9: AN EXAMPLE OF AN INTERSECTION OF THE R335 / W.M.MAKU / TUTU STREET ON THE PERIPHERY OF MOTHERWELL, WHICH WILL BE UPGRADED ...... 36 PLATE 8-1: VIEW OF THE URBAN LANDUSE (WITHIN MOTHERWELL) ALONG THE ROAD ALIGNMENT ...... 54 PLATE 8-2: VIEW OF THE BRICK FACTORIES ALONG THE ALIGNMENT ...... 55 PLATE 8-3: COEGA WINDFARM ALONG THE ALIGNMENT ...... 55 PLATE 8-4: VIEW OF THE LIVESTOCK AND GAME FARMS ALONG THE ALIGNMENT ...... 56 PLATE 9-1: SITE MR450-S1, THE SUNDAYS RIVER BRIDGE ...... 74 PLATE 9-2: SITE MR450-S7, THE COEGA RIVER BRIDGE ...... 75 PLATE 9-3: VIEW OF SITE MR450-S8 ...... 75 PLATE 9-4: EXAMPLES OF PROTECTED SPECIES ENCOUNTERED ALONG THE R335 ...... 80 PLATE 10-1: ATTENDEES AT THE MOTHERWELL PUBLIC MEETING HELD ON 11 APRIL 2018 ...... 85

APPENDICES

APPENDIX 1: EAP CV ...... 127 APPENDIX 2: APPLICATION FOR ENVIRONMENTAL AUTHORISATION FORMS ...... 128 APPENDIX 3: DEA PRE-APPLICATION MEETING MINUTES ...... 129 APPENDIX 4: ENGINEERING DESIGN DRAWINGS – ...... 130 APPENDIX 5: SPECIALIST REPORTS ...... 137 APPENDIX 6: ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR) ...... 145

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APPENDIX 7: PUBLIC PARTICIPATION PROCESS ...... 146 APPENDIX 8: NEM:BA GAZETTED PROTECTED AREAS LIST ...... 156

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1. INTRODUCTION

An Application for Environmental Authorisation and consequent Basic Assessment process for the upgrading of the R335 between Motherwell and Addo commenced in 2008. The project was granted Environmental Authorisation by the Eastern Cape Department of Economic Affairs, Environment and Tourism on 13/04/2011 (RoD Ref ECm1/386/M/08-138). The Record of Decision (RoD) was valid for a period of 12 months, during which time construction did not commence and as a result the RoD lapsed. Consequently, a new Application for Environmental Authorisation has been submitted and the Basic Assessment process has re-commenced.

The proposed project entails the upgrading of 32.0km of road from the intersection with the R334 (km 9.580) up to the Sunday’s river bridge (km 34.700). The horizontal alignment will be offset by 7m from the intersection with the R334 in Motherwell to the Sundays River Bridge. Thereafter the alignment returns to the existing centreline. The vertical alignment will be smoothed out along portions of the alignment to prevent sudden dips and rises in the road surface. As a result, substantial mass earthworks (cut and fill) on the existing road will be required. The road crosses the Coega and Sundays Rivers. The existing Coega River Bridge will be demolished and reconstructed on a new horizontal and vertical alignment close to the existing bridge. The resulting bridge width will be 14.35m, the road width will be 13.4m and the length of the bridge will be 25m. The Sundays River bridge will be reconstructed and widened. As it will be necessary to widen the deck the existing balustrades and sidewalks shall be demolished, and a duplicate bridge will be constructed alongside the existing structure in order to accommodate the wider road profile. The new deck will accommodate a road width of 13.4 m. Five existing culvert structures (Culverts B- F) will be expanded. The five in situ box culverts will be completed with inlet and outlet structures with 3 cell x 3400mm width x 3200mm height configuration. Two new culvert structures will be constructed along the alignment. Culvert A has a configuration of a 2-cell x 2400mm width x 2400mm height and Culvert G has a 2-cell x 2000mm width x 1800mm height. Two precast wildlife underpasses will be constructed along the R335 road. These culvert structures will have a 1-cell x 2400mm width x 2400mm height configuration.

Additional works include the construction of retaining walls, road and cross drainage, guardrails, signage, fencing, bus / taxi shelters and stops and road markings.

1 It is to be noted that the R335 is also referred to as the MR450 and that they are the same road. Whilst the majority of this document refers to the road as the R335, some of the specialist studies make reference to the MR450.

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As per GNR 982 of the Environmental Impact Assessment (EIA) Regulations (2014, as amended) a Basic Assessment (BA) Process must be undertaken in such a manner that the environmental outcomes, impacts and residual risks of the proposed Listed Activities being applied for are noted in the BAR and assessed accordingly by the Environmental Assessment Practitioner (EAP). In this regard, the requirements of the BA Process are noted in the EIA Regulations (2014, as amended), Listing Notice 1, Appendix 1 of GNR 982 and are consequently adhered to in this report (please refer to Table 1-1 of the Executive Summary). In this regard, this BAR focuses on the construction and decommissioning phase impacts and mitigation measures.

Ultimately, the outcome of the BA Process is to provide the Competent Authority, the Department of Environmental Affairs (DEA), with sufficient information to provide a decision on the Application in terms of Environmental Authorisation (EA), in order to avoid or mitigate any detrimental impacts that the activity may have on the receiving environment.

It is to be noted that the materials required for the construction phase of the upgrade will require an application for a Mining Permit in terms of the Mineral and Petroleum Resources Development Act (MPRDA, Act 28 of 2002) and the National Environmental Management Act (Act 107 of 1998) Environmental Impact Assessment Regulations (2014) as amended. This will include an application for two new borrow pits along the existing R335 road. In this regard it is noted that the Competent Authority in terms of Mining Right / Permit Applications is the Department of Mineral Resources (DMR). Therefore, the activities related to the Mining Permit have been assessed in a separate Application for Environmental Authorisation to be submitted to the DMR and have not been assessed further in this BAR.

2. DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)

Terratest (Pty) Ltd has been appointed by GIBB Engineering & Architecture (Pty) Ltd, on behalf of the South African national Roads Agency SOC Ltd (SANRAL), to undertake the environmental services required for the construction works associated with this Application. Details of the qualified EAPs involved in undertaking the BA Process are included in Table 2-1 and the Curriculum Vitae (CV) of the relevant EAP’s attached as Appendix 1.

Table 2-1: Details of the EAP

COMPANY: TERRATEST (PTY) LTD Qualifications & professional EAP Experience Contact details affiliations Mr M. van Rooyen BSc, BSc Hons, MPhil. 14 years Tel: (033) 343 6789 Executive Associate (Environmental Management), Email: Pr. Sci. Nat, IAIAsa [email protected] Ms I. Summers BSc. (Hons), MSc Environmental 7.5 years Tel: (033) 343 6789 Senior Environmental Science Email: [email protected] Consultant IAIAsa Mrs C. Coetzee BSc Honours (Zoology), MSc 5 years Tel: (041) 390 8730 Environmental Scientist (Zoology) Email: [email protected] IAIAsa, IWMSA

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3. LOCATION OF THE ACTIVITY

The proposed activity is located within Wards 23,53,54, 55 and 56 of the Nelson Mandela Bay Municipality and Wards 3 and 6 of the Sundays River Valley Local Municipality (Sarah Baartman District Municipality), between Motherwell (on the outskirts of Port Elizabeth) and Addo town, Eastern Cape Province.

The R335 is located within an existing SANRAL road servitude, which is 30m in width. Whilst the proposed upgrade will result in the centreline of the R335 being realigned along certain portions of the route, the realignment will partially fall within the SANRAL servitude. However, a total of fifty-one different land parcels, both municipal and private land will be affected by the proposed upgrade. The total additional area required for the road widening is 485 075.4m². Notification and consultation with municipal and private land owners, as well as relevant land acquisitions for the proposed upgrade is being undertaken as a separate process by GIBB Engineering & Architecture and LA Consulting Engineers. It is to be noted that all of these directly affected stakeholders have been notified of the proposed development and the availability of this Draft BAR for review and comment. The proposed development is not considered a like-for-like application as the project footprint is to be expanded on and new infrastructure is to be developed. Co-ordinates every 250m along the road alignments are provided in table 1 of Appendix 4. Landowner details and 21-digit Surveyor General (SG) code cadastral land parcels for all properties to be affected by the proposed upgrading are also provided in Table 2 of Appendix 4. Figure 3-1 and 3-2 illustrate the alignment of the R335 on topographical and aerial images.

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Figure 3-1: Locality map indicating the route of the existing R335 road between Motherwell and Addo

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Figure 3-2: An aerial image indicating the route of the existing R335 road between Motherwell and Addo [Ref: Google Earth, 2018]

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4. LEGAL CONTEXT

4.1 APPLICABLE LISTED ACTIVITIES

In terms of the Environmental Impact Assessment (EIA) Regulations (2014, as amended), promulgated in terms of the National Environmental Management Act (Act 107 of 1998 (NEMA), certain Listed Activities are specified for which either a Basic Assessment (GNR 983 and GNR 985) or a full Scoping and EIA (GNR 3984) is required.

The following Listed Activities in Government Notice 983 (Listing Notice 1) and Government Notice 985 (Listing Notice 3) are applicable to the proposed development:

Table 4-1: Applicable Listed Activities in terms of NEMA (Act 107 of 1998) LISTING NOTICE LISTED ACTIVITY AND TRIGGER AS PER THE PROJECT DESCRIPTION & ACTIVITY GNR 983 “The infilling or depositing of any material of more than 10 cubic meters into, or the dredging, (Listing Notice 1), excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 10 as amended: cubic meters from – Activity 19 (a) A watercourse;”

- Construction of the new Coega River Bridge and new culverts as well as the expansion of the existing Sundays River Bridge and existing culverts will require the excavation and removal of material from the various watercourses. As the cumulative volume of material to be excavated from the watercourses is anticipated to be 3000 m³, this Listed Activity is triggered. See Section 5.2 of this report for further details.

GNR 983 “The clearance of an area of 1 hectares or more, but less than 20 hectares of indigenous (Listing Notice 1), vegetation, except where such clearance of indigenous vegetation is required for- as amended: (i) the undertaking of a linear activity…” Activity 27 - It is to be noted that whilst this exclusion applies to the upgrading of the R335 road, it does not apply to the proposed bridge and culvert structures, site camps and stockpile areas. As such, it is anticipated that cumulatively, in excess of 1ha of indigenous vegetation will be cleared during the construction process and as such this Listed Activity is triggered. GNR 983 “The decommissioning of existing facilities, structures or infrastructure for – (Listing Notice 1), (i) any development and related operation activity or activities listed in this Notice, Listing as amended: Notice 2 of 2014 or Listing Notice 3 of 2014…” Activity 31 - A new Coega River Bridge will be constructed adjacent to the existing bridge structure. Once construction is completed, the ‘old’ bridge will be decommissioned and demolished and would trigger Activity 19 (of LN1) and Activities 12 and 14 (of LN3) if it was to be constructed. As such, this Listed Activity for the decommissioning of this structure is triggered. GNR 983 “The expansion of – (Listing Notice 1), (i) infrastructure or structures where the physical footprint is expanded by 100 square metres as amended: or more;

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Activity 48 Where such expansion occurs- (a) within a watercourse; (c) if no development setback exists, within 32 metres of a watercourse, measured from the edge of a watercourse…”

- The cumulative expansion of the Sundays River Bridge and culvert structures will exceed 100m² and will occur within watercourses, as well as within 32m of watercourses. As such, this Listed Activity is triggered. GNR 983 “The widening of a road by more than 6 metres, or the lengthening of a road by more than 1 (Listing Notice 1), kilometre- as amended: (i) where the existing reserve is wider than 13.5 metres…” Activity 56 - The proposed upgrading of the R335 road will exceed a road widening width of 6 metres and has a reserve of 30 metres (a maximum total road width of 13.4m applies) and as such this Listed Activity is triggered. GNR 985 (Listing “The clearance of an area of 300 square metres or more of indigenous vegetation except Notice 3), as where such clearance of indigenous vegetation is required for maintenance purposes amended: undertaken in accordance with a maintenance plan. Activity 12 a. Eastern Cape i. Within any critically endangered or endangered ecosystem listed in terms of section 52 of NEMBA or prior to publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004…”

- The alignment of the R335 at the Coega River Bridge passes directly through what is characterised as Albany Alluvial Vegetation, which has an endangered status as per SANBI status. The construction of the new Coega River Bridge is anticipated to require the clearing of in excess of 300m², and as such this Listed Activity is triggered. GNR 985 (Listing “The development of – Notice 3), as (ii) infrastructure or structures with a physical footprint of 10 square metres or more; amended: where such development occurs – Activity 14 (a) within a watercourse; (c) …within 32 meters of a watercourse, measured from the edge of the watercourse; excluding the development of infrastructure or structures within existing ports or harbours that will not increase the development footprint of the port or harbour. (a) In Eastern Cape: i. Outside urban areas, in: (aa) A protected area identified in terms of NEMPAA, excluding conservancies; (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.”

- The footprint of the Coega River Bridge, within the Coega River, proposed to be demolished and reconstructed, will exceed the 100m² footprint. In addition, new drainage culverts will be established along the upgraded alignment. The majority of the proposed development will occur outside an urban area (see Figure 8-7 showing the Urban Edge, as per the NMBM).

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- A section of the R335 bisects the Tregathlyn Game Farm, listed on the DEA Screening Tool as a Protected Area. Within this portion of the alignment, one new culvert (Culvert A) is to be constructed with a footprint of 23.04m² (4.8m x 4.8m). The construction of Culvert G, a new culvert, falls within 7.6km of the Addo Elephant National Park and has a footprint of 12.96m² (3.6m x 3.6m). Based on these factors this Listed Activity is triggered. GNR 985 (Listing “The widening of a road by more than 4 metres, or the lengthening of a road by more than 1 Notice 3), as kilometre. amended: (a) Eastern Cape: Activity 18 i. Outside urban areas: (aa) A protected area identified in terms of NEMPAA, excluding conservancies; (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; (kk) A watercourse…”

- The proposed upgrading of the R335 will involve the widening of the road by more than 4m and the majority of the proposed site falls outside the urban area (see Appendix 6 showing the Urban Edge, as per the NMBM). The proposed site falls within 5 km from the Grassridge Private Nature Reserve, and within 10 km from the Addo Elephant National Park. In addition, the road traverses the Sundays and Coega Rivers as well as unnamed watercourses at which the culverts will be constructed. This Listed Activity is therefore triggered. GNR 985 (Listing “The expansion of – Notice 3), as (ii) infrastructure or structures where the physical footprint is expanded by 10 square metres amended: or more; Activity 23 where such expansion occurs – (a) within a watercourse; (c) if no development setback has been adopted, within 32 meters of a watercourse, measured from the edge of the watercourse; … (a) In Eastern Cape: i. Outside urban areas: (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.”

- The bridge crossing the Sundays River will be expanded by more than 910m² (130m x 7m). In addition Culverts C, D, E and F will all be expanded (each having a footprint of 34.68m² (10.2m x 3.4m). The proposed sites fall within 5 km from the Grassridge Private Nature Reserve, and within 10 km from the Addo Elephant National Park. In addition, the road traverses the Sundays and Coega Rivers as well as unnamed watercourses at which the culverts will be constructed. This Listed Activity IS therefore triggered.

Based on the above proposed activities, a Basic Assessment (BA) Process is required. The associated Environmental Authorisation (EA) Application form is attached to this Report as Appendix 2 and an organogram of the BA Process is provided in Figure 4-1 for reference purposes.

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4.2 DEA PRE-APPLICATION MEETING

A Pre-Application Meeting was held with Ms Adika Rambally and Mr Mahlatse Shubane of the Department of Environmental Affairs, and Mrs Cherize Coetzee and Ms Imke summers of Terratest (Pty) Ltd. The attendance register and meeting minutes are attached as Appendix 3. The purpose of the Pre-Application Meeting was to introduce the project to the DEA, present and confirm the relevant Listed Activities and Specialist Studies pertinent to the proposed development as well as any additional information to be included in the BAR.

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Figure 4-1: Basic Assessment Process Organogram

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4.3 NATIONAL WATER ACT (ACT 36 OF 1998)

As per the National Water Act (Act 36 of 1998), should an activity require a water use, as defined in Section 21 of the Act, a Water Use Licence or a General Authorisation registration will be required prior to the activity being undertaken. The Competent Authority in this regard is the Department of Water and Sanitation. Water uses, in terms of Section 21 of the Act include: 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.

Terratest (Pty) Ltd has been appointed to undertake the necessary processes required to register the applicable water uses for the project. In this regard, based on the water uses proposed, a General Authorisation Registration would be required in terms of Section 39(1) of the National Water Act (Act 36 of 1998), Notice 509 of 2016. The following water uses are applicable:

• Section 21(c): Impeding or diverting the flow of water in a watercourse; and • Section 21(i): Altering the bed, banks, course or characteristics of a watercourse.

The above water uses are associated with the upgrading, expansion and reconstruction of the Coega and Sundays River Bridges, the two new culvert structures to be established and the five culvert structures which will be expanded.

4.4 APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES

Table 4-2 provides a list of all the applicable legislation, policies and/or guidelines of any sphere of government that are relevant to the application as contemplated in the EIA Regulations (2014, as amended).

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Table 4-2: Applicable legislation, policies and/or guidelines

TITLE OF LEGISLATION, POLICY OR GUIDELINE: ADMINISTERING AUTHORITY: DATE:

Conservation of Agricultural Resources Act, 1983 (Act 43 of 1983) National Department of 1983 – for protection of agricultural resources and for control and Agriculture removal of alien invasive plants

Environmental Conservation Act (Act 73) – for potential Department of Environmental 1989 environmental degradation Affairs

National Environmental Management Act (Act 107 of 1998) – for Department of Environmental 1998 its potential to cause degradation of the environment (Section 28) Affairs

National Water Act (Act 36 of 1998) – for potential to cause Department of Water Affairs and 1998 pollution of water resources defined under the Act (Section 19 and Forestry 21)

The National Heritage Resources Act (Act No 25 of 1999 as Department of Arts and Culture 1999 amended) – for the identification and preservation of items of (Amafa KwaZulu-Natal) heritage importance

Occupational Health and Safety Act, 1993 (Act No. 85 of 1993): Department of Labour 2002 Asbestos Regulations, 2001

National Environmental Management: Biodiversity Act, 2004 (Act Department of Agriculture and 2004 10 of 2004) – for protection of biodiversity Environmental Affairs & Ezemvelo KZN Wildlife

Guideline 4: Public Participation in support of the EIA Regulations Department of Environmental 2006 (2005) Affairs and Tourism

Guideline 7: Detailed Guide to Implementation of the Department of Environmental 2007 Environmental Impact Assessment Regulations (2006) Affairs and Tourism

Environmental Conservation Act, 1989. Regulations for the Department of Environmental 2008 prohibition of the use, manufacturing, import and export of Affairs and Tourism asbestos and asbestos containing materials

Department of Environmental Affairs (2017), Public Participation Department of Environmental 2017 guidelines in terms of NEMA EIA Regulations Affairs, Pretoria, South Africa

Integrated Environmental Management Guideline; Guideline on Department of Environmental 2017 Need and Desirability (2017) Affairs, Pretoria, South Africa

Nelson Mandela Bay Municipality By-Laws Distriict Municipality Updated accordingly

Sundays River Valley Local Municipality By-Laws Local Municipality Updated accordingly

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5. DESCRIPTION OF THE ACTIVITY

5.1 PROJECT OVERVIEW

The R335 is an existing surfaced regional road that runs in a north – south direction2. The R335 tees off the N2 on the periphery of the town of Port Elizabeth and proceeds through Motherwell. At approximately km 9.2 Motherwell ends, and the R335 proceeds past private game farms, agricultural lands and past citrus farms towards and through Addo town. The southern limit of construction is at km 5.60, which is approximately 170 metres north of WM Maku Street in the heart of Motherwell. The northern limit is at km 37.60, which is on the southern boundary of the Addo CBD. The total length of the road upgrade is 32 km. A minimum road reserve of 30 m (15 m either side of the centre line) will be observed. In certain instances, the road reserve has to be extended for a minimum of three meters where the toe lines of the fills or the shoulder lines of the cuts pass beyond the road reserve.

The R335 serves as an important link to the Sunday’s River Valley area, Addo Elephant National Park and Port Elizabeth. The road is a vital transport route between the citrus farming region in close proximity to Addo, and the city of Port Elizabeth. In addition, PPC Cement Ltd has a major cement mining and manufacturing plant along the R335 due to the area being a major calcrete source. Tourists visiting the Addo Elephant Park and the Sunday’s River Valley Area also use the R335 seasonally. At present, the road consists of a single carriageway road (6m in width, 3m per lane), with no shoulder or overtaking lanes. In addition, the road has a varied, unsafe vertical alignment. In light of the busy nature of the route, as well as its importance as an agricultural, tourism and material sources transport route, an upgrading of the road is proposed.

5.2 PROJECT DESCIPTION

5.2.1 Design Details1

The proposed development entails the upgrading of the R335 road surface, the realignment (vertical and horizontal) of certain portions of the road, the upgrading and construction of hydraulic structures, the establishment of road drainage, the establishment of underpasses, the establishment and upgrade of intersections and the establishment of road furniture.

a. Sundays River Bridge The existing bridge on the Sundays River (located at km34.80) is to be reconstructed and widened. The existing bridge is a three-span, reinforced concrete fixed arch structure with spandrel walls. The spans are each 31.39m in length and the total bridge length is 118.6m. The substructure is reinforced concrete and is based on spread footings. The bridge does not have a structural deck slab as the roadway has been constructed on fill contained between the spandrel walls and surfaced with asphalt. The existing balustrades and sidewalks are constructed on the fill and spandrel walls. As it will be necessary to widen the deck the existing balustrades and sidewalks shall be demolished and a duplicate bridge will be

2 Gibb (Pty) Ltd, 2018: Contract SCMU 10-06/07-138, For Improvement of National Route R335 Between Motherwell (Km5.600) and Addo (Km37.600): Executive Summary of the Detailed Assessment and Design Report, East London

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Table 5-1: Centre point co-ordinates for the Sundays River Bridge SOUTHERLY CO-ORDINATE EASTERLY CO-ORDINATE Sundays River Bridge 33° 34’ 52.75” S 25° 40’ 27.79” E

b. Coega River Bridge The Coega River Bridge will be demolished and reconstructed on a new horizontal and vertical alignment close to the existing bridge. The new bridge will have a road width of 13.4m. F-shaped concrete parapets will be placed along the outer edges of the bridge deck. The resulting bridge width will be 14.35m and the length of the bridge will be 25m, measured between the centroids of the abutments. The bridge will have a simply supported deck with two 12.5m spans, crossing the river at right angles. The bridge surface area is therefore equal to approximately 335m². Guardrails will be placed on the approach embankments. The upstream and downstream sides of the approach embankments will be protected by gabion mattresses and boxes. Consequently, the bridge will be upgraded from its present state i.e. a single lane per direction, with no road shoulder (total width of 8m), to a bridge with a single lane in each direction and a road shoulder (total width of 13.4m) and a longer deck. The ‘old’ Coega river bridge will remain in use until such time as the new bridge and road tie ins have been constructed. Once the new Coega River Bridge has been constructed and traffic has been diverted onto it, the old bridge will be decommissioned. It is to be noted that there are derelict abutments downstream of the existing bridge from a previous bridge structure. These are not associated with this application in any way.

Table 5-2: Centre point co-ordinates for the Coega River Bridge SOUTHERLY CO-ORDINATE EASTERLY CO-ORDINATE Coega River Bridge 33° 34’ 52.75” S 25° 40’ 27.79” E

See Figure 5-2 for an illustration of the General Arrangement of the Coega River Bridge, as well as Appendix 4 for the Engineering design drawing.

c. Decommissioning of the Coega River Bridge The decommissioning of the old bridge structure will include the following: • Road closures will be put in place which will divert traffic over the newly constructed bridge; • The existing bridge deck will then systematically be demolished. It is anticipated that support work will be constructed under the bridge deck in order to support the existing deck while it is being demolished; • The demolition of the bridge will be the reverse of the construction process i.e. top down removal; • Rubble will be removed to a designated quarry where it will be re-purposed as concrete stone or used as fill for rehabilitation purposes; • The concrete abutments will remain in place to limit any further construction activities within the watercourse.

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Figure 5-1: Proposed widening of the Sundays River Bridge

Figure 5-2: The General Arrangement of the Coega River Bridge

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d. Infilling and depositing material within a watercourse Only the foundations of the bridges will be constructed within the water course. Drilling will indicate at which depth the bridge foundations will be constructed and this will affect the volume of material to be removed. The footprint per base should not exceed 20 x 5m (100m²) and it is anticipated that the bases will be constructed at an approximate depth of 5m. Three foundations are proposed for the Sundays River Bridge and two foundations are proposed for the Coega River Bridge. Approximately 3000 m³ (100 x 5 x (3+2)) of material will be cumulatively removed from the water course. Approximately 80% of this material will be rocky hard material and all topsoil will be stockpiled for re-use.

e. Culvert Structures The construction / expansion of seven major in situ box culverts complete with inlet and outlet structures of which 2 major culverts are located on intersecting roads a short distance from the R335; • Culvert A (new culvert), at km26 – 2 cell x 2.4m wide x 2.4m high on the DR01958 at km 0.120 • Culvert B (upgrading and expanding existing culvert), at km27.12 – 3 cell x 3.4m wide x 3.2m high on the R335 at km 27.120 • Culvert C (upgrading and expanding existing culvert), at km28.83 – 3 cell x 3.4m wide x 3.2m high on the R335 at km 28.825 • Culvert D (upgrading and expanding existing culvert), at km29.305 – 3 cell x 3.4m wide x 3.2m high on the R335 at km 29.305 • Culvert E (upgrading and expanding existing culvert), at km30.760– 3 cell x 3.4m wide x 3.2m high on the R335 at km 30.730 • Culvert F (upgrading and expanding existing culvert), at km32.327 – 3 cell x 3.4m wide x 3.2m high on the R335 at km 30.730 • Culvert G (new culvert), at km30 - 2 cell x 1.8m wide x 2 m high on the MN50267 at km 0.08

Culvert A is positioned on District road DR01958 and Culvert G is positioned on the MN50267, a district roads which link on to the R335. These roads flood on a regular basis and would cause the R335 to flood if culverts were not provided. The culverts have to be constructed in order for the drainage basin to continue functioning as it currently does. See Table 5-3 for GPS co-ordinates of the culvert structures.

Table 5-3: Centre point co-ordinates for the five culvert structures CULVERT SOUTHERLY CO-ORDINATE EASTERLY CO-ORDINATE Culvert A 33° 36’ 56.29” S 25° 36’ 26.31” E Culvert B 33° 36’ 53.98” S 25° 36’ 30.49” E Culvert C 33° 36’ 10.41” S 25° 37’ 11.06” E Culvert D 33° 35’ 59.37” S 25° 37’ 21.64” E Culvert E 33° 35’ 29.10” S 25° 38’ 02.59” E Culvert F 33° 35’ 29.67” S 25° 39’ 04.21” E Culvert G 33° 35’ 24.51” S 25° 38’ 00.53” E

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See Figures 5-3 to 5-9 for illustrations of Culverts A - G. See Appendix 4 for the Engineering design drawings thereof.

Figure 5-3: Culvert A Layout Plan

Figure 5-4: Culvert B Layout Plan

Figure 5-5: Culvert C Layout Plan

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Figure 5-6: Culvert D Layout Plan

Figure 5-7: Culvert E Layout Plan

Figure 5-8: Culvert F Layout Plan

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Figure 5-9: Culvert G Layout Plan

f. Minor Culvert Structures The construction of minor precast box culverts complete with inlet and outlet structures.

g. Retaining Structures The construction of retaining structures (concrete and/or reinforced earth).

h. Vertical and Horizontal Realignment An offset alignment (i.e. centreline realignment) of 7m will be used for the horizontal alignment from the intersection with the R334 (km 9.58) up to the Sunday’s River Bridge (km 34.7) (See Figure 5-10). Thereafter the alignment returns to the existing centreline and the road is widened centrally in order to avoid affecting trees within the citrus farms up to km 37.6 just before entering the town of Addo.

The vertical alignment of the existing road is generally of a low standard and therefore the vertical alignment of the proposed road deviates substantially from that of the existing. As a result, substantial mass earthworks (cut and fill) on the existing road is envisaged. Batter slopes shall be constructed to a constant slope of 1 vertical and 1.5 Horizontal for all cut and fill conditions.

Guardrails combined with a concrete kerb and channel will generally be provided at all fills higher than 3,0 m and at retaining structures. The road profile width will remain at 13.4 m where guardrails are provided.

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Figure 5-10: An illustration of the existing centre line (yellow), proposed realigned centre line (red) and servitude footprint (purple) between km29.47 and km32.28 between Motherwell and Addo

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i. Wildlife Underpasses The construction of three precast culverts which will serve as wildlife underpasses to facilitate the safe movement of wildlife to either side of the road. Details of the underpasses are as follows: • Underpass No.1 crosses the R335 at km 28.14. Configuration is 1-cell x 2400mm width x 2400mm height. • Underpass No.2 crosses the R335 at km 33.320. Configuration is 1-cell x 2400mm width x 2400mm height. • Underpass No.3 crosses the R335 at km 28.02. Configuration is 1-cell x 2400mm width x 2400mm height. Wildlife underpasses were requested by the farm owners whose properties straddle the R335. At present, wildlife crosses the R335 to get to the Sundays River, as this is the only drinking water available to the animals. The animals are currently crossing the road in an uncontrolled manner by either jumping the fence or passing through a gate which is left open for them. The underpasses are therefore proposed to safeguard the animals and the road users alike. The underpasses have been designed in conjunction with the landowners and will cater for antelope, including Kudu, Sable, Springbok and Impala. No larger game is stocked on the farms.

Underpass 3 connects both sides of the Tregathlyn Game Farm which is bisected by the R335. The game farm is a Private Nature. See Table 5-4 for GPS co-ordinates of the underpass structures.

Table 5-4: Centre point co-ordinates for the three underpass structures SOUTHERLY CO-ORDINATE EASTERLY CO-ORDINATE Underpass No.1 33° 35’ 17.46” S 25° 39’ 35.63” E Underpass No.2 33° 35’ 16.90” S 25° 39’ 36.57” E Underpass No.3 33° 36’ 30.33” S 25° 36’ 51.06” E

Figure 5-11: A typical design of a single-cell culvert structure to be constructed for as a wildlife underpass

j. Road Drainage On-road drainage will achieved by a combination of the longitudinal grade and the cross fall of the road. The cross fall of the road will be increased to 2.5 % where the longitudinal grade falls below 1% and increased to 3% where the longitudinal grade falls below 0.5%. The stormwater will be collected in side

Page | 21 DBAR: R335 Upgrade, Motherwell to Addo 41643 drains, kerb and channel, concrete v drains or it will be allowed to run down embankments in the areas of low fill.

Drainage away from the road prism will include the construction of cut-off drains at the tops of high cuts in order to avoid water spilling down the embankment.

Subsoil drains will be installed to deal with groundwater in order to protect the lower road layers.

Across the road drainage will be achieved by introducing minor and major culverts or bridges in order to contain a storm with 1:50 year return period.

k. Major Intersections Intersections will be placed at intersections of numbered District or Main Roads and major industrial intersections that intersect with the R335 and are as followes:

• R 334 at km 9.2525 • DR01945 at 15.158 • PPC road at km 22.352 • DR01954 at km 22.956 • Poultry Farm Access at km 24.470 • DR01958 at km 27.024 Details of the intersection types are included in the Conceptual Transport Planning Study (Appendix 4).

l. Pavement Due to high traffic volumes and considerable uncertainty about traffic growth, the pavement design included in Tables 5-5 and 5-6 were used to guide the design and construction parameters. It is to be noted that a dual carriageway will be constructed along the urban Motherwell section of the upgrade (Figure 5- 11), and that a single carriageway is proposed for the rural section towards Addo (Figure 5-12).

Table 5-5: Pavement structure SURFACING 30 mm Asphalt in Motherwell, 20 mm Cape Seal in Rural areas

BASE 150 mm dense-graded unweathered crushed stone G1 base layer using material from approved off-site quarry

SUB-BASE 300mm C3 chemically stabilized gravel sub-base layers, (from approved borrow pits or from commercial)

UPPER SELECTED 150 mm G6 natural gravel selected layer

LOWER SELECTED 150 mm G7 natural gravel selected layer

ROADBED PREP As instructed by the Engineer

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Figure 5-12: Typical Dual Carriage way for the urban section within Motherwell (km5.6 to km9.3)

Figure 5-13: Typical Single carriageway for the rural section towards Addo (km9.43 to km 37.6)

Table 5-6: Geometric Design Criteria CRITERIA DESCRIPTION Stopping Sight Distance Design Speed Distance 80km/h 115m 90km/h 135m 100km/h 155m Minimum radius of Design Speed Radius horizontal curvature 80km/h 210m

90km/h 270m

100km/h 350m

Minimum Length of Curve 150 m Maximum Length of Curve 1000 m Maximum super-elevation 8% Minimum super-elevation Design Speed Radius Relative Slope Factor run-off length 80 60 200 100 68 230 120 77 260

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CRITERIA DESCRIPTION Location of super –elevation 1/3 of super-elevation run-off to be within the circular curve. run-off length Minimum K Values for Design Speed Crest Curves Sag Curves Vertical Curves 80 km/h 33 25 100 km/h 60 36 120 km/h 110 52 Minimum Lengths of Vertical Design Speed Length of Curve Curves 80 km/h 140 m 100 km/h 180 m 120 km/h 220 m Maximum Gradients As a guideline only Design Speed Rolling Mountainous 80 km/h 6% 7% 100 km/h 5% 6% 120 km/h 4% 5%

m. Roadworks Proposed roadworks will include: • Clearing and grubbing; • Removal of topsoil for widening of the road; • Roadbed preparation for widening of the road; • Bulk Earthworks (cut to fill or spoil); • Removal of existing road layer works to stockpile; • The construction of in-situ and imported layers; • The construction of a C3 stabilised subbase layer; • The construction of a crushed stone base bitumen (stabilised and unstabilised); and • Surfacing the road with a Cape Seal.

n. Ancillary Roadworks Proposed ancillary roadworks will include: • Construction of bus/taxi stops with shelters; • Fencing of the road reserve; • The provision of road markings; • The installation of road studs; • The installation of new road signs; • The erection of guardrails; • Topsoiling and grassing of cut and fill slopes; and • Finishing off the road reserve, spoil areas and borrow pits.

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o. General General construction related activities will include:

• Establishment of the contractor on site; • Provision of offices and housing for the Engineer as well as a shared laboratory that will be under the control of the Engineer; • Accommodation of traffic and the construction of deviations; • The opening and rehabilitation of borrow pits and quarries from which road construction materials will be sourced; • The maintenance of the existing road and/or deviations until the contract has been handed over to the Employer; and • Removal of site establishment.

p. Site Camp The location of the site camp is yet to be confirmed, and will be at the discretion of the contractor, should they choose to establish elsewhere. However, the engineers have recommended that a site camp be established at the PPC quarry as sufficient space is available for the contractors camp and it will be close to the quarry activities and equidistant to the various points of construction. The access road to the proposed site camp also separates the two portions of the property so the establishment could take place on the eastern side of the road while blasting3 is done on the western side of the road. Materials will be stockpiled at a central stockpile area within the designated borrow / quarry areas and will not be stored along the roadside.

6. DEVELOPMENT MOTIVATION

6.1 NEED

The need for the proposed upgrade can be summarised as follows:

• The R335 is a primary access and public transport route between Motherwell, the N2 and the Addo Elephant National Park which has sections that have deteriorated. The poor condition of the existing road can be attributed to natural wear and tear as well as the poor-quality materials used in its construction in excess of fifty years ago. As a result, this section of road needs to be reconstructed for most of its length; • The upgrading and realignment of certain portions will reduce wear and tear on vehicles utilising the road; • The operational phase of this activity will provide road users and communities of the surrounding areas with a much-needed improved and safer road; and

• The deck of the existing Coega River Bridge is presently not high enough, with residents in the area confirming that the bridge has over topped during high rainfall events. Consequently, in accordance with the design guidelines for bridges, a minimum freeboard is required. The route has

3 Please note that the blasting made reference to is in relation to the sourcing of materials from borrow pits. As noted, this is activity is being applied for through a separate authorisation process and different Competent Authority.

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now been classified as a Class 2 road4 and all structures must be designed to accommodate runoff from a storm with a 1:50 year reoccurrence. The current Coega river bridge does not comply with this requirement. As a result, a new bridge will be constructed adjacent to the existing one, and will be high enough to accommodate rainfall events with a 1:50 year occurrence, as well as being wide enough to accommodate the upgraded road.

6.2 DESIRABILITY

The desirability for the proposed upgrade can be summarised as follows: • The lack of appropriate road infrastructure has a negative impact on overall service delivery. The improved standard of the road surface will add value to the various industries (agricultural, construction/ brick-making, tourism) relying on this road to transport their produce and goods; • An upgraded transport network reduces road user costs, costs of maintenance and capital costs; • Socio-economic benefits would include the expected provision of 275 employment opportunities for both skilled and unskilled staff to the value of R70 million, and an annual turnover to be generated as a result of the project, in excess of R 150 million; • It is anticipated that the majority of the unskilled labour will be sourced from the local communities; • The jobs created during the upgrading of the R335 will be short to medium term and associated with the design and construction phase of the development. However, the jobs created will leave behind a legacy of up-skilled and trained work force that is able to trade their acquired new skills wherever opportunities arise; • Opportunity for local construction contractors and associated local community enterprises to gain temporary economic benefits from the construction phase; and • The upgrading of the R335, and associated establishment of the wildlife underpasses will protect road users and wildlife alike as the animals will no longer have to cross the R335 road, but can instead use the underpasses for safe crossing.

6.3 PLANNING CONTEXT

6.3.1 National Development Plan5

A critical action within the National Development Plan for 2030 is as follows: “Public infrastructure investment at 10 percent of gross domestic product (GDP), financed through tariffs, public-private partnerships, taxes and loans and focused on transport, energy and water.” The proposed upgrading of the R335 seeks to pursue this vision by providing safe, more easily accessible and direct transport infrastructure.

4 Gibb (Pty) Ltd, 2018: Contract SCMU 10-06/07-138, For Improvement of National Route R335 Between Motherwell (Km5.600) and Addo (Km37.600): Executive Summary of the Detailed Assessment and Design Report, East London 5 National Planning Commission, 2012: National Development Plan 2030: Executive Summary https://www.gov.za/sites/default/files/Executive%20Summary-NDP%202030%20-%20Our%20future%20- %20make%20it%20work.pdf Accessed: 22/10/2018

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6.3.2 NMBM Comprehensive Integrated Transport Plan: 2011/126

The vision and objectives of the NMBM Comprehensive Integrated Transport Plan are to “manage and provide efficient, safe, affordable, sustainable and accessible multi-modal transport services and infrastructure which promotes integrated land use development and ensures optimal mobility for the residents and users of the transport system in the metropolitan area” (Pg 10, NMBM CITP). Roads are consequently a fundamental and integral element within the CITP transport infrastructure system as they ensure accessibility to the whole of the transport network as well as promoting the mobility of people and goods. Roads therefore play the primary role in meeting transport demands in South Africa as a large portion of bulk freight transport and passenger movements take place by road. In this regard, the NMBM has the responsibility to plan, permit, design, construct, operate, manage and maintain an adequate road network in its area of jurisdiction to ensure sustainable growth. To this end, the R335, defined as an Existing Freight Route, requires maintenance to ensure that the level of service required by road users within the public and private sector, is maintained.

6.3.3 NMBM Metropolitan Spatial Development Framework7

The Metropolitan Spatial Development Framework (MSDF) is a plan outlining the desired spatial development of the metropolitan area as contemplated in the Spatial Planning and Land Use Management Act, 2013 (SPLUMA). In this regard, the MSDF highlights ‘Corridors and Accessibility’ as a key point of focus to achieve restructuring, integration and sustainability.

Further, the MSDF notes that the Addo Elephant National Park is one of the key tourist attractions (with both local and international tourists) at the borders of the NMBM and the adjacent Sundays River Valley Municipality (SRVM). It is therefore critical to ensure that there is social, spatial and economic integration between NMBM and the SRVM. The R335 is key in unlocking development at the border of these two Municipalities. However, the section of the R335 after the Motherwell Depot to the Elephant Park’s main gate is in poor condition. The implications for the MSDF are that of ensuring that there is a tourism linkage between the Addo Elephant Park and NMBM. Furthermore, the MSDF encourages linkages in terms of road infrastructure to the agricultural holdings in the hinterland that contribute to the economic growth and development of the region, in terms of agricultural produce and shipping services. The upgrading of the R335 therefore realises and enhances tourism potential within the NMBM and adjacent SRVM, as well as the agricultural potential of the surrounding region.

6.3.4 NMBM Integrated Environmental Policy8

The Integrated Environmental Policy (IEP) outlines the vision, priorities and commitments of the Nelson Mandela Bay Municipality (NMBM), in respect of the management of the environment in the area of its jurisdiction. The NMBM is floristically extremely diverse, being located in the eastern extreme of the Cape Floral Kingdom. Dominant vegetation biomes include Fynbos and Sub-tropical Thicket. Regrettably,

6 SSI Engineers and Environmental Consultants (2011): Final Comprehensive Integrated Transport Plan 2011/12 http://www.nelsonmandelabay.gov.za/datarepository/documents/OxuM7_CITP%20Report%20Final%20- 2011%20-%20Chapter%201%20-4.pdf Accessed: 22/10/2018 7 Department of Strategic Planning and Economic Development (2015): Nelson Mandela Bay Metropolitan Municipality Spatial Development Framework 2015. http://www.nelsonmandelabay.gov.za/datarepository/documents/msdf- 2015-final-document-nmbm.pdf Accessed: 22/10/2018 8 Nelson Mandela Bay Municipality Integrated Environmental Policy (IEP), 2012 http://www.nelsonmandelabay.gov.za/datarepository/documents/4e9Cd_IEP%20for%20NMBM.pdf Accessed: 23/05/2018

Page | 27 DBAR: R335 Upgrade, Motherwell to Addo 41643 approximately one third of the natural environment has already been lost due to urban expansion, cultivation, overgrazing, mining and alien plant infestation and hence there is a strong need to correctly conserve and manage the remaining environment. Fauna is well represented both on and off-shore and the value of this diversity cannot be over emphasised, nor can the importance of conservation thereof. It is therefore imperative that the impacts identified, and mitigation measures provided in the site-specific Environmental Management Programme (EMPr) are strictly adhered to during the construction phase of the proposed development.

6.3.5 SRVM Socio-Economic Review9

The provincial priorities for 2017/18 have been pronounced as a) Small town revitalization, b) Local economic development, c) Integrated Human Settlements and d) Improved roads network infrastructure. The upgrading of the R335, whilst not a function of the SRVM, will assist in realising the priority that is improved road networks infrastructure within the Local Municipality. The Addo Elephant National Park and citrus production are two important economic drivers in the Sundays River Valley Municipality. To ensure the longevity of these economic drivers, efficient and safe transport networks are required which is what the upgrading of the R335 will contribute to.

6.3.6 SRVM IDP10

The IDP notes that with regards to the SRVM’s Department of Rural Development and Land Reform, a Priority Issue is SMME beneficiation on the construction of R335 road. This will be realised through construction related appointments of skilled / unskilled community members within the SRVM. Ecotourism is another driving force of the local economy; To ensure the continued increase in these numbers, a suitable road network for travel to the park is required, which the upgrading of the R335 will provide.

7. MOTIVATION FOR THE PREFERRED SITE, ACTIVITY AND TECHNOLOGY ALTERNATIVE

The proposed development triggers Listing Notice 1 (GNR 983), Activities 19, 27, 30, 31, 48, 56 and Listing Notice 3 (GNR 985), Activities 12, 14, 18 and 23 of the EIA Regulations, (2014, as amended).

As per GNR 982, Appendix 1(2)(b), alternatives for the proposed development are to be identified and considered. Chapter 1 of the EIA Regulations (2014, as amended) provides an interpretation of the word “alternatives”, which is to mean “in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to the - a) Property on which or location where the activity is proposed to be undertaken; b) Type of activity to be undertaken; c) Design or layout of the activity;

9 ECSECC, 2017: Sundays River Valley Local Municipality Socio Economic Review and Outlook (2017) https://www.ecsecc.org/documentrepository/informationcentre/sundays-river-valley-local- municipality_35214.pdf Accessed: 22/10/2018 10 Sundays River Valley Municipality: Final Integrated Development Plan (IDP) 2017/18 http://mfmamirror.s3.amazonaws.com/Documents/01.%20Integrated%20Development%20Plans/2017- 18/02.%20Final/02.%20Local%20municipalities/EC106%20Sundays%20River%20Valley/EC106%20Sundays %20River%20Valley%20Final%20IDP%202017-18.pdf Accessed: 22/10/2018

Page | 28 DBAR: R335 Upgrade, Motherwell to Addo 41643 d) Technology to be in the activity; or e) Operational aspects of the activity; And includes the option of not implementing the activity.” Based on the above, the following alternatives are presented for the proposed upgrading of the R335 from Motherwell to Addo.

7.1 PREFERRED SITE ALTERNATIVE

Road infrastructure is developed based on a demand / supply basis. The initial R335 road infrastructure was developed in order to provide access for the farming community to distribute goods to the harbour in Port Elizabeth. Over the years, whilst the road and associated infrastructure has been maintained, the road has deteriorated. Once the road reaches a point where the maintenance will become too costly (typically when it exceeds R2.5 m / km to maintain) a decision is taken to rehabilitate it. This decision is made by the Client. In the case of the R335 the decision was taken by the Department of Roads and Public Works (who were responsible for the road at the time of the decision-making). SANRAL then took over the management of the road including the maintenance of it and came to a similar decision that the road must undergo rehabilitation in order to suit its intended function.

A Highway and Development Model 4 (HDM4) analysis (see Appendix 4) was undertaken in which the cost / benefit ratio of a proposed development was determined. The HDM4 analysis is based on the length of road and takes items into consideration such as the amount of traffic contributing to the economy, delays, accidents, time saving due to shorter routes etc. As the road is presently sub-standard according to SANRAL standards, a major upgrade of the road is required. In addition, the road has been classified as a Class 2 road by SANRAL and all infrastructure must therefore comply. The findings of the HDM4 model confirmed that the proposed development was also financially feasible.

As the proposed development is the upgrading of an existing regional road, no site alternatives have been considered as this would entail the construction of a completely new road alignment which is not reasonable or feasible. In addition, the existing R335 is a vital transport route for the citrus farming region, the cement mining and manufacturing plants and the tourism industry. At present, the road consists of a single carriageway road (6m in width, 3m per lane), with no shoulder or overtaking lanes. In addition, the road has a varied, unsafe vertical alignment. In light of the busy and important nature of the route, the upgrading of the existing road is proposed. As such the existing R335 is the only site alternative considered within this assessment report.

7.2 PREFERRED LAYOUT ALTERNATIVE

7.2.1 Road Alignment

As a directive from SANRAL at the commencement of the planning phase of the proposed road upgrade, it was stated that bi-directional traffic accommodation had to be maintained. In order to facilitate this a 7m offset from the existing alignment was used. This implies that traffic may be accommodated as part of the construction process. This approach was applied where feasible, in some areas additional property was required to ensure that the minimum 30m road reserve is achieved. The road returns to the existing alignment and is widened centrally just after the Sunday’s River bridge. This has been done to minimise the

Page | 29 DBAR: R335 Upgrade, Motherwell to Addo 41643 impact on the existing citrus farms. Widening the road centrally means that no orange trees will be destroyed, and internal farm access roads remain as they are.

The upgrading and realignment of the R335 road alignment took many factors into account, including engineering and design standards and requirements, road safety standards, existing infrastructure, economic factors, environmental sensitivities, heritage and palaeontological sensitivities, material sources, hydrological flows etc. What was produced was the Preferred Road Alignment Layout (see Figure 3-1 and 3-2 as well as Appendix 4). In addition, as this is the upgrading of an existing alignment, no other layout alternatives were provided. See Plates 7-1 and 7-2 for an illustration of the infrastructure along the R335.

Plate 7-1: An example of the R335, heading in the direction of Addo, along which no shoulder is available for stopping or overtaking

Plate 7-2: The approaches towards the Kudu Ridge property, along which the centre line is being realigned (to the right of the image) to avoid the wetland system to the left of the road

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7.3 PREFERRED TECHNOLOGY ALTERNATIVE

7.3.1 Sundays River Bridge

The height of the existing Sundays River Bridge complies with relevant safety and hydraulic standards, and as such the existing structure will remain. However, the present bridge structure is too narrow and requires widening to accommodate the upgraded and widened R335 road profile. As the Sundays River bridge is a national heritage site, adding to it was the preferred option as the alternative would mean to abandon a functional bridge simply because it is not wide enough. Widening it is therefore a practical cost-effective solution. In addition, the bridge does not have a structural deck slab as the roadway was constructed on fill contained between the spandrel walls and surfaced with asphalt. The existing balustrades and sidewalks were constructed on the fill and spandrel walls. The existing bridge is still structurally sound, functional and architecturally pleasing. The proposed widening of the bridge will incorporate the existing bridge architecture and building elements in order to provide the required road widths. As it will be necessary to widen the deck, the existing balustrades and sidewalks shall be demolished and a duplicate bridge will be constructed alongside the existing structure in order to accommodate the wider road width of 13.4km. The layout provided in Figure 5-1 as well as Appendix 4 has been produced through extensive design input from the engineering team and is based on safety requirements, the receiving environment and the widening of the R335. This has consequently produced the preferred and only layout alternative for the Sundays river Bridge and therefore, no other layout alternatives have been provided for the crossing of the Sundays River. Please see Plates 7-3 to 7-5 for an overview of the receiving environment associated with the Coage River Bridge.

Plate 7-3: The approaches to the Sundays Rive Bridge when travelling from Addo to Motherwell

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Plate 7-4: A downstream view of the Sundays River Bridge

Plate 7-5: An upstream view of the Sundays River Bridge

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7.3.2 Coega River Bridge

At present, the Coega River Bridge provides the only crossing point over the Coega River, along the R335. The existing Coega River bridge is not high enough and overtops periodically during high flow events. This consequently does not comply with the design guidelines for bridges and a minimum freeboard is therefore required. Widening the bridge could have potential risks for road users and as such the bridge has to be raised in height as well. As the route has now been classified as a Class 2 road, all structures must be designed to accommodate runoff from a storm with a 1:50 year reoccurrence. The current Coega River bridge does not comply with this requirement. To ensure the continued flow of traffic throughout the construction process, as well as to accommodate the safety requirements required for a Class C road (see Section 6.2), a new bridge structure has been proposed adjacent to the existing Coega River Bridge. The layout provided in Figure 5-2 as well as Appendix 4 has been produced through extensive design input from the engineering team and is based on safety requirements, the receiving environment and the realigned centre line of the R335. This has consequently produced the preferred and only layout alternative for the Coega River and therefore, no other layout alternatives have been provided for the crossing of the Coega River. Please see Plates 7-6 to 7-8 for an overview of the receiving environment associated with the Coega River Bridge.

Plate 7-6: The approaches to the Coega River ridge, when travelling from Addo to Motherwell

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Plate 7-7: A downstream view of the Coega River Bridge

Plate 7-8: An upstream view of the Coega River Bridge at the point that the new bridge is proposed

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7.3.3 Culvert Structures

All of the existing culvert structures are sub-standard and cannot simply be lengthened. All of the major culverts will have to be upgraded as their current capacity does not comply with the minimum drainage requirements for a Class 2 road (which the R335 is being classed as by SANRAL). All culvers must be able to accommodate a Q2t flood (1:20 year flood = t equivalent 1:40 year flood = Q2t). None of the existing culverts presently have sufficient capacity to deal with a flood of this size and are regularly over topped. In certain instances, the existing culverts comprise of 600 mm pipes and therefore need to be replaced with structures that can accommodate a Q2t flood.

The layouts provided in Figures 5-3 to 5-9 as well as Appendix 4 have been produced through extensive design input from the engineering team and are based on safety requirements, the receiving environment and the realigned centre line of the R335. This has consequently produced the preferred and only layout alternatives for the culvert structures and therefore, no other layout alternatives have been provided.

7.3.4 Underpasses

The design of the underpass should be able to accommodate the anticipated user. In this regard, the accepted general height of the animals using the underpass (e.g. Kudu, Sable, Impala etc.) was taken into account. Input was provided by the landowner who had requested the wildlife underpass. In addition, to allow human and vehicular use of the underpass, and in accordance with building regulations, a minimum ceiling height of 2.4m was used as the soffit of the underpass will effectively act as a ceiling. The width of the underpass is 2.44m allowing sufficient width for a vehicle to pass. This width will also allow animals to pass through side by side.

The above design criteria and needs of the underpass were taken into consideration in the engineering design of the wildlife underpasses. As the design complies with the various needs of the underpass, no other alternatives were considered. Therefore, the design provided (see Figure 5-11 and Appendix 4) is the preferred wildlife underpass alternative.

7.3.5 Interchanges

Intersection analyses were performed using the SIDRA 3.2 and HCS2000 computer programmes11 for the following main intersections: • R335 (MR450) / W.M.Maku Street / Tutu Street • R335 (MR450) / R334 • R335 (MR450) / DR 01945 • R335 (MR 450) / DR01954 • R335 (MR450) / DR01958 • R335 (MR450) / Addo Heights Road (DR01971)

11 Department of Roads and Transport Eastern Cape, 2008: Upgrading of the R335 between Motherwell and Addo, Draft Conceptual Transport Planning Study, Ref: J27218A

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The analysis took into consideration Levels of Service (LOS), vehicle queuing lengths during AM, Midday and PM peak hours, the widening of the R335 and inhibited turning movements due to vehicle queuing at intersections. The results consequently indicated which interchanges would be required to be upgraded, and the designs were consequently based on this. The interchange layout designs were consequently produced and entails the preferred and only design for the relevant interchanges. See the Conceptual Transport Planning Study found in Appendix 4 for the layout drawings for the relevant interchanges. See Plate 7-9 for an example of an interchange to be upgraded.

Plate 7-9: An example of an intersection of the R335 / W.M.Maku / Tutu Street on the periphery of Motherwell, which will be upgraded

7.4 NO-GO ALTERNATIVE

The No-go Alternative has to be investigated as per the requirements of the EIA Regulations (2014, as amended). This alternative essentially investigates the option of not implementing the proposed upgrading of the R335 between Motherwell and Addo.

Should the No-Go Alternative proceed, the route will not be upgraded, and the current safety hazards will remain; there will be no shoulder to pull over onto, there will be no overtaking lanes, the Coega River Bridge will continue to overtop during high rainfall events, the unsafe vertical and horizontal alignment will remain, the culvert structures will not have capacity to accommodate high flood events, and wildlife will continue to cross the R335. Based on the busy nature of the route as a tourism and transport network, these issues will become exacerbated over time.

Ultimately, should the R335 not be upgraded, road user’s safety will remain in jeopardy, the transport and tourism route will not be upgraded and the status quo will continue. This therefore is not the preferred alternative.

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8. DESCRIPTION OF THE BASELINE ENVIRONMENT

8.1 TOPOGRAPHY

The gradient of the R335 is varied and relatively undulating. It is to be noted that whilst the elevation profile (Figure 8-1) illustrates an alignment that is rather steep, this can be attributed to the scale of the illustration. There is a variation in elevation of 209m along the 32km route.

Figure 8-1: Gradient of the R335 from Motherwell (km5.6) to Motherwell (km7.6)

8.2 ECOLOGICAL ENVIRONMENT

The R335 road alignment passes through three designated vegetation biomes, namely Albany Alluvial Vegetation (Aza6), Sundays Thicket (AT6) and Coega Bonteveld (AT7), as per Mucina & Rutherford (2006)12 (see Figure 8-2).

Albany Alluvial Thicket is distributed throughout the Eastern Cape province, predominantly along the wide floodplains of larger rivers such as the Sundays and Coega Rivers. The vegetation has an altitude range of 20-1000m and is dominated by two major types of vegetation patterns; riverine thicket and thornveld. Riverine thicket tends to occur in narrow floodplain zones, whereas thornveld occurs on wide floodplains further inland. Habitats within Albany Alluvial Thicket vary and include riparian thickets, reed beds, flooded grasslands and herblands. Only 6% of this biome is statutorily conserved (predominantly within Addo Elephant Park), and 2% is conserved within private conservation areas. It is consequently considered as being Endangered. More than half of the biome has been transformed to urban development, road building, cultivation and plantations.

Sundays Thicket is distributed throughout the Eastern Cape province and within the context of the R335, from the northern edge of Port Elizabeth into the lower Sundays River Valley. The Sundays Thicket is found in altitudes of 0-800m along undulating plains, low mountains and foothills. Vegetation includes tall, dense thickets where trees, shrubs and succulents are common. The Sundays Thicket has a conservation status of Least Threatened and is statutorily protected in various nature reserves as well as private conservation areas. Degradation of the biome is linked to cultivation, urban development and grazing by livestock.

Coega Bonteveld is distributed within the Eastern Cape province just north-east of Port Elizabeth, as well as in and around Coega and in small patches in Addo. The biome is found between altitudes of 0-400m on moderately undulating plains where a mosaic of low thicket built mainly of bush clumps occurs. Species include a mix of fynbos, grassland and succulent karoo elements. Approximately 14% of the biome has

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

Page | 37 DBAR: R335 Upgrade, Motherwell to Addo 41643 been conserved in statutory and private nature reserves. However, developments around Port Elizabeth (e.g. the Coega Industrial Development Zone) continue to threaten this vegetation type.

Figure 8-2: Vegetation designations for the site as per Mucina & Rutherford (2006)

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8.3 BIOREGIONAL AND LOCAL CLASSIFICATION

The NMBM has implemented a systematic conservation assessment and plan to conserve a representative proportion of all biodiversity in the Municipality. To achieve this goal, a suite of Critical Biodiversity Areas (CBAs) and Critical Ecosystem Support Areas (CESAs) were identified. These areas, if safe guarded, will facilitate the long-term persistence of a representative portion of all biodiversity patterns, ecological processes and species of conservation concern (NMBM, 2009). This Conservation Plan was gazetted in March 2015 as part of the Metropolitan Bioregional Plan and is now widely used as the most recent and applicable fine scale conservation assessment in the NMBM.

The NMB MOSS (2009) identifies six (6) vegetation types in the study area (see Figure 8-3) namely:

• Grassridge Bontveld; • Sundays Spekboom Thicket; • Sundays Valley Thicket; • Sundays Doringveld Thicket; • Koedoeskloof Karroid Thicket; and • Motherwell Karroid Thicket.

Grassridge Bontveld is a subtropical Valley Thicket habitat unit consisting of small clumps of Sundays Valley Thicket in a matrix of veld that consists of a combination of species that are characteristic of fynbos (Acmadenia obtusata, Euryops ericifolius), succulent karoo (Pteronia incana) and grassland (Themeda triandra, Eustachys paspaloides). This unit contains many highly localized endemics and is found on the Alexandria Formation. Approximately 90.9% of the intact vegetation remains. This vegetation type is classified as ‘Vulnerable’.

Sundays Valley Thicket is a subtropical Valley Thicket habitat unit dominated by Boerboon (Schotia afra) and Gwarrie (Euclea undulata) trees. Suurnoors (Euphorbia ledienii) and the Uitenhage aalwyn (Aloe africana) are also reliable indicator species. This unit is generally present on red, loamy to clayey soils derived from the Sundays River and Kirkwood formations. Approximately 74.8% of the intact vegetation remains. This vegetation type is classified as ‘Vulnerable’.

Sundays Spekboom Thicket is a unit of Valley Thicket dominated by Spekboom (Portulacaria afra). Pappea capensis generally dominates the tree component while Suurnoors (Euphorbia ledienii) and wilde granaat (Rhigozum obovatum) are characteristically common. This vegetation unit is generally present on deep alluvial soils. Approximately 77.4% of the intact vegetation remains. This vegetation type is classified as ‘Vulnerable’.

Motherwell Karroid Thicket consist of thicket clumps containing species typical of Sundays Valley thicket occurring in a matrix or succulent karoo dominated by Pteronia incana (asbossie). Themeda triandra is dominant son after fire. Characteristic species include local endemics such as Euphorbia meloformis. This vegetation unit is typically present on calcareous limestones of the Alexandria formation. Motherwell Karroid Thicket is classified as ‘Endangered’. Approximately 39.6% of the intact vegetation remains.

Sundays Doringveld Thicket consist of thicket clumps often species-poor but those present are typical of the Sundays Valley Thicket. Dominant in the Nama-karoo matrix are sweet thorn (Acacia karroo), wolwedoring (Lycium spp.) and quick grass (Cynodon dactylon). Characteristic features are the high cover of Panicum spp. and the presence of succulents. Some of these succulents are rare species (e.g.

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Harworthia sordida). This vegetation unit is restricted to deep, red, alluvial soils of the Coega, Sundays and Swartkops Rivers. Sundays Doringveld is classified as ‘Endangered’. Approximately 36.1% of the intact vegetation remains.

Koedoeskloof Karroid Thicket consist of thicket clumps typical of Sundays Spekboom Thicket. The matrix is succulent karoo dominated by asbossie (Pteronia incana) and grasses (Aristida spp., Digitaria eriantha). Maerman (Drimia elata) is abundant and a characteristic feature. This vegetation unit is generally present on a complex mix of soils derived from the Sundays River formation. Koedoeskloof Karroid Thicket is classified as ‘Least Threatened’. Approximately 87.7% of the intact vegetation remains.

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Figure 8-3: Local Vegetation Map illustrating the vegetation type found within the study area

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8.4 PROTECTED AREAS

In terms of proximity to National Environmental Management Biodiversity Act (NEM:BA, Act 10 of 2004) gazetted protected areas (see Appendix 8) list, the proposed development falls within 2.5km of the Addo Elephant Nature Reserve (at its norther-most extent) and within 3.3km of the Kwartkops Valley Nature Reserve at its southern-most extent (within Motherwell). The Kaapse Grysbok Nature Reserve is private nature / game reserves found within 2.5km of the road. See Figure 8-4.

The R335 road passes directly through the Tregathlyn Game Farm, a private nature reserve which was established after the R335 was constructed. See Figure 8-5.

8.5 NATIONAL PROTECTED AREAS EXPANSION STRATEGY

The goal of the National Protected Areas Expansion Strategy (NPAES)13 is to achieve cost-effective protected area expansion for ecological sustainability and increased resilience to climate change. It sets targets for protected area expansion, provides maps of the most important areas for protected area expansion, and makes recommendations on mechanisms for protected area expansion. The NPAES includes both formally and informally14 protected conservation areas.

As per Figure 8-6, the R335 falls in close proximity to the Baviaans-Addo Focus Area, designated as an informal expansion strategy focus area. However, the road does not bisect the NAPEAS identified area, and it is not anticipated that the proposed upgrade will have any impact on Baviaans-Addo Focus Area.

13 National Protected Area Expansion Strategy Resource Document, 2009 https://www.environment.gov.za/sites/default/files/docs/npaes_resource_document.pdf 14 Informally protected conservation areas are areas of land not formally protected by law but informally protected by the current owners and users and managed at least partly for biodiversity conservation.

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Figure 8-4: The R335 in location to NEM:BA (Act 10 of 2004) gazetted protected areas

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Figure 8-5: Private nature / game reserves in close proximity to the R553

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Figure 8-6: NPAES areas in close proximity to the R335

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8.6 CRITICAL BIODIVERSITY AREAS

8.6.1 Eastern Cape Biodiversity Conservation Plan

The Eastern Cape Biodiversity Conservation Plan, 2007 (ECBCP) is a systematic biodiversity conservation plan that shows terrestrial and aquatic features that are critical for conserving biodiversity and maintaining ecosystem functioning. Critical Biodiversity Areas are areas required to meet biodiversity targets for ecosystems, species and ecological processes, as identified in a systematic biodiversity plan. Ecological Support Areas are not essential for meeting biodiversity targets but play an important role in supporting the ecological functioning of Critical Biodiversity Areas and/or in delivering ecosystem services.15 The ECBCP contains land use guidelines, based on the CBA-type within which a particular land use is proposed. These guidelines are intended to guide land-use decision-making, so as to avoid or minimise negative impacts in CBAs and important water catchments in the Province.

In the case of the proposed road alignment, the majority of the alignment falls within a Critical Biodiversity 2 (CBA2) designation (Figure 8-7). This is attributed to the vegetation of the site predicted to comprise of Endangered and Threatened vegetation types, which require a level of protection and conservation. CBA2 areas are areas that have been selected as the best option for meeting biodiversity targets, based on complementarity, efficiency, connectivity and/or avoidance of conflict with other land or resources uses.

The ECBCP adopts a land management objectives-based approach, identifying Biodiversity Landuse Management Classes (BLMC), on the basis of CBA-type, and setting out the desired ecological state for each BLMC, that an area should be kept in, in order to ensure biodiversity persistence. Terrestrial BLMCs set out the desired ecological state of a parcel of land, and the ECBCP recommends that only land use types what are compatible with maintaining this ecological state should be allowed. In the case of the proposed development, the development site is located within CBA2 and CBA3 designated areas. CBA2 translates to a BLMC 2, identified as a near natural landscape with minimal loss in ecosystem integrity and functioning. The recommended land use objective for this class is to maintain biodiversity in a near-natural state, with minimal loss of ecosystem integrity. No transformation of natural habitat should be permitted. Recommended land uses within this BLMC include conservation, game farming and communal livestock. Whilst the applicability of these land management classes cannot be implemented along the R335 alignment as it is an existing structure, the recommended land uses have been implemented adjacent to and surrounding the road alignment as illustrated by the conservation and game farming that presently takes place.

CBA3 translates to a BLMC 3, identified as a functional landscape. Land use management classes include managing land to maintain basic ecosystem processes despite expecting significant loss in natural vegetation cover and maintaining biodiversity in critical patches and ecosystem corridors. This designation is appropriate as this portion of the alignment falls within Motherwell, within the urban edge of Port Elizabeth (see Figure 8-8), and a land use that is completely transformed due to densification and urbanisation.

15 http://biodiversityadvisor.sanbi.org/industry-and-conservation/biodiversity-in-the-urban-economy/understand/definitions-related-to- urban-land-use-planning/critical-biodiversity-areas-and-ecological-support-areas/

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Figure 8-7: ECBCP designated CBA areas which the R335 traverses

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Figure 8-8: The location of the R335 in relation to the urban edge of the Nelson Mandela Bay Municipality

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8.6.2 Nelson Mandela Bay Municipality Bioregional Plan

The Nelson Mandela Bay Municipality (NMBM) Bioregional Plan (BRP), 2014, has been prepared in accordance with the provisions of Chapter 3 of the National Environmental Management Act, 1998 (Act 107 of 1998) (NEMA). The purpose of the BRP is to provide a map of biodiversity priorities and accompanying guidelines, to inform land-use planning, environmental assessment and authorisations, and natural resource management by a range of sectors whose policies impact on biodiversity. The NMBM has set targets for the conservation of these vegetation types, with those areas deemed valuable for this purpose being identified as CBAs in the Bioregional Plan.

As illustrated in Figure 8-9, the alignment of the R335 passes through what is designated as CBA, PA1 and ESA1 land. As per the NMBM Bioregional Plan16, the following designations apply: Critical Biodiversity Areas (CBA’s) are critically endangered habitats, processes and corridors for species and habitats of special concern listed as Endangered, Vulnerable or Least Threatened. Such areas must be managed for biodiversity conservation purposes and incorporated into the protected area system. Non-consumptive conservation land-use recommendations are suggested.

Protected Areas 1 (PA1) are considered natural landscapes and are generally protected areas managed by SAN Parks, provincial or local authorities, parastatals and / or the private sector. General recommendations and land use objectives include maintaining biodiversity in as natural a state as possible and managing land to limit / prevent biodiversity loss. Areas designated as PA1’s are to be maintained as Protected Areas.

Ecological Support Area 1 (ESA1) is agricultural or partly degraded land essential for connectivity in the landscape, particularly between CBA’s. In terms of ESA1 areas, the land management objective includes maintaining existing extensive land-uses where these facilitate ecological functioning and connectivity between adjacent CBA’s, or manage for conservation.

Consequently, from a land use management and biodiversity protection point of view, it is to be noted that the R335 is an existing structure, established prior to the implementation of CBA’s. In this regard, the majority of the proposed planning and land management criteria listed within the CBA, ESA1 and PA1 recommendations cannot be applied to the road alignment, as the infrastructure is existing. However, it is to be noted that with regards to the construction of the realigned portions of the route, the bridges, culverts and underpasses, that all construction activities are advised to be strictly undertaken in compliance with specialist recommendations and the EMPr to ensure that sensitive areas in close proximity to the construction footprint are not impacted upon. All construction activities are to remain within the road servitude and all site camps, stockpile areas and access points are to be limited to existing impacted areas.

16 SRK Consulting (Pty) Ltd, 2014: Nelson Mandela Bay Municipality Final Bioregional Plan, Report No. 400919/3, Port Elizabeth http://www.nelsonmandelabay.gov.za/datarepository/documents/Atvli_400919- 3%20NMBM%20Final%20Bioregional%20Plan%20-%2013November2014.pdf

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Figure 8-9: Critical Biodiversity Areas (CBA’s), as designated by the NMBM BRP (2014) that are intersected by the R335

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8.7 GEOLOGY AND SOILS

The proposed development area is located in the Algoa Basin and is underlain by sediments of the Cretaceous aged (approximately 140 million years old) Kirkwood Sundays River and Enon Formations of the Uitenhage Group, the Witteberg Group of the Cape Supergroup as well as the Algoa Group (see Figure 8-10). The Kirkwood Formation consists of readily-weathered variegated (reddish-brown and green) silty mudrocks and subordinate sandstones of fluvial origin while the Sundays River Formation consists largely of grey coloured mudstone, siltstone and subordinate sandstone. The geology of the Algoa Group consists of clastic limestone and conglomerates. The Mid-Devonian to Early Carboniferous Witteberg Group consists mainly of sandstone of deltaic origin, overlain by marine shales.

Mucina and Rutherford (2012) interpret the geology and soils of the project site according to the vegetation type found in that area and since the project site is made up of three different vegetation types, the geology and soils within the project site is diverse as it corresponds with the overlain vegetation type (i.e. the soils/geology is one of the drivers of the plant communities).

Albany Alluvial Vegetation is underlain by sediments of the Uitenhage Group, generally alluvial deposits of various textures but often rich in clay content. These soils can become flooded during intensive storms. Sundays Thicket is generally located on deep (> 1 m) red, loamy to clayey soils derived from the Sundays River and Kirkwood Formations. Coega Bontveld generally occurs on outcrops of limestone of the Nanaga formation and calcareous paleo-dune fields. Soils are shallow and often lime rich.

8.8 HYDROLOGY (WATERCOURSES & WETLANDS)

The road alignment crosses two predominant drainage catchments, the Coega and Sundays River Catchments. The Coega River drains into the sea at the Port of Ngqura while the Sundays River enters the sea at the town of Colchester. The topography along the alignment can be divided into three separate features, these being the Coega River Valley, the Sundays River Valley and the relatively level plateau watershed between these two features. As such, all water off the plateau section, either drains in a southerly direction towards the Coega River or in a northerly direction towards the Sundays River. Apart from these two rivers, no other major rivers or streams occur along the road alignment.

A review of the National Freshwater Ecosystem Priority Areas (NFEPA) wetland database shows minimal wetland systems in the study area (see Figure 8-11). A specialist Wetland Identification and Assessment was undertaken which provides further information on the hydrology of the area (see Section 9.1 and Appendix 5).

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Figure 8-10: The surface geology of the proposed Motherwell to Addo upgrade [Ref: Banzai Environmental (Pty) Ltd Palaeontological Impact Assessment, 2016]

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Figure 8-11: Wetlands and watercourses within the greater development footprint

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8.9 CLIMATE

The Eastern Cape has a complex climate. There are wide variations in temperature, rainfall and wind patterns, mainly as a result of movements of air masses, altitude, mountain orientation and the proximity of the Indian Ocean. The study area is subject to strong winds from the west and west-south-west (41% combined frequency) all year round, and from the east (15%) from October through to March. These winds occur mainly throughout the day and may generate a significant amount of fugitive dust. Diurnal variations in the wind regime occur which are due to the influence of land-sea breeze circulation on the airflow of the region. The study area is situated between Port Elizabeth and Addo.

The area is characterised by non-seasonal rainfall and a Mean Annual Precipitation (MAP) of between 19- 480mm. Frost days range from 3 to 8 days per annum. Mean monthly maximum and minimum temperatures range from 0.3˚C to 39˚C.

8.10 LAND USES17

The landuse along the road alignment can be divided into a number of separate landuses depending on the relevant section of road, as noted in Table 8-1 and Plates 8-1 to 8-4.

Table 8-1: Landuse as per the road chainage

CHAINAGE LANDUSE km5.6 to km9.24 Urban km11.7 to km15.16 Brick factory km17.42 to km23.56 Windfarm and mining km23.58 to km37.6 Agriculture

Plate 8-1: View of the urban landuse (within Motherwell) along the road alignment

17 Van Rooyen, M., 2018: Wetland Identification and Assessment Associated with the Proposed Upgrading of the National Route R335 between Motherwell (km5.600) and Addo (km37.600) in the Eastern Cape Province

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Plate 8-2: View of the brick factories along the alignment

Plate 8-3: Coega Windfarm along the alignment

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Plate 8-4: View of the livestock and game farms along the alignment

8.11 CULTURAL, HISTORICAL AND ARCHAEOLOGICAL RESOURCES

A specialist Phase 1 Archaeological Impact Assessment (AIA) was undertaken ArchaeoMaps: Archaeological Consultancy. No fatal flaws to development were identified, however certain permit requirements will be required to be adhered to, associated with the upgrading and construction of the Sundays and Coega River Bridges, prior to construction commencing. The HIA Report is discussed in Section 9.2 and attached as Appendix 5.

A Palaeontological Assessment was undertaken by Banzai Environmental which noted that there will be no palaeontological impacts associated with the proposed upgrading, but that certain chance find protocols must be followed. The desktop Palaeontological Assessment Report is discussed in Section 9.3 and attached as Appendix 5.

The Eastern Cape Provincial Heritage Resources Authority, the authority responsible for the Eastern Cape’s heritage, has been contacted regarding the proposed development and the associated HIA Report submitted to them for comment via the South African Heritage Resources Information System (SAHRIS). To date, no comment has been provided.

8.12 EXISTING INFRASTRUTCTURE

Various forms of infrastructure exist along the alignment which include Eskom electricity lines, access roads, intersections, fence lines and Telkom telephone lines. Wind turbines are found in the general vicinity of the R335 but will not be impacted upon by the upgrade. It is not anticipated that existing infrastructure will be negatively impacted upon as the upgrade will run within the existing road reserve, within which no

Page | 56 DBAR: R335 Upgrade, Motherwell to Addo 41643 additional infrastructure (bar intersections and access roads) are permitted to be established. Access roads and intersections will be upgraded and formalised where necessary. In addition, Eskom, Telkom, the Nelson Mandela Bay Municipality, the Sundays River Valley Local Municipality and the management body for the wind turbine farms have been notified of the proposed development. Municipal planning documents and on-site infrastructure were used to determine any possible no-go areas relating to existing infrastructure, however none were identified during the assessment process.

8.13 SOCIO-ECONOMIC

The R335 passes through two municipalities, namely the Nelson Mandela Bay Municipality (NMBM), and the Sundays River Valley Local Municipality (SRVLM). The NMBM, a Category A (metro) municipality, is a major seaport and automotive manufacturing centre. It is the economic powerhouse of the Eastern Cape Province and one of eight metropolitan areas in South Africa. The Main Economic Sectors within the NMBM include manufacturing (25%), community services (23%), finance (23%), trade (13%), transport (13%). Historical socio-economic information for the NMBM is presented in Table 8-2.

Table 8-2: Socio-economic information for the NMBM18 YEAR 2016 2011 Population 1 263 051 1 152 115 Age Structure Population under 15 30.6% 25.5% Population 15 to 64 63.6% 68.5% Population over 65 5.9% 6.0% Dependency Ratio Per 100 (15-64) 57.3 46 Population Growth Per annum 2.09% n/a Labour Market Unemployment rate (official) n/a 36.6%

Youth unemployment rate (official) 15-34 n/a 47.3%

The SRVLM is a Category B municipality situated within the Sarah Baartman District. The municipality boasts The Addo Elephant National Park and citrus production which are two important economic drivers in the Sundays River Valley Municipality. The main economic sectors within the SRVLM include community services, trade, finance, agriculture, transport, construction. Historical socio-economic information for the SRVLM is presented in Table 8-3.

18 Municipalities of South Africa, 2012-2017: Nelson Mandela Bay Metropolitan Municipality (NMA). URL: https://municipalities.co.za/demographic/1/nelson-mandela-bay-metropolitan-municipality Accessed: 25/10/2018

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Table 8-3: Socio-economic information for the SRVLM YEAR 2016 2011

Population 59 793 54 504 Age Structure Population under 15 29.1% 26.7% Population 15 to 64 66.5% 68% Population over 65 4.3% 5.2% Dependency Ratio Per 100 (15-64) 50.3 47 Population Growth Per annum 2.10% n/a Labour Market Unemployment rate (official) n/a 15% Youth unemployment rate (official) 15-34 n/a 18.8%

Of particular relevance to the proposed development is the dependency rate, which has increased for both municipalities, from 2011 to 2016. This can be attributed to minimal income opportunities and a greater dependence on the state. This will be mitigated, within reason and temporarily, through the creation of job opportunities during the construction phase of the proposed development. In addition, through toolbox talks, on-site training etc., community members employed during the construction phase will be provided with skills that will assist in qualifying for future job opportunities.

8.14 ECONOMICS

The HDM4 model assesses the costs associated with the proposed development in terms of travel time, accident costs, operating costs and social benefits. When the Economic Internal Rate of Return (EIRR) of the HDM4 model produces a score exceeding 12%, the proposed development is considered economically viable development. The EIRR of the Upgrading of the R335 is 17.9%, and as such the development was considered economically viable and SANRAL proceeded from the pre-feasibility phase, into the design and EIA phases.

In terms of job creation in the skilled and unskilled areas, the following has been identified:

Table 8-4: Job creation and expenditure associated with the design and upgrading of the R335

ACTIVITY EXPENDITURE

R700 million (Excl Anticipated CAPEX value of the project on completion VAT)

R150 million (Excl What is the expected annual turnover to be generated by or as a result of the project? VAT)

Skilled employment opportunities created in the construction phase of the project 25

Skilled employment opportunities created in the operational phase of the project N/A

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Un-skilled employment opportunities created in the construction phase of the project 250

Un-skilled employment opportunities created in the operational phase of the project N/A

What is the expected value of the employment opportunities during the operational R70 million (10%) and construction phase?

It is important to note that, wherever possible, local and surrounding community members will be employed during the construction phase, but that direct employment opportunities are limited to the design and construction phases only.

8.15 TRAFFIC

The R335 is a busy traffic route between the greater Addo region, and Port Elizabeth. The route is used for both commercial (citrus and cement) and private (tourism) transport, throughout the year. This is illustrated by the fact that Addo Elephant Park receives about 115 000 visitors each year, of which 50% are foreign. The Conceptual Transport Planning Study (2008)19 projected that in 2017 there would be 4004 vehicles per day on the R335, in both directions, with 24% being heavy vehicles associated with transportation from the citrus farms, cement factories etc.

In order to accommodate this traffic and to ensure the smooth flow of traffic during construction, a detailed traffic plan has been developed. This plan is based on construction being split into two phases and that each phase will take approximately three years to complete. Two transport alternatives have been provided to R335 road users, namely;

• Providing alternative routes which may be used to access the park (see Figure 8-16); and

• Including specific written requirements in the engineering and tender documents which stipulate that the road shall allow bi-directional traffic flow at all times and that no closures shall be allowed during school holiday period. A STOP/GO will only be used at the Sundays River bridge, while the bridge is being widened.

To mitigate the impact of construction on road users utilising the R335, the following methods20 are proposed to be used to manage traffic:

A. The construction of temporary deviations at major culverts. B. Offset construction with 7m from the existing road centreline in order to accommodate bi- directional traffic while constructing the road in two halves. C. Constructing the road alongside the existing road without affecting traffic. Effectively greenfields construction.

19 Department of Roads and Transport Eastern Cape, 2008: Upgrading of the R335 between Motherwell and Addo Draft Conceptual Transport Planning Study, Ref: J27218A 20 GIBB (Pty) Ltd, 2018: Contract SCMU 10-06/07-138, For Improvement of National Route R335 Between Motherwell (Km5.600) and Addo (Km37.600): Executive Summary of the Detailed Assessment and Design Report, East London

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D. Half width construction with STOP and GO control during daytime and temporary traffic lights during night time. E. Temporary widening on one side of the existing road to allow two-way traffic while the other half of the road is constructed. When the first half is complete, traffic is switched over and the newly constructed roadway and the originally widened section is constructed.

Table 8-5 below provides a summary of the traffic accommodation methods that will be implemented during construction. Please refer to the reference drawing Figures 8-12 to 8-13 which provide greater detail regarding traffic accommodation along specific portions of the route.

Table 8-5: Summary of Traffic accommodation plan START KM END KM METHOD

5.600 9.580 B 9.580 10.680 C 10.680 11.020 B 11.020 12.180 C 12.180 12.440 B 12.440 12.960 C 12.960 16.380 B 16.380 16.540 C 16.540 25.840 B 25.840 26.120 C 26.120 26.780 B 26.780 27.600 A 27.600 28.700 B 28.700 29.640 A 29.640 30.680 B 30.680 32.600 C 32.600 34.700 B 34.700 37.900 D 34.900 37.600 E

The planned STOP/GO construction will have a negative impact on traffic and cycling times of 15 minutes will be implemented which should minimise waiting times. The various methods of traffic accommodation expected may be seen in Figures 8-14 and 8-15.

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Figure 8-12: Traffic accommodation methods for km5.16 to km22.3

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Figure 8-13: Traffic accommodation methods for km22.3 to km38.400

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Figure 8-14: Traffic accommodation measure Types A to C as listed in the legend of Figure 8-10

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Figure 8-15: Traffic accommodation measure Types D and E as listed in the legend of Figure 8-12

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Figure 8-16: Alternative road for STOP/GO alleviation

9. SPECIALIST STUDIES

9.1 WETLAND IDENTIFICATION AND ASSESSMENT

Terratest (Pty) Ltd was appointed to undertake a Wetland Identification and Assessment of all wetlands and drainage lines located along the R335 road, as well as to conduct an impact assessment of the proposed development on the receiving environment. Mitigation measures and recommendations have also been presented based on the impacts identified.

The Wetland Identification and Assessment Report is attached as Appendix 5. The relevant details of the specialist who conducted the assessment are noted in Table 9-1.

Table 9-1: Details of Specialist Name of Education Field of expertise Title of specialist report/s as attached in specialist qualifications Appendix 5 Mr Pr.Sci.Nat Biodiversity, Wetland Wetland Identification and Assessment Magnus (SACNASP) and Vegetation Associated with the Proposed Upgrading of the van Specialist National Route R335 between Motherwell Rooyen (km5.600) and Addo (km37.600) in the Eastern Cape Province

9.1.1 Wetland Delineation and Identification

The NFEPA database indicated the presence of a number of wetland areas within the 500m radius of the proposed road upgrade project. Several wetlands are located along the southern section of the road

Page | 65 DBAR: R335 Upgrade, Motherwell to Addo 41643 alignment, one in the middle section and two in the northern section towards the Sundays River. See Table 9-2 and Figures 9-1 to 9-3 for details thereof.

Table 9-2: Details regarding the wetlands found within a 500m radius of the site WETLAND NAME NATURE HGM UNIT CENTRE POINT COORDINATES

Wetland 1 (W1) Natural Pan S 33º 47’ 44.20” E 25º 36’ 47.64” Wetland 2 (W2) Artificial Stormwater attenuation pond S 33º 47’ 48.90 E 25º 36’ 42.31” Wetland 3 (W3) Artificial Stormwater attenuation pond S 33º 46’ 39.72” E 25º 35’ 30.07” Wetland 4 (W4) Natural Pan S 33º 46’ 22.71” E 25º 35’ 52.47” Wetland 5 (W5) Natural Pan S 33º 45’ 50.82” E 25º 35’ 20.27” Wetland 6 (W6) Natural Pan S 33º 41’ 25.30” E 25º 35’ 10.69” Wetland 7 (W7) Natural Hillslope Seep S 33º 35’ 21.56” E 25º 37’ 39.12” Wetland 8 (W8) Artificial Stock dam S 33º 35’ 05.46” E 25º 39’ 50.44”

Figure 9-1: The location of the NFEPA wetlands along the southern section of the road alignment

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Figure 9-2: The location of the NFEPA wetlands along the central section of the road alignment

Figure 9-3: The location of the NFEPA wetlands along the northern section of the road alignment

The site assessment has confirmed the presence of these wetland areas within the 500m radius with no additional wetland areas being identified. None of the identified wetlands are crossed by the road alignment and will therefore not be directly impacted on by the project. Drainage features were noted during the site visit and are associated with the Coega River and the Sundays River catchments and consist of small to very small seasonal streams. A drainage feature of interest is the Soutkloof stream channel located between Culverts E and F. The section of the river channel has eroded down to a pediment that is covered by a thin layer of fine sediment. Due to the mineralogical characteristics of the eroded rock in the area, the thin layer of sediment that covers the pediment is saline in nature. This salinity has resulted in large

Page | 67 DBAR: R335 Upgrade, Motherwell to Addo 41643 sections of the channel being unvegetated. The vegetation that does occur in the channel consist of small succulent species that have adapted to live in soils with a high salinity.

9.1.2 Description of Wetland Type

As per Table 9-2, the predominant Hydrogeomorphic Unit (HGM) found on site were pans (or depressions). These wetland units can receive both ground and surface water which accumulates in depressions due to the impervious nature of the underlying soil or rock layer. These depressions are usually associated with relatively small catchments which limit the amount of water inflow into these areas. As the pans are not associated with any water courses, no outflow of water takes place from these features.

Hillslope Seep wetlands are typically associated with groundwater discharges, although flow through these seep areas can be augmented by surface water flows. These wetland types are expected to contribute to some surface flow attenuation early in the wet season until the soils are saturated after which the contribution to flood attenuation decreases.

9.1.3 Wetland Ecological Functional Assessment (WET-EcoServices)

All inwardly draining pans act as a sink for nitrates, phosphates and toxicants that drain from their catchment into the pans. The pans also provide a flood attenuation function to the areas in which they occur. This function is confirmed by the fact that those that occur within the Motherwell area have all been incorporated into the local stormwater networks.

The Hillslope Seep remnant associated with the Soutkloof Stream provides very little ecological service to the catchment it is associated with, largely as it is in the process of rapid erosion. A slight ecosystem service is provided as a carbon storage sink.

9.1.4 Ecological Importance and Sensitivity Assessment (WET-Health)

The results of the Level 1 assessment of the WET-Health model indicated that the wetland areas have the following classifications in terms of their Present Ecological State (PES21): • Pans: Class D – largely modified. A large change in ecosystem processes and loss of habitat and biota has occurred. This classification is largely due to the existing human impacts (stormwater attenuation ponds) and impacts on the small catchments of these pans; and • Hillslope Seep: Class D – largely modified. A large change in ecosystem processes and loss of habitat and biota has occurred. This classification is largely due to the high level of erosion that is taking place in this seep area. This is as a result of the natural geomorphological processes in the area. The specialist notes that these wetland areas are both in a degraded state most likely as a result of the external impacts from the surrounding area occurring within the catchments of these wetlands.

Based on the findings of the WET-Health and WET-EcoServices models, it is considered that the Ecological Integrity Score (EIS) of the wetland areas are of low importance to the local ecology indicating that their health is of a low score and that they consequently provide few services as well.

21 Since hydrology, geomorphology and vegetation are interlinked in the model, their scores are aggregated to obtain the overall PES health score using

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9.1.5 Buffer determination

None of the wetland areas are close enough to any of the activities associated with the proposed road upgrade, making the specification for a buffer irrelevant. Furthermore, the location of the construction of the new Coega River bridge is located in close proximity to the current bridge while the construction of the additional bridge structure over the Sundays River is also located immediately adjacent to the existing bridge. The implementation of a buffer at these sites are therefore also irrelevant.

9.1.6 Risk Assessment

The impact assessment identified impacts on the wetland areas and other aquatic features, associated with the upgrading of the R335. It is believed that the activities associated with the road upgrading will not result in any direct impacts on the identified wetland areas due to a combination of the nature of these activities as well as the location of the wetlands in relation to the activities. The risks posed to the Coega and Sundays Rivers were however considered as the proposed works will take place within the channels of these rivers. Table 9-3 lists the various risks associated with the proposed upgrading of the R335 in relation to the various watercourses, as well as providing control measures / mitigation measures for said risks.

It is important to note that consideration is given to the fact that the design of all the drainage structures (culverts, Sundays River and Coega River bridges) are in accordance with the SANRAL Drainage Manual. The SANRAL Drainage Manual seeks to facilitate free movement of water through the crossing structures so as to prevent any downstream impact on the characteristics of the aquatic feature it is constructed on. As such all the impacts associated with these structures will have a risk rating of “low”. In addition, the assessment of these risks is in line with the Department of Water and Sanitation’s Risk Assessment Matrix.

As per Table 9-3, all of the risks identified can be mitigated and managed by the implementation of site specific management and mitigation measures. In light of these management and mitigation measures, it is the opinion of the Specialist that these risks can all be classed as being “Low” risks. Furthermore, monitoring requirements for the water quality as well as the aquatic ecology in the watercourses are proposed for the construction period of the bridges (see Section 9.1.7). .

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Table 9-3: Mitigation Measures associated with potential impacts on water resources during the construction phase ACTIVITY ASPECT IMPACT CONTROL MEASURE Risk of Plant and equipment that will be Impact on the water quality in 1. As much as it is possible, works within the watercourses should be contamination of the used for the bridge construction the watercourses, which will planned during the low flow periods of the year to limit the risk of watercourses by activities may leak and may negatively impact on the potential spillages. leaking plant and result in contamination of any water quality in the system. 2. No plant or equipment will be parked within 100m of the edge of any equipment during water that may be present in the watercourse. Plant and equipment will be parked at designated parking construction watercourse. areas. 3. All plant and equipment will be checked on a daily basis for leaks, any plant that is found to be leaking will be removed off site for maintenance. 4. All stationary machinery must be equipped with a drip tray to retain any oil leaks. 5. Emergency plans must be in place in case of spillages. Risk of It is unsure if the site camp that Impact on the water quality in 1. The site camp must be located as a minimum 100m away from the contamination of the will be established for the project the watercourses, which will edge of the delineated watercourses. watercourses by the will be storing any dangerous negatively impact on the 2. All dangerous goods must be stored in bunded areas providing for storage of dangerous goods, however, if it will, these water quality in the greater 110% of the capacity of the dangerous goods to be stored. goods within the site goods will pose a contamination system camp risk to the water quality in the watercourses. Risk of Ablution facilities in the form of Impact on the water quality in 1. All ablution facilities (portable chemical toilets) must be located as a contamination of the mobile chemical toilets will be the watercourses, which will minimum 100m away from the edge of the delineated watercourses. watercourses provided within the site camp or negatively impact on the 2. The portable chemical toilets must be serviced on a regular basis by a through leakages at water quality in the greater registered service provider. from the on-site the construction front (i.e. the system ablution facilities location of the bridge construction sites). Risk of Construction materials The construction materials 1. As far as practically possible, works within the watercourses should contamination of the (concrete, cement, rebar, etc.) that could potentially be planned during the low flow periods of the year to limit the risk of watercourses by will be used for the construction contaminate the watercourse contamination. It will also enable the successful retrieval/collection of the construction of the bridges. could pose a risk to the water material from the watercourse. materials during the quality as well as the being a 2. All construction waste material (concrete waste, metal, shutter- construction phase physical impediment in the boards, etc.) that finds its way into the watercourses must be removed watercourse by hand.

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ACTIVITY ASPECT IMPACT CONTROL MEASURE . 3. All collected waste must be accumulated in a designated area no less than 50m from the delineated edge of the watercourse. Collection from this designated area must be conducted on a weekly basis with the material being disposed of at a municipal landfill facility. 4. All concrete mixing must occur on impermeable surfaces. Risk of Domestic waste materials (food The domestic waste 1. Domestic waste must be collected in waste bins that are located on contamination of the containers, plastics, papers, materials could Potentially site. The content of these bins must be cleared on a daily basis to a watercourses by etc.) that will be used by the contaminate the watercourse collection point in the site camp from where the waste can be removed domestic waste labour working on the sites. which could pose a risk to on a weekly basis. The collected waste must be disposed of at a during the the water quality municipal landfill facility. construction phase characteristics of the 2. A designated eating area must be identified no less than 50m from the watercourse. delineated edge of the watercourse or within the site camp. This eating area must be used by the labour during their eating breaks. 3. Waste bins must be placed at this designated eating area for use by the labour.

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9.1.7 Recommendations

Water Quality Monitoring The quality of the water within the watercourses must be monitored to determine any occurrence of contamination as a result of the construction activities. To this end, the following monitoring principles must be applied:

• Identification of two sampling locations, one upstream and one downstream of the bridge locations, before construction on the bridges can commence. • Representative, monthly water samples must be taken at these locations during the preceding three (3) months before construction is to commence. This will enable the determination of the baseline water quality in the watercourses. • The analysis criteria for the samples must make provision for the following parameters:  Turbidity;  Petrochemicals (oil, diesel, etc.); and  pH • Further water sampling events need to be undertaken on a monthly basis for the duration of the construction phase of the structures. • Monthly Water sampling events must extend for a period of 3 months after the cessation of the construction of the structures. • The results of this analysis process must form part of the monthly reporting during the project management meetings.

Aquatic Monitoring The aquatic ecological condition in the watercourse must be monitored to determine any occurrence of contamination as a result of the construction activities. To this end, the following monitoring principles must be applied: • Identification of two sampling locations, one upstream and one downstream of the bridge locations, before construction on the bridges can commence. • A South African Scoring System (SASS) bioassessment monitoring event is to be undertaken two (2) months before the construction activities are to commence at these sampling sites. This will enable the determination of the baseline water quality in the watercourses. • Further SASS monitoring events need to be undertaken on a quarterly basis (every three months) for the duration of the construction phase of the structures. • The final SASS monitoring event must be scheduled to be 3 months after the cessation of the construction of the structures. • Feedback on the results of the SASS monitoring must be provided during the project management meetings of the month that the monitoring event took place.

9.1.8 Conclusion

It is the Specialist’s opinion that there are no fatal flaws associated with the proposed implementation of the road upgrading project. This opinion is only applicable if the management and mitigation measures as provided in this assessment report are applied and monitored. It is suggested that this monitoring be

Page | 72 DBAR: R335 Upgrade, Motherwell to Addo 41643 conducted by an independent and suitably qualified Environmental Control Officer (ECO) on a monthly basis for the duration of the construction phase.

9.2 PHASE 1 ARCHAEOLOGICAL & CULTURAL HERITAGE IMPACT ASSESSMENT

ArchaeoMaps: Archaeological Consultancy was appointed to undertake a Phase 1 Archaeological & Cultural Heritage Impact Assessment (AIA) for the proposed upgrading of the R335. Mitigation measures and recommendations have been presented based on the impacts identified. It is to be noted that Umlando: Archaeological Surveys and Heritage Management was requested to review the report undertaken by ArcaheoMaps after the alignment and road width had been changed. The new road alignment effectively widens the road and this increases the impact area. The purpose of the review was to determine, at a desktop level, if further assessment was required and/or if mitigation from the original mitigation was still valid. The Phase 1 Heritage Survey undertaken by ArchaeoMaps appears to have covered all of the sites along the route and no further survey will be required for the road alignment. The findings of this section consequently represent those provided in the ArchaeoMaps Phase 1 AIA Report as well as recommendations included in the Umlando report review.

The AIA report as well as the review thereof by Umlando are attached as Appendix 5. The relevant details of the specialists who undertook the work are noted in Table 9-4.

Table 9-4: Details of Specialist Name of Education Field of expertise Title of specialist report/s as attached specialist qualifications in Appendix 5 Ms Karen van MSc Archaeology Heritage Impact Upgrading of the Main Road MR450 Ryneveld Assessment (R335) from Motherwell to Addo, Nelson Mandela Bay Municipality and Sundays River Valley Local Municipality, Eastern Cape Mr Gavin M. Phil Heritage Impact Upgrading of the Main Road MR450 Anderson (Archaeology and Assessment (R335) from Motherwell to Addo, Nelson Social Psychology Mandela Bay Municipality and Sundays River Valley Local Municipality, Eastern Cape

ArchaeoMaps was appointed to undertake a Phase 1 Archaeological & Cultural Heritage Impact Assessment This report comprises a Phase 1 AIA, including a basic pre-feasibility study and field assessment. The report was prepared in accordance with the ‘Minimum Standards’ specifications for Phase 1 AIA reports, as stipulated by SAHRA (2007). Phase 1 HIA studies focus on pre-feasibility and desktop studies, routinely coined with field assessments in order to locate, describe and assign heritage site significance ratings to identified resources that may be impacted by development. The aim of a Phase 1 AIA is to make site specific and general development recommendations regarding identified heritage resources for development planning and implementation purposes and may include recommendations for conservation, heritage site declaration, monitoring, Phase 2 mitigation (excavation), or destruction.

Findings of the desktop and field assessment identified eleven (11) archaeological and cultural heritage resources (Sites MR450-S1 to MR450-S11), as defined and protected by the NHRA 1999, and one (1) culturally sensitive site (Site MR450-S12), not formally protected by the NHRA 1999, during the field assessment. Of the identified resources Site MR450-S1, the Colonial Period bridge across the Sundays

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River and Site MR450-S7, the Colonial Period bridge across the Coega River will be directly impacted by development. The bulk of the identified resources (SitesMR450- S2 to MR450-S6, and MR450-S8 to MR450-S11) comprise Colonial Period farmstead / homestead sites, situated in proximity to the study site only. These sites will not be directly impacted by development.

9.2.1 Site MR450-S1 – Colonial Period: Sundays River Bridge

Site MR450-S1 (S33°34’53.7”; E25°40’26.3”) comprises the Colonial Period bridge across the Sundays River. The bridge was constructed in 1942; currently 76 years of age and by implication formally protected by the NHRA 1999. The site receives automatic SAHRA / EC PHRA protection as a site of High Significance with a Provincial Grade II Field Rating. Development will directly impact on the bridge. Development will need to be done under an EC PHRA – BE Unit NHRA 1999, Section 34 site alteration permit. It is recommended that the permit application be made, and considered by the EC PHRA – BE Unit, for the tenure of construction as per the EA, in the event of a positive EA being issued for the proposed development.

Plate 9-1: Site MR450-S1, the Sundays River bridge

9.2.2 Site MR450-S7 – Colonial Period: Coega River Bridge

Site MR450-S7 (S33°44’43.8”; E25°35’37.7”), the Coega River bridge, have just come of its 60-yearold heritage protection status in terms of the NHRA 1999. The site receives automatic SAHRA / EC PHRA protection as a site of High Significance with a Provincial Grade II Field Rating. Development will directly impact on the bridge, requiring demolition thereof to meet development requirements in terms of the project proposal. Development will need to be done under an EC PHRA – BE Unit NHRA 1999, Section 34 site demolishment permit. It is recommended that the permit application be made, and considered by the EC PHRA – BE Unit, for the tenure of construction as per the EA, in the event of a positive EA being issued for the proposed development.

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Plate 9-2: Site MR450-S7, the Coega River bridge

9.2.3 Site MR450-S8 – Colonial Period: Homestead

Site MR450-S8 (S33°44’48.7”; E25°35’37.6)” constitutes a Colonial Period homestead site, older than 60 years of age and formally protected by the NHRA 1999. The site is still in use and fairly well conserved. The site, situated a mere 15m from the proposed development corridor is formally conserved, with conservation measures including a permanent fence with access gate, thus complying with SAHRA / EC PHRA minimum standards for heritage site conservation. As per the Umlando review report, the realignment will most likely remove the boundary trees and entrance structures. Both of these are protected and require permits. Consequently, development will need to be done under an EC PHRA – BE Unit NHRA 1999, Section 34 site alteration permit. It is recommended that the permit application be made, and considered by the EC PHRA – BE Unit, for the tenure of construction as per the Environmental Authorisation (EA), in the event of a positive EA being issued for the proposed development.

Plate 9-3: View of Site MR450-S8

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9.2.4 Recommendations and conclusions

An Environmental Impact Assessment Rating score was provided by the specialist, for inclusion in the Impact Assessment scoring table (see Table 13-1), to provide a significance rating of development impacts on resources, (in accordance with NEMA 1998, Regulations).

With reference to archaeological and cultural heritage compliance, as per the requirements of the NHRA 1999, it is recommended that the proposed Upgrading of the Main Road MR450 (R335) from Motherwell to Addo, Nelson Mandela Bay Municipality and Sundays River Valley Local Municipality, Eastern Cape, proceed as applied for provided the developer comply with the below listed heritage compliance requirements.

• Eleven (11) archaeological and cultural heritage resources (Sites MR450-S1 toMR450-S11), as defined and protected by the NHRA 1999, and one (1) culturally sensitive site (Site MR450-S12), not formally protected by the NHRA 1999, were identified. Of the identified resources Site MR450- S1, the Colonial Period bridge across the Sundays River and SiteMR450-S7, the Colonial Period bridge across the Coega River will be directly impacted by development. In both cases EC PHRA – BE Unit alteration / demolishment permits would be requisite to development. • The development proposal poses no ‘fatal flaws’ with reference to archaeological and cultural heritage resources or to the cultural landscape within which the development is set. No alternative study sites or realignment of portions of the line route is recommended. • In the event of any incidental archaeological and cultural heritage resources, as defined and protected by the NHRA 1999, being identified during the course of development the process described in ‘Appendix B: Heritage Protocol for Incidental Finds during the Construction Phase’ should be followed.

9.3 PALAEONTOLOGICAL IMPACT ASSESSMENT

Banzai Environmental (Pty) Ltd was appointed to undertake a desktop and field survey, assessing the potential Palaeontological Impact for the proposed development of the upgrading of the R335. Mitigation measures and recommendations have been presented based on the impacts identified.

The desktop Palaeontological Assessment Survey is attached in Appendix 5. The relevant details of the specialist who undertook the work are noted in Table 9-5.

Table 9-5: Details of Specialist Name of Education Field of expertise Title of specialist report/s as attached in specialist qualifications Appendix 5 Elize Butler MSc Zoology Palaeontology (25 Palaeontological Impact Assessment of the years’ experience) Proposed Upgrading of Main Road MR450 (R335) From Motherwell to Addo within the Nelson Mandela Bay Municipality and Sundays River Valley Local Municipality, Eastern Cape Province

The objective of a Palaeontological Desktop Assessment is to determine the impact of the development on potential palaeontological material at the site. According to the National Heritage Resources Act (Act No 25 of 1999, section 38), a palaeontological impact assessment is required to detect the presence of fossil

Page | 76 DBAR: R335 Upgrade, Motherwell to Addo 41643 material within the proposed development footprint and to assess the impact of the upgrading of Main Road between Motherwell and Addo on the palaeontological resources.

As part of the PIA, a field-survey of the development footprint was conducted in July 2018 to assess the potential risk to palaeontological material (fossil and trace fossils) in the proposed footprint of the development. A physical field-survey was conducted on foot within the proposed development footprint. The results of the field-survey, the author’s experience, aerial photos (using Google Earth, 2018), topographical and geological maps and other reports from the same area were used to assess the proposed development footprint.

Based on the desktop survey undertaken, the palaeontological sensitivity of the development is related to the specific geology that underlies the development footprint. The development area is completely underlain by sediments of the Sundays River, Kirkwood and Enon Formations of the Uitenhage Group, the Witteberg Group of the Cape Supergroup as well as the Algoa Group. During a field survey poorly- to fairly well-preserved loose as well in situ fossil assemblages were recorded within the proposed development

9.3.1. Recommendations Recommendations noted in the Palaeontological Assessment Report (Appendix: 4) include:

• The EAP as well as the ECO for this project must be informed that sediments of the Sundays River and Kirkwood Formations of the Uitenhage Group, the Witteberg Group of the Cape Supergroup as well as the Algoa Group has a high to very high Palaeontological Sensitivity. • Should fossil remains be discovered during any phase of construction, either on the surface or exposed by fresh excavations, the ECO responsible for these developments should be alerted. Such discoveries ought to be protected (preferably in situ) and the ECO should alert SAHRA (South African Heritage Research Agency) so that appropriate mitigation (e.g. recording, sampling or collection) can be taken by a professional paleontologist. • Mitigation by a palaeontologist will entail the collection and recording of fossils as well as obtaining important data of the surrounding sedimentary matrix within the proposed development footprint. Excavation of this fossil heritage will require a permit from SAHRA and the material must be housed in a permitted institution. All fieldwork and reports should meet the minimum standards for palaeontological impact studies developed by SAHRA • These recommendations must be incorporated into the Environmental Management Plan for the Motherwell road upgrade project.

9.3.2. Conclusion

The development area is completely underlain by sediments of the Sundays River and Kirkwood Formation of the Uitenhage Group as well as the Algoa Group. Although the Palaeontological sensitivity of these areas is rated as very high no fossils have been found during a field survey. Thus, the impact on palaeontological material along the Motherwell-Addo upgrade is negligible and regarded as insignificant. It is therefore recommended that no further palaeontological heritage studies, ground truthing and/or specialist mitigation are required for the commencement of this development, pending the discovery or exposure of any fossil remains during the construction phase.

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9.4. VEGETATION ASSESSMENT A Botanical Survey was undertaken by Mr Wesley Berrington of the Van Stadens Wild Flower Reserve, Port Elizabeth, in 2010. Due to the timeframes that had passed since the date of the survey (2010) and the commencement of the Basic Assessment phase (2018), a follow-up Vegetation Impact Assessment was conducted Terratest (Pty) Ltd. The Vegetation Impact Assessment identified plant species along the alignment, as well as potential impacts and mitigation measures for the proposed upgrading of the R335 road between Motherwell and Addo.

The Botanical Survey and Vegetation Impact Assessment are attached in Appendix 5. The relevant details of the specialists who undertook the work are noted in Table 9-6.

Table 9-6: Details of Specialist

Name of Education Field of Title of specialist report/s as attached in specialist qualifications expertise Appendix 5 Mrs Kim Brent BSc (Hons) Botany Vegetation Impact Assessment for the Proposed Botany Upgrading of National Route R335 Between Motherwell (Km 5.600) and Addo (Km 37.600), within the Nelson Mandela Bay Municipality and Sundays River Valley Local Municipality, Eastern Cape Province Mr Wesley NMMU Botany Botanical Study: Upgrading of MR 450 Road Berrington between Addo and Motherwell

The Botanical Survey report dealt with the management of the Endangered plant species and identification of plant Species of Special Concern (SSC) occurring in the development footprint.

The objective of the Vegetation Impact Assessment was to determine the status of the affected terrestrial environment (specifically vegetation) as well as the potential impact that the proposed development and associated infrastructure may have on the terrestrial habitat. The assessment included a desktop and legislative review of the relevant legislation, policies, guidelines and standards and identify the need for additional permitting based on these documents; identify areas of high biodiversity, the presence of species of conservation concern (SCC) and areas where disturbance should be avoided or minimised; provide an assessment of the potential direct and indirect impacts resulting from the proposed development both on the footprint, and the immediate surrounding area during construction and operation; and provide a detailed description of appropriate mitigation measures that can be adopted to reduce negative impacts for each phase of the project, where required.

9.4.1. Floristic Findings

As per the site survey one main habitat unit was identified, namely Valley Thicket. Two main vegetation units were identified to occur within the entire study area and within this habitat unit, namely Bontveld and Thicket vegetation.

Thicket Vegetation

Thicket vegetation can be classified as Karroid Thicket and Valley Thicket. Indigenous thicket vegetation encountered on site has previously been destroyed on both sides of the road to accommodate services

Page | 78 DBAR: R335 Upgrade, Motherwell to Addo 41643 such as roadworks, telephone and power lines. A low grassy cover with scattered thicket species remains. The natural thicket in this area is rich in endemic plants, but only a few protected Aloe plants were found within the road reserve and within 5 m of the existing road reserve. In terms of the Valley Thicket vegetation, shrubs and spinescent plants including Aloe africana are indicators of this vegetation type. Where Valley thicket was encountered, a few small protected areas still exist within the road reserve. Aloe africana and Aloe striata were the only Species of Conservation Concern (SCCs) that were encountered. It is anticipated that in some areas scattered individuals of Sideroxylon inerme (the protected White Milkwood tree) may also be encountered. Both these vegetation units have been disturbed within the study area by the construction of the existing road and road reserve, mining activities, agriculture and urbanisation and only narrow portions of partially intact vegetation remain.

Bonteveld Vegetation

Grass Ridge Bontveld vegetation is found on the Grassridge plateau at an altitude varying from about one hundred and seventy (170 m) to two hundred (200 m) meters above sea level. This vegetation is characterized by bush clumps dispersed in grassland with a low shrub cover. The distribution of Syncarpha recurvata is restricted to the limestone soils within the Nelson Mandela Bay Metropolitan Municipality. Along the road reserve scattered clumps of the endangered Syncarpha recurvata plants were encountered. Vegetation within the road reserve has been previously been disturbed but has mostly recovered. Vegetation on the properties neighboring the road reserve is largely in a natural to near natural condition. Private landowners presently protect the vegetation adjoining the road reserve. Within the 2010 Botanical Survey it was noted that the plants have spread onto previously disturbed areas within the road reserve and have been particularly successful in re-establishing on exposed calcrete or shallow limestone soils. This plant appears to be a pioneer plant colonizing exposed areas on this soil type only.

9.4.2. Species of Conservation Concern

Species of Conservation Concern (SCC) are species that have a high conservation importance in terms of preserving South Africa's high floristic diversity. A total of two species are listed as protected in the Eastern Cape Provincial Nature Conservation Ordinance (PNCO) list, with no species being listed on the NEM:BA list. One protected tree species is likely to occur as scattered individuals within the study area. Two species classified as Endangered in the SA Red Data list were recoded. The floral species of conservation concern that were identified during the site visit are reflected in the Table 9-7. In addition, the GPS co-ordinates of those species identified during the 2010 Botanical Survey have been listed in Table 9-8 and are to be searched for and protected as per the recommendations in the Botanical Survey, prior to construction commencing. Table 9-7: SCC species identified within the study area SCIENTIFIC NAME SANBI RED LIST IUCN PNCO NEMBA Protected Trees Aloe africana Least Concern - Schedule 4 Aloe striata cf subsp. striata Least Concern - Schedule 4 Euryops ericifolius Endangered - - - - Syderoxylon inerme Least Concern ˗ ˗ ˗ Protected Syncarpha recurvata Endangered - - - -

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Table 9-8: GPS co-ordinates of species of special concern (SSC) as per the Botanical Survey SPECIES EASTERLY DEGREES AND SOUTHERLY DEGREES AND DECIMAL MINUTES DECIMAL MINUTES Aloe africana S33 34,940 E25 40,318 Aloe ferox S33 42,194 E 25 35,331 Aloe striata S33 35,789 E25 37,567 S33 43,601 E25 35,712 Sideroxylon inerme S33 42,832 E 25 35,576 Syncarpha recurvata S 33 38,861 E 25 35,611 33 40,087 E E 25 35,514 S 33 41,614 E 25 35,315 S 33 40,691 E 25 35,428

Plate 9-4: Examples of protected species encountered along the R335

9.4.3. Sensitivity mapping

The sensitivity map was developed by identifying areas of high, medium and low sensitivity (Figure 9-4). Guidelines for sensitivity mapping are indicated in Table 9-9. Sensitivity mapping is used to assess areas of sensitivity in more detail during the site visit as well as providing a guide for mitigation measures.

Table 9-9: Sensitivity rating criteria SENSITIVITY ATTTRIBUTES Other heavily impacted on vegetation LOW All transformed areas such as roads, mining areas etc. NFEPA wetlands, 500 m regulatory buffer of a wetland and the 100 m regulatory buffer of watercourses, tributaries and drainage lines MODERATE Intact to partially intact Thicket vegetation (precautionary area) Bontveld vegetation - degraded to some extent CBA and ESA areas Watercourses, tributaries and drainage lines HIGH Protected areas

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Figure 9-4: Map illustrating the Terrestrial CBA and ESA classification of the study area as classified by NMB MOSS (2009)

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9.4.4. Impact Assessment

The impacts listed in Table 9-10 are based on the field work, analysis of applicable legislation, relevant databses, permitting guidelines, biodiversity requirements and constraints, species of conservation concern etc. The impacts take into account the no-go / existing impacts, construction phase impacts and operational phase impacts. Impacts and consequent mitigation measures for the impacts identified, as based on the Vegetation Impact Assessment are included in Table 12-1. Scoring of impacts as based on the Vegetation Impact Assessment are included in Table 13-1.

Table 9-10: Floral impacts associated with the no-go / existing phase, construction phase and operational phase ISSUE DESCRIPTION OF IMPACT

Loss of Natural • Vegetation is currently being impacted on by a number of land uses in the Vegetation and area. Should the no-go option be the preferred option it is likely that this SCCs impact will continue as this is an existing road and vegetation loss has already occurred. • During the construction phase the development will require the clearance of natural and indigenous vegetation. Vegetation onsite is classified as Vulnerable (Grassridge Bontveld; Sundays Spekboom Thicket; Sundays Valley Thicket), Endangered (Sundays Doringveld Thicket & Motherwell Karroid Thicket) and Least Threatened (Koedoeskloof Karroid Thicket). Loss of SCCs • A total of three (3) species are listed as protected in the Eastern Cape PNCO list, and one (1) on the NEM:BA list. One (1) protected tree species (Sideroxylon inerme) is likely to occur as scattered individuals within the study area. Two (2) species classified as Endangered in the SA Red Data list was recoded. There may be a number of additional species of conservation concern that could be found on site during construction that were not observed during this study. The loss of SCCs is likely to occur where these occur within the road upgrade footprint and where disturbance cannot be avoided. It should be noted that in terms of Syncarpha sp and Sideroxylon sp., very few individuals of these have been observed within the development footprint.

Disruption of • Vegetation, ecosystem function and process has been disrupted as a result of Ecosystem the development of the road historically. This has resulted in the permanent Function and fragmentation of vegetation within the area. Together with the existing land Proces uses impacting on the ecosystems, function and processes will continue to be impacted on.

Invasion of Alien • The removal of vegetation creates ‘open’ habitats that will inevitably be species colonised by pioneer plant species. While this is part of a natural process of regeneration, which would ultimately lead to the re-establishment of a secondary vegetation cover, it also favours the establishment of undesirable species in an area. These species colonise areas of disturbance and once established, they are typically very difficult to eradicate and can pose a threat to the neighbouring ecosystem. The project area has a number of alien species present and the seedbank is therefore likely to be full of seeds from these undesirable species. Under the no-go option, unless mitigated, these species will continue to encroach indigenous vegetation. • The proposed development will result in the clearance of alien vegetation within the project area. This will be a positive impact as alien invasive species will be removed and subsequently this will also improve the condition of the

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existing natural vegetation within the study area.

Soil erosion and • During construction, topsoil loss from soil erosion during earthworks will result increase in erosion from construction activities. potential Rehabilitation of • During the Operational Phase, poor rehabilitation of disturbed areas may lead disturbed areas to the permanent degradation of ecosystems as well as allow alien vegetation species to encroach on natural vegetation. Invasion of Alien • During the operational phase the loss of natural vegetation will increase the Species potential invasion by alien plant species. This, coupled with the lack of implementation of the Alien Vegetation Management Plan may result in large scale alien plant invasion.

9.4.5. Recommendations

The following recommendations must be included into the final EMPr: • All legal matters pertaining to permitting must be completed prior to any construction activity commencing; • A qualified and independent Environmental Control Officer (ECO) must be appointed prior to commencement of any activity on site, to monitor all legal and policy compliance; • Project infrastructure must be designed in such a way as to minimise the impact on natural vegetation; • The project construction site must be demarcated prior to commencement of activities on site. All areas outside the demarcation will be considered as No-Go areas during construction; • If any unidentified SCC is found, work must cease in that area and the ECO must be notified so the correct procedures can be implemented. • Syncarpha recurvata has a very limited distribution range largely because of the unique soil it grows on. Should any species occur within the development footprint, complete avoidance of the species is preferred. Where clearance is required, search and rescue is to be attempted. However, seed heads can be harvested and distributed over areas prepared for a rehabilitation function. If possible, Syncarpha recurvata plants are to be allowed to re-establish naturally within the road reserve after construction is completed; • All protected Aloe species are to be removed before or if they are going to be damaged or destroyed during construction; • Where Sideroxylon inerme (White Milkwood trees) are encountered, the appropriate permits must be obtained from DAFF for relocation/removal should it not be possible to avoid disturbance; • The following Management Plans must be developed prior to clearing and must be implemented during construction and operation of the proposed development. These management plans must be incorporated into the EMPr: o Storm Water & Contingency Management Plan; o Erosion Action Plan; o Road verge vegetation maintenance plan; o Rehabilitation Management Plan; and o Alien Vegetation Management Plan. • The approved Operational Alien Vegetation Management Plan must be implemented every 3 months once construction is complete for a period of 12 months.

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9.4.6. Ecological Statement and Opinion of the Specialist

The majority of the negative impacts identified can be mitigated down to a low significance rating. Minor path and location deviations from the proposed works are deemed acceptable provided that the recommended mitigation measures contained in this report are implemented for those alternatives as well, and the road reserve is not moved laterally for more than 20 m at any one location (cumulatively on either side of the road).

Given the implementation of the mitigation measures provided, and although the site contains some intact vegetation, the proposed development is NOT considered to be Fatally Flawed. As a result, it is recommended that a positive environmental authorisation is issued for the proposed project.

10. PUBLIC PARTICIPATION

To fulfil the necessary public participation required as part of the BA Process, the following methods of stakeholder engagement were conducted by the EAP, as outlined below.

10.1 INTERESTED AND AFFECTED PARTIES (IAPS)

A register of IAPs was compiled as per Section 42 of the EIA Regulations, 2014 (as amended). This included all relevant authorities, Government Departments, the Local Municipality, the District Municipality, relevant conservation bodies and non-governmental organisations (NGO’s), as well as neighbouring landowners and the surrounding community. This register was updated throughout the process as details of IAP’s / Stakeholders changed, or additional IAP’s / Stakeholders registered. A copy of the IAP Register is included as Appendix 7 of this report.

10.2 BACKGROUND INFORMATION DOCUMENT

A Background Information Document (BID) and notification letter were compiled in English and circulated to all affected landowners and identified IAPs and stakeholders by letter drop and email in January, September and October 2018. The purpose of the BID was to provide preliminary information regarding the project and its location. Furthermore, the BID invited preliminary comments from IAPs and requested those notified to provide details of other potential IAPs which they may be aware of. A copy of the BID is included as Appendix 7 of this report.

10.3 LANDOWNER NOTIFICATION LETTERS

Landowner Notification letters were hand delivered and emailed to landowners along the alignment of the R335 in January, September and October 2018. The intention of the letters was to notify landowners directly of the proposed upgrading of the R335, as well as opening up direct communication channels between the EAP and landowners. A copy of the letters are included as Appendix 7 of this report.

10.4 PUBLIC MEETING

A Public Meeting was held with members of the Motherwell community on 11 April 2018, at the Raymond Mahlaba Indoor Centre. The purpose of the public meeting was to:

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• Provide information to Interested and Affected Parties (IAPs) on the proposed development; • Describe the application process for Environmental Authorisation (EA); and • Provide IAPs with an opportunity to raise any additional issues which they feel should be considered / addressed through the application process.

The meeting was attended by 219 community members who were registered on the project specific IAP register. Comments and queries raised during and after the meeting have been included in the Comments and Responses Report (Table 10-1). A copy of the meeting presentation and register can be found in Appendix 7.

Plate 10-1: Attendees at the Motherwell public meeting held on 11 April 2018

An additional public meeting has been scheduled to be held in early December 2018 at the Addo Community Hall to present the findings of the BAR to the attendees. All registered stakeholders and IAP’s will be invited to attend this meeting.

10.5 WARD COUNCILLOR NOTIFICATION

One central point of contact was used to notify the relevant NMBM ward councillors, namely the Ward 60 councillor. The Ward 60 councillor notified all the affected ward councillors (Wards 23, 53, 54, 55, 56) of the project, at a council meeting. Affected councillors were also further notified through the public meeting process by the Ward 60 councillor. The SRVLM Ward 3 and 6 councillors were notified in September 2018 by Terratest as well as through the Social Facilitator for the SRVLM.

10.6 NEWSPAPER ADVERTISEMENT

Two newspaper advertisements were published to inform the general public of the BA Process. An advert, in English, was placed in the Public Notices section of The Herald newspaper on 12/01/2018 and the Daily Dispatch on 12/01/2018. Copies of the advertisements are included in Appendix 7 of this report.

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Figure 10-1: A copy of the newspaper advert placed in the Daily Dispatch on 12/01/2018

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10.7 SITE NOTICE BOARDS

The purpose of the site notices was to inform neighbours and community members of the proposed BA Application. The details of the EAP were also provided should any member of the public require additional information or wish to register as an IAP in the Application. Five site notice boards were placed along the road alignment on 19/01/2018. The notice boards were written in English. Figure 10-2 provides a copy of the relevant site notice, while Figure 10-3 provides an illustration of the location of the site notices on site. Plates 10-1 to 10-6 provide proof of notices on site.

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Figure 10-2: A copy of the site notice placed along the existing R335 footprint.

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Figure 10-3: The location of the five site notices placed along the R335 alignment

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Plate 10-1: Notice Board (NB) 1 (NB1) placed at the end of the centre-line realignment, as the R335 enters citrus farming lands. Co-ordinates of NB1: 33° 34’ 41.08”S, 25° 40’ 42.23”E

Plate 10-2: NB2 placed along the R335 adjacent to a game farm. Co-ordinates of NB2: 33° 35’ 28.96”S, 25° 38’ 44.11”E

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Plate 10-3: NB 3 placed at one of the intersections proposed to be upgraded. Co-ordinates of NB3: 33° 39’ 19.16”S, 25° 35’ 32.30”E

Plate 10-4: NB4 placed at the entrance to D.W. Steenmakery (brick makers). Co-ordinates of NB4: 33° 44’ 46.51”S, 25° 35’ 38.86”E

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Coega River Bridge

Plate 10-5: NB4 placed along the R335 just after the Coega River Bridge (when travelling to PE from Addo)

Plate 10-6: NB5 placed along the pedestrian walkway adjacent to the R335, within Motherwell. Co- ordinates of NB5: 33° 47’ 32.20”S, 25° 36’ 09.54”E

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10.8 CIRCULATION OF DRAFT BASIC ASSESSMENT REPORT FOR COMMENT

Digital and / or hard copies of the Draft BAR were circulated to the following Key Stakeholders and IAPs for review and comment:

• DEA Compliance Monitoring and Enforcement – hard copy; • DEA Protected Areas – hard copy; • DEA Biodiversity Conservation – hard copy; • DEDEAT – hard copy; • Department of Water and Sanitation – hard copy; • Motherwell Public Library – hard copy; • Addo Public Library – hard copy; • Sundays River Valley Local Municipality – soft copy; • Sarah Baartman District Municipality – soft copy • Nelson Mandela Bay Municipality – soft copy; and • SANParks - soft copy.

Stakeholders and IAPs were notified of the availability of the Draft Basic Assessment Report via email, on 26/11/2018. Hard copies of the report were couriered on 26/11/2018 to three departments within the DEA, as requested at the Pre-Application Meeting. Hard copies of the documents were placed at the Motherwell public library and the Addo public library, for general viewing. A complete copy of the report was uploaded onto the Terratest (Pty) Ltd website (www.terratest.co.za) for public review.

It is to be noted that in terms of the NEMA: EIA Regulations (2014), GNR 982 43(2) as amended, all State Departments that administer a law relating to a matter affecting the environment, specific to the Application, including the DEA, must submit comments within 30 days to the EAP as per the request of the EAP. Should no comment be received within the 30-day commenting period, it has been assumed that the relevant State Department has no comment to provide.

10.9 COMMENTS RECEIVED

To date comments have been submitted by stakeholders and IAP’s based on the adverts, posters, BID and public meeting. Comments received during the Public Participation Process have been provided and responded to in Table 10-1 and Table 10-2.

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Table 10-1: IAP / Stakeholder Comments received based on the Background Information Document / Site Notice / Newspaper Advert IAP / STAKEHOLDER & IAP / STAKEHOLDER COMMENTS RESPONSE ORGANISATION / INTEREST Paul Martin I assume that the EIA previously undertaken for this road Your name and details will be captured on the I&AP register. The and the resulting Environmental Authorisation (that Department of Economic Development, Environmental Affairs and Local resident and Tour expired) will be taken cognisance of. In particular, there Tourism (DEDEAT) will take cognisance of the fact that this project has Operator & Guide needs to be a plan for the threatened, locally endemic been granted an Environmental Authorisation before. Once the engineers’ Syncarpha recurvata found in the road verge at design specifications have been confirmed, I will provide you with a BID in 29-11-2016 Grassridge. the new year. And yes, a botanist has been consulted for this project. More information on the vegetation will be provided in the Draft Basic Assessment Report at a later stage. Ndileka Dlamini Required more information regarding her property as it Terratest explained to Ms Ndileka Dlamini as she is a neighbouring neighbours the proposed upgrading. Was concerned that resident of the proposed upgrading, the development will not affect her Neighbouring landowner she might lose her house. property directly. – Motherwell

16-01-2018 Emmanuel Marais Concerned about a section of his property, where the new It is understood that Mr Marais has been consulted by the project servitude will extend into, will be taken by SANRAL. engineers (GIBB and LA Consulting) as they are undertaking the land Affected landowner acquisition process with all the affected landowners. Further consultations with Mr Marais will be undertaken throughout this process by the Jan-18 engineers and to provide clarity on extent of his property to be taken by SANRAL. Siseko Mnqanqeni Requested a map of the road alignment. Thank you for your call earlier. Please see the attached google earth file showing the following: NMBM Electrical • current /existing road reserve in blue Infrastructure • proposed new road reserve in green, and • new centreline in red 04-04-2018 The following is included in the design report from the engineers: An offset alignment of 7 m will be used for the horizontal alignment from the intersection with the R334 (km 9.580) up to the Sunday’s river bridge (km 34.700). Thereafter the alignment returns to the existing centreline

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and the road is widened centrally in order to avoid affecting trees within the citrus farms up to km 37.600 just before entering the town of Addo. It would be much appreciated if you can email me your concern regarding the powerlines running alongside the road. It is just easier if I have it in writing, then I can forward it onto the engineers for an official comment/response. Siseko Mnqanqeni Can you please find us a detailed design of the road, We will be sending you a layout of the proposed upgrade on A2 format. which also shows the portions that affects municipality There are power lines within Motherwell which will be affected and will NMBM Electrical lines? have to move. I will make contact with Siseko regarding the services in the Infrastructure area.

11-05-2018 Angel Mbili We received a layout of the proposed R335 Addo to Application phase: The Application process for Environmental Motherwell upgrade, a proposed route for the upgrade is Authorisation will be approximately 6 months once the application form is NMBM Electrical affecting the existing NMBM Electrical Infrastructure (11kV submitted. We are planning on submitting the application form and Infrastructure Overhead Line and the Streetlights). This line is currently circulate the DBAR for public comment in November 2018. supplying many customers along the Addo Road and it is Construction phase: It is anticipated that construction will be split into two 28-05-2018 planned to be upgraded to 22kV O/H. Could you please phases and that each phase will take approximately 3 years to complete. advise on time frame for the project? Please note that the existing overhead line needs to be relocated at a cost borne by the developer or a servitude acceptable to the Executive Director: Electricity and Energy needs to be registered. For any queries, please do not hesitate to contact Ms A. Mbili at 041 392 4360 or 082 301 0056. Sisanda Piki To work towards seeing my location having better and Noted. Safety and security is one of the main reasons for the proposed safer infrastructure. These roads need to be done asap upgrading of the road. By improving the road surface and widening the Neighbouring landowner because they can and also do cause accidents sometimes road, will result in a safer road for all road users and will add value to the – Motherwell as drivers turn to overtake and move away from potholes various industries (agricultural, brick-making, tourism) relying on this road that are on the tar. to transport their goods and produce. 24-01-2018

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Vuyo Sorendese This route should be made more safe, secure and Safety and security is one of the main reasons for the proposed upgrading Ndumndum environmentally conscious as it is used by tourism. of the road. Regarding the environmental aspect of this project, impacts There will be no noise and obstacles for the cars or the on the environmental sensitive areas along the route will be assessed and Melisizwe Public Primary animals. I have one CIDB certificate, so I can be able to included in the DBAR. In addition, a vegetation, wetland, heritage and School clean or build manholes. I will be glad if you can consider paleontological specialist studies have been undertaken and the my proposal. recommendations of each study will be included in the DBAR. Noise will 17-04-2018 be mitigated during the construction phase through the Environmental Management Programme (EMPr) which will contain, amongst others, noise control measures.

Marcel Venter I refer to you letter dated 24 January 2018 delivered by Thank you for your e-mail and interest in the project. I will capture you on hand to owner at farm 6/300-Master Brick Works (your the Interested and Affected Parties database for the project. Master Brick Works – reference). I would like to register as an interested and

Affected Property affected party. Contact details as follows: Email: [email protected] 08-02-2018 T: 041-4619510 F: 041-5811445 M: 084 6969 700 Neels Diederichs I am happy with the proposal and no need to be involved Thank you for your response. I unfortunately do not have knowledge of in any way. I understood from Arno that my entrance of your discussion / agreement with Arno Alberts from GIBB. Will your Farms 549, 1/549 and De Old Drift Guest Farm next to the tar road must be entrance be rebuilt after the road upgrade works? 3/122 – Affected rebuild, please supply me with detail so that can proceed. properties Apparently, it is in the way of the new construction, don’t 25-10-2018 worry they will most probably contact me in any way. Theo Strydom Farm Culvert A & B is on my farm. I have asked for a cattle Culvert A & B are located on Farm RE/191 belonging to Cliffort Bartman –

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6/191 – Affected property underpass. Is the culvert the same or not? Please revert. I have attached a map to show a closer view of the locations of these culverts. 07/11/2018 Can you please clarify what you mean with the culvert being the same? You are correct – one of the underpasses to be constructed falls within your property, Farm 6/191 – see the position attached. I have also attached the design of the underpass. John Adendorff None at this stage. Thank you, I confirm receipt of your mail. We will capture you / SANPARKS as a registered IAP for the proposed project. SANPARKS We will be circulating the Draft Basic Assessment Report within the next

day or two. You will be notified of the availability of the report and be 14-11-2018 afforded the opportunity to provide comment on the report within 30 days. Allan Hartslief Please advise on the affected portion? Also, is there Please open both attachments – you should see your property roughly compensation from the roads engineer re this? Can you outlined in red and the extended road reserve in green. According to this, Farm 28/124 – Affected get me in touch with the engineer and road builders? As only the new road reserve will encroach onto your property not the new property maybe they will want to rent my piece as an equipment widened road. Let me just confirm this with the engineers. and office depot? I would want them to advise if they will

09-11-2018 be creating an access road onto the property from the 10-11-2018 main road etc. The attached kmz shows the green line as the new road reserve and the 13-11-2018 red line as the property boundary. It appears that his property will be slightly affected by the new alignment. Mr. Hartslief was on our register however, after finalizing the handover point with Aurecon he fell outside of our scope as our work stops at km 37.6. He should therefore contact David Nel at Aurecon '[email protected]' in order to confirm their final alignment and property requirements.

We will review the current land acquisition plans and let you know if and how your property may be affected. Our joint venture partners Nako Iliso are responsible for the design on this section of the project and will confirm if and how your property may be affected by the road works.

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SANRAL will follow a formal land acquisition process to acquire any property required. This process has not yet commenced. They compensate at agreed market values (willing buyer/willing seller basis). All existing access will be retained. If there is no current access you could apply for one (to SANRAL) so that its construction could be included in the contract works. All access works within the limits of the road reserve would be provided through the SANRAL contract. At the time of tender you would be able to obtain from us a list of the interested contractors so that you could let them know about the availability of the property for their temporary use. Mbuyi Manyika Eskom is an interested party as we have overhead lines in Thank you, I confirm receipt of your mail. We will capture Eskom as a the area. registered IAP for the proposed project. We will be circulating the Draft ESKOM Basic Assessment Report soon. You will be notified of the availability of the report and be afforded the opportunity to provide comment on the 23-11-2018 report within 30 days.

The issue of existing overhead lines has already been raised by the NMBM’s Electrical Infrastructure section. It is understood that there are power lines within Motherwell which will be affected and will have to move. I will ask the engineers, GIBB, to engage with you further on this matter, and to provide information on the translocation of the overhead lines along the entire stretch of road to be upgraded, both within the NMBM and Sundays River Local Municipal areas.

Table 10-2: Comments and responses provided at the Motherwell Public meeting held on 11 April 2018 NAME PLEASE STATE YOUR INTEREST IN COMMENTS DO YOU REQUIRE ANY THE PROPOSED PROJECT ADDITIONAL INFORMATION Andile Gege Sub-contracting opportunities I would like to see the municipality in charge of NMMBF and Yes, like SANRAL NAFCOC and others. I think it will be fair to everybody if it is Subcontracting Policy and handled by the municipality SCM dept. Not forums as these forums Employment Policy. are going to corrupt the whole project with favouritism and nepotism. I would like to see Motherwell SMMEs take priority on this project.

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NAME PLEASE STATE YOUR INTEREST IN COMMENTS DO YOU REQUIRE ANY THE PROPOSED PROJECT ADDITIONAL INFORMATION Luyanda Would also like to be involved in Please take SMMEs who are residing in Motherwell because we Please email me a map as I am Queenie developing my area/Community don’t have any other roads that we can upgrade. It will give us more writing on this one. Majali exposure in building or upgrading the roads, and please consider SMMEs with grade 1 . Because we also need experience. Nomawethu To create jobs to the fellow brothers This project must be fair enough. There must be transparency in No Sylvia Mgijima and sisters, especially youth and to everything in the project. make a difference in our area. To eliminate the rate of crime in our area.

Mzwandile I would like to see my company Next to the graveyard we need a bridge crossing. We also need Bus stop and shelters, grass, Michael participate in this project so that I can training for our community. Selection of CLO and PLC committee so fence, and walkways. Mtetho upgrade. that the work must be done smooth and gently, No Toyi-Toyi. Buyiswa If you work close to the school let the students go back home then Matyila begin or start working on or during the weekend. Try to have a sign or surround with something if you have a hole. The bridge which is used by the people must not be the same bridge used by animals. Will you please not use Councillors when you hire from Motherwell because they will use their interest, use the committee. Thank you. Bongiwe To get general Job. No comment No Kopele Mhlangabezi Is motherwell community going to I am very pleased for this project because it provides job creation to NO Aron benefit and how? the Motherwell community. Ndabambi Luyanda Job please I am looking forward for this project, hoping that we will benefit in Njokweni terms of employment. Pindiwe Norah To be given a chance as an emerging Warning and danger signs should be available so that people No Dambuza contractor, so that I can grow. cannot get injured as the project will be closer to the houses. Trenches must be closed at all times. Motherwell residents should be prioritised in the project, as it is in Motherwell.

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NAME PLEASE STATE YOUR INTEREST IN COMMENTS DO YOU REQUIRE ANY THE PROPOSED PROJECT ADDITIONAL INFORMATION Themba Goliath Ntembi Alice Rixama Thanks for everything, because this project is going to benefit all the SMMEs of Motherwell. Patricia The interest that I have for this We wish that this project will also provide training for the people Mngoma development, we know that there are who are not working, we must also have committees to help people no jobs, so we wish that our fellow to get jobs and training. brothers get jobs to put something on the table. Nokhanyo yes cordelia Sambu Patrick Fumba Thanks about the project, I hope we are going to get jobs. Boniswa To create more jobs for everyone As from 2010 I did not find any job, so help me please and we need Rosey to help the community. Notshulwona Nonzame My interest is to help us to create jobs Since I opened my company no jobs can be found for all Lindelwa To create better jobs Since I was registered no jobs has been found Komeni Thuletu Looking for job Priority is the SMMEs of Motherwell. Communication of councillors Mhlubulwana office to take workers in each ward and aslo SMMES, especially grade 1 to gain experience. Nomfuneka The development is needed, the This project will develop and increase the skills of the SMMEs. I yes Simauza project will eliminate the death of our would like to be part of this big project as I am a SMME. I need to community. grow by participating in order to get a higher grade.

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NAME PLEASE STATE YOUR INTEREST IN COMMENTS DO YOU REQUIRE ANY THE PROPOSED PROJECT ADDITIONAL INFORMATION Ntombomzi To learn more about the job. I am Priority for SMMEs of Motherwell. Training for youth, and women. Virginia Nelani looking for job. Training as a Councillors must update the community about this project. contractor. Mboneli Alfred Job creation is my the interest in the There are old graves opposite to SASSA office near the old salt yes Mavata project pan. Nandipha Job Bentshimani Noluthando Job for all ages without pensioners I like the development so we need workshop for all ages, youth and Jantjies elders to benefit and please we want to be employed after workshops. Luvuyo Prince Job opportunities Dambuza Cikizwa Consideration of SMMEs especially grade 1, monitoring of SMMEs yes Dingela on sites, training of SMMEs in construction Thotyelwa Considering of SMMEs especially grade 1. yes Msilarha Mlungisi Coselela Trading to get Project is important to address high rate of unemployment in our yes Rwaxa placement/employment, attended area and to promote local economic development and social SANRAL Training responsibility programmes. Bonani I would like this project to be fair because many times the SMMEs Mcanda are looked down at, sometimes we don’t qualify but we complain in terms of documents. I am happy that this project requires only grade one of the CIBD

Nobathembu To be employed We want to say thank you for this development and we also want to Mnguni benefit from this development. We aslo want a workshop for this development.

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NAME PLEASE STATE YOUR INTEREST IN COMMENTS DO YOU REQUIRE ANY THE PROPOSED PROJECT ADDITIONAL INFORMATION Thozama I have an interest to this project, This project will also reduce unemployment rate to the youth No Cecilia Yaphi because it will renovate our roads so community that it will be easy for the busses to come in this area, since we have gravel roads only. Thandeka I am interested due to the lack of jobs Things to be considered while construction is in progress: 1) Gqobani in our community, any kind of jobs. Vegetation, 2) Noise, 3) Roads to help people using route R335, 4) Animals, 5) Any grade must be employed. Sisanda I am interested due to the lack of jobs According to my understanding I think there are things to be noted Mramba in our communities. And I am also while construction is in progress : 1) Vegetation, 2) Animals, 3) interested to dedicate myself to any Noise, 4) Small roads aside to help people using R335 route, 5) All kind of job given. standards or grades must be employed. Boniwe Qongo I want job only yes

Pinkie Jina Want job only yes

Neliswa Employment Yes do the project no Mngeyana

Nomathemba Employment I have no problem with the project. You must carry on with the no Teyise project, because there are a lot of trucks that use the road. Weziwe Tabita Employment My company is to get a job to upgrade my GDB Kapo

Ncediswa I highly appreciate this project because it is going to create jobs for Budaza us here in Motherwell. Thank You very much.

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NAME PLEASE STATE YOUR INTEREST IN COMMENTS DO YOU REQUIRE ANY THE PROPOSED PROJECT ADDITIONAL INFORMATION Phumelele 1) No forums should be in charge of our 30%, 2) Municipality's SCM Robert Robile to be in charge of the 30% of SMMEs, 3) Motherwell SMMEs to be given first priority on this project, 4) Make sure all Motherwell SMMEs get work before giving work to outside Motherwell SMMEs. Noxolo Portia To create job opportunities For people around the area to get job opportunities so that they can Mdyogolo benefit from this project because it surrounds the area so as long as it gives people jobs then it's fine. Other people who are sitting at home who do not attend such meetings are the ones who benefit the most in such projects because they have connections, so what about us who attend these meetings. So it's a point that you see us.

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11. IMPACT ASSSESSMENT AND MITIGATION MEASURES

11.1 IMPACT ASSESSMENT METHODOLOGY

The EIA Regulations (2014, as amended), prescribe requirements to be adhered to and objectives to be reached when undertaking Impact Assessments. These are noted in the following sections contained within the EIA Regulations (2014, as amended):

• Regulation 982, Appendix 1, Section 2 & Section 3 – Basic Assessment Impact Requirements; and • Regulation 982, Appendix 2 & Appendix 3 – Environmental Impact Assessment Requirements.

In terms of these Regulations, the following should be considered when undertaking an Impact Assessment:

• A description and assessment of the significance of any environmental impact including:  Cumulative impacts that may occur as a result of the undertaking of the activity during the project life cycle;  Nature of the impact;  Extent and duration of the impact;  The probability of the impact occurring;  The degree to which the impact can be reversed;  The degree to which the impact may cause irreplaceable loss of resources; and  The degree to which the impact can be mitigated.

The overall significance of an impact / effect has been ascertained by attributing numerical ratings to each identified impact. The numerical scores obtained for each identified impact have been multiplied by the probability of the impact occurring before and after mitigation. High values suggest that a predicted impact / effect is more significant, whilst low values suggest that a predicted impact / effect is less significant.

The interpretation of the overall significance of impacts is presented in Table 11-1.

Table 11-1: Interpretation of the significance scoring of a negative impact / effect22

Scoring value Significance

High - The impact is total / consuming / eliminating - In the case of adverse impacts, there is no possible mitigation that could offset the impact, or mitigation is difficult, expensive, time- >35 consuming or some combination of these. Social, cultural and economic activities of communities are disrupted to such an extent that these come to a halt. Mitigation may not be possible / practical. Consider a potential fatal flaw in the project.

High - The impact is profound - In the case of adverse impacts, there are few opportunities for mitigation that could offset the impact, or mitigation has a limited effect on the impact. 25 - 35 Social, cultural and economic activities of communities are disrupted to such an extent that their operation is severely impeded. Mitigation may not be possible / practical. Consider a

22 Source: adapted from Glasson J, Therivel R & Chadwick A., 1999: Introduction to Environmental Impact Assessment, 2nd Edition. pp 258. Spoon Press, United Kingdom.

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Scoring value Significance

potential fatal flaw in the project.

Medium - The impact is considerable / substantial - The impact is of great importance. Failure to mitigate with the objective of reducing the impact to acceptable levels could render 20 – 25 the entire project option or entire project proposal unacceptable. Mitigation is therefore essential.

Medium - The impact is material / important to investigate - The impact is of importance 7 – 20 and is therefore considered to have a substantial impact. Mitigation is required to reduce the negative impacts and such impacts need to be evaluated carefully.

Low - The impact is marginal / slight / minor - The impact is of little importance, but may 4 – 7 require limited mitigation; or it may be rendered acceptable in light of proposed mitigation.

Low - The impact is unimportant / inconsequential / indiscernible – no mitigation required, 0 – 4 or it may be rendered acceptable in light of proposed mitigation.

The significance rating of each identified impact / effect was further reviewed by the Environmental Assessment Practitioner (EAP) by applying professional judgement.

For the purpose of this assessment, the impact significance for each identified impact was evaluated according to the following key criteria outlined in the sub-sections below.

NATURE OF IMPACT

The environmental impacts of a project are those resultant changes in environmental parameters, in space and time, compared with what would have happened had the project not been undertaken. It is an appraisal of the type of effect the activity would have on the affected environmental parameter. Its description includes what is being affected, and how.

SPATIAL EXTENT

This addresses the physical and spatial scale of the impact. A series of standard terms and ratings used in this assessment relating to the spatial extent of an impact / effect are outlined in Table 11-2.

Table 11-2: Rating scale for the assessment of the spatial extent of a predicted effect / impact

RATING SPATIAL DESCRIPTOR

7 International - The impacted area extends beyond national boundaries. 6 National - The impacted area extends beyond provincial boundaries. Ecosystem - The impact could affect areas essentially linked to the site in terms of significantly 5 impacting ecosystem functioning. Regional - The impact could affect the site including the neighbouring areas, transport routes and 4 surrounding towns etc. Landscape - The impact could affect all areas generally visible to the naked eye, as well as those 3 areas essentially linked to the site in terms of ecosystem functioning. Local - The impacted area extends slightly further than the actual physical disturbance footprint and 2 could affect the whole, or a measurable portion of adjacent areas.

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RATING SPATIAL DESCRIPTOR

Site Related - The impacted area extends only as far as the activity e.g. the footprint; the loss is 1 considered inconsequential in terms of the spatial context of the relevant environmental or social aspect.

SEVERITY / INTENSITY / MAGNITUDE

This provides a qualitative assessment of the severity of a predicted impact / effect. A series of standard terms and ratings used in this assessment which relate to the magnitude of an impact / effect are outlined in Table 11-3.

Table 11-3: Rating scale for the assessment of the severity / magnitude of a predicted effect / impact

RATING MAGNITUDE DESCRIPTOR

Total / consuming / eliminating - Function or process of the affected environment is altered to the 7 extent that it is permanently changed.

Profound / considerable / substantial - Function or process of the affected environment is altered to 6 the extent where it is permanently modified to a sub-optimal state.

Material / important - The affected environment is altered, but function and process continue, albeit 5 in a modified way.

Discernible / noticeable - Function or process of the affected environment is altered to the extent 4 where it is temporarily altered, be it in a positive or negative manner.

Marginal / slight / minor - The affected environment is altered, but natural function and process 3 continue.

Unimportant / inconsequential / indiscernible - The impact temporarily alters the affected 2 environment in such a way that the natural processes or functions are negligibly affected.

1 No effect / not applicable

DURATION

This describes the predicted lifetime / temporal scale of the predicted impact. A series of standard terms and ratings used in this assessment are included in Table 11-4.

Table 11-4: Rating scale for the assessment of the temporal scale of a predicted effect / impact

RATING TEMPORAL DESCRIPTOR

Long term – Permanent or more than 15 years post decommissioning. The impact remains beyond 7 decommissioning and cannot be negated.

3 Medium term – Lifespan of the project. Reversible between 5 to 15 years post decommissioning.

Short term – Quickly reversible. Less than the project lifespan. The impact will either disappear with 1 mitigation or will be mitigated through natural process in a span shorter than any of the project phases or within 0 -5 years.

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IRREPLACEABLE LOSS OF RESOURCES

Environmental resources cannot always be replaced; once destroyed, some may be lost forever. It may be possible to replace, compensate for or reconstruct a lost resource in some cases, but substitutions are rarely ideal. The loss of a resource may become more serious later, and the assessment must take this into account. A series of standard terms and ratings used in this assessment are included in Table 11-5.

Table 11-5: Rating scale for the assessment of loss of resources due to a predicted effect / impact

RATING RESOURCE LOSS DESCRIPTOR

Permanent – The loss of a non-renewable / threatened resource which cannot be renewed / 7 recovered with, or through, natural process in a time span of over 15 years, or by artificial means.

Long term – The loss of a non-renewable / threatened resource which cannot be renewed / 5 recovered with, or through, natural process in a time span of over 15 years, but can be mitigated by other means.

Loss of an ‘at risk’ resource - one that is not deemed critical for biodiversity targets, planning goals, 4 community welfare, agricultural production, or other criteria, but cumulative effects may render such loss as significant.

Medium term – The resource can be recovered within the lifespan of the project. The resource can be 3 renewed / recovered with mitigation or will be mitigated through natural process in a span between 5 and 15 years.

Loss of an ‘expendable’ resource - one that is not deemed critical for biodiversity targets, planning 2 goals, community welfare, agricultural production, or other criteria.

Short-term – Quickly recoverable. Less than the project lifespan. The resource can be renewed / 1 recovered with mitigation or will be mitigated through natural process in a span shorter than any of the project phases, or in a time span of 0 to 5 years.

REVERSIBILITY / POTENTIAL FOR REHABILITATION

The distinction between reversible and irreversible impacts is a very important one and the irreversible impacts not susceptible to mitigation can constitute significant impacts in an EIA (Glasson et al, 1999). The potential for rehabilitation is the major determinant factor when considering the temporal scale of most predicted impacts. A series of standard terms and ratings used in this assessment are included in Table 11-6.

Table 11-6: Rating scale for the assessment of reversibility of a predicted effect / impact

RATING REVERSIBILITY DESCRIPTOR

7 Long term – The impact / effect will never be returned to its benchmark state.

Medium term – The impact / effect will be returned to its benchmark state through mitigation or 3 natural processes in a span shorter than the lifetime of the project, or in a time span between 5 and 15 years.

Short term – The impact / effect will be returned to its benchmark state through mitigation or natural 1 processes in a span shorter than any of the phases of the project, or in a time span of 0 to 5 years.

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PROBABILITY

The assessment of the probability / likelihood of an impact / effect has been undertaken in accordance with ratings and descriptors provided in Table 11-7.

Table 11-7: Rating scale for the assessment of the probability of a predicted effect / impact

RATING PROBABILITY DESCRIPTOR

1.0 Absolute certainty / will occur

0.9 Near certainty / very high probability

0.7 – 0.8 High probability / to be expected

0.4 - 0.6 Medium probability / strongly anticipated

0.3 Low probability / anticipated

0.2 Possibility

0.0 - 0.1 Remote possibility / unlikely

11.2 MITIGATION

In terms of the assessment process, the potential to mitigate the negative impacts is determined and rated for each identified impact and mitigation objectives that would result in a measurable reduction, or enhancement of the impact, are taken into account. The significance of environmental impacts has therefore been assessed taking into account any proposed mitigation measures. The significance of the impact “without mitigation” is therefore the prime determinant of the nature and degree of mitigation required.

12. IMPACTS IDENTIFIED

The preferred and only site alternative is the upgrading of the existing R335 between Motherwell and Addo. The site is considered to be the only alternative, as the existing road, in its present state, poses health and safety risks to road users due to its uneven horizontal and vertical geometry, lack of road shoulder and overtaking lanes, unsuitable drainage and bridges that no longer safely fulfil their requirements. In addition, the road is a very busy transport (commercial, private and tourism) route. Based on the characterisation of the site, the specialist studies conducted and construction works that will be required to implement the upgrade, the following potential impacts to the receiving environment have been identified:

• Watercourse and wetland disturbance as a result of construction activities; • Impacts to soils resulting in topsoil loss and erosion during construction; • Impacts to surrounding vegetation during construction; • Impacts to local fauna during construction; • Air quality deterioration and increase in noise pollution as a result of construction activities; • An increase in construction traffic as a result of construction activities; • The impact of construction waste as a result of construction activities; • Positive socio-economic impacts; • Potential to disturb existing infrastructure during construction;

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• Safety and security impacts associated with construction activities; and • Potential disturbance to items of heritage and palaeontological significance during construction.

The impacts identified for the proposed activity and the associated mitigation measures which directly and indirectly relate to the Listed Activities being applied for, are provided in Table 12-1.

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Table 12-1: Construction phase impacts identified and associated mitigation measures

CONSTRUCTION RELATED IMPACTS

IMPACT DESCRIPTION MITIGATION

Soil preservation • Physical disturbance of the soil and plant removal may result in • Proper and timely back filling of excavations; reuse of the excavated earth and proper and erosion control soil erosion; disposal of surplus excavated soil will be implemented; • Potential impacts include compaction, physical removal and • Excavated soil must be retained and be returned in the reverse order to which it was potential pollution by hydrocarbons; removed so as to re-establish the original soil profiles as best as possible; • Construction related activity such as excavations for • Excavations must be refilled immediately after construction is complete; underpasses, culverts and drainage lines can affect the soil • In excavations, soil must be compacted to match the porosity of the surrounds; stability causing soil erosion; • Soil erosion prevention measures must be implemented such as gabions, sand bags etc. • Insufficient stormwater management can lead to erosion, whilst energy dissipaters should be constructed at any surface water outflow points. The destabilisation of banks and sedimentation of the watercourses; site must be monitored weekly for any signs of off-site siltation and erosion. All areas and impacted by earth-moving activities will be re-shaped post-construction to ensure natural • Loss of excavated soils due to incorrect management measures flow of runoff and to prevent ponding. All exposed earth will be rehabilitated promptly with and construction activities. suitable, indigenous vegetation to stabilize the soil; • Exposed soils are to be quickly vegetated so as to prevent erosion and the establishment of alien plants; • No surplus soil or other such material may be disposed of in the watercourses / wetlands; • All areas within the construction footprint must be regularly checked for signs of erosion. If erosion is evident, corrective action must be taken; • Topsoil must be stripped and appropriately stockpiled for later use in rehabilitation works; • Stockpile areas must be appropriately managed and maintained for wind and water erosion during the construction phase of the project; and • Ensure that appropriate stormwater structures are designed prior to construction and implemented during construction; • Ensure that all road sections situated on slopes incorporate stormwater diversion; • Ensure that all stormwater structures are designed in line with both SANRAL and DWS requirements; • All the relevant permits must be obtained from DWS prior to commencement of any activities onsite; this includes areas within 100 m of a river/stream and areas within 500 m of a wetland; • Develop and implement an Erosion Action Plan that aims to monitor and respond to erosion events; • Rehabilitate disturbed areas as soon as possible after construction; • All erosion problems observed should be rectified as soon as possible, using the appropriate erosion control structures and vegetation techniques; • All cleared areas (not used for the development footprint) should be vegetated with indigenous perennial shrubs and grasses from the local area as soon as possible; and

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IMPACT DESCRIPTION MITIGATION

• Natural vegetation (scrubs & trees) that was removed onsite may be used as soil stabilizers by placing them on cleared areas if natural recovery is slow. Wetlands and • Due to the highly erodible soils the risk of impacts is considerable • The watercourses must be left in a stable condition post-construction. This is to be watercourses and the consequences would be additional sedimentation of the determined by the ECO in conjunction with the Engineer. If necessary, a specialist is to be system and some (limited) secondary degradation of the called to site to confirm whether watercourse rehabilitation measures are sufficient; biodiversity; • Should the stockpiling of soils be required, the topsoil and the subsoil must be placed • Change in the sub-surface movement / percolation of water in the separately and at a point which is designated by the ECO. The soil must then be returned wetlands / pans can lead to the formation of preferential flow to the excavation in the reverse order to which it was removed so as to re-establish the channels which can set off further erosion; original soil profiles as best possible; • Risk of contamination of the watercourses by leaking plant and • It is recommended that any riparian plants which are excavated should be set aside and equipment during construction; be kept moist until they can be returned for planting during the rehabilitation phase; • Risk of contamination of the watercourses by the storage of • A rigorous programme of alien weed control must be implemented and sustained until the dangerous goods within the site camp; vegetation cover along the alignment is well established and complete; • Risk of contamination of the watercourses through leakages from • As much as it is possible, works within the watercourses should be planned during the low the on-site ablution facilities (mobile chemical toilets); flow periods of the year to limit the risk of potential spillages; • Risk of contamination of the watercourses by construction • No plant or equipment must be parked within 100m of the edge of any watercourse. Plant materials (concrete, cement, rebar and spoil material stockpiles) and equipment must be parked at designated parking areas; during the construction phase; and • All plant and equipment must be checked on a daily basis for leaks, any plant that is found • Risk of contamination of the watercourses by domestic waste to be leaking must be removed off site for maintenance; (food containers, plastic, paper etc.) during the construction • All stationary machinery must be equipped with a drip tray to retain any oil leaks; phase • Emergency plans must be in place in case of spillages; • The site camp must be located as a minimum 100m away from the edge of the delineated watercourses and wetlands; • All dangerous goods must be stored in bunded areas providing for 110% of the capacity of the dangerous goods to be stored; • All construction waste material (concrete waste, metal, shutter-boards, etc.) that finds its way into the watercourses must be removed by hand; • All collected waste must be accumulated in a designated area no less than 50m from the delineated edge of the watercourse or outside of the 1:100 year floodline (whichever is the greatest). Collection from this designated area must be conducted on a weekly basis with the material being disposed of at a registered municipal landfill facility; • All concrete mixing must occur on impermeable surfaces; • Domestic waste must be collected in waste bins that are located on site. The content of these bins must be cleared on a daily basis to a collection point in the site camp from where the waste can be removed on a weekly basis. The collected waste must be disposed of at a registered municipal landfill facility; • A designated eating area must be identified no less than 50m from the delineated edge of

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IMPACT DESCRIPTION MITIGATION

the watercourse or within the site camp. This eating area must be used by the labour during their eating breaks; • Waste bins must be placed at this designated eating area for use by the labour; • Under no circumstances are materials to be stored within a watercourse, or the 1/100year floodline of a watercourse (whichever is the greatest); • Water Quality Monitoring must be implemented prior to and during construction:  Identification of two sampling locations, one upstream and one downstream of the bridge locations, before construction on the bridges can commence.  Representative, monthly water samples must be taken at these locations during the preceding three (3) months before construction is to commence. This will enable the determination of the baseline water quality in the watercourses. The analysis criteria for the samples must make provision for the following parameters: ➢ Turbidity; ➢ Petrochemicals (oil, diesel, etc.); and ➢ pH.  Further water sampling events need to be undertaken on a monthly basis for the duration of the construction phase of the structures.  Monthly Water sampling events must extend for a period of 3 months after the cessation of the construction of the structures.  The results of this analysis process must form part of the monthly reporting during the project management meetings. • Aquatic Monitoring must be implemented prior to and during construction;  The aquatic ecological condition in the watercourse must be monitored to determine any occurrence of contamination as a result of the construction activities. To this end, the following monitoring principles must be applied:  Identification of two sampling locations, one upstream and one downstream of the bridge locations, before construction on the bridges can commence.  A SASS monitoring event to be undertaken two (2) months before the construction activities are to commence at these sampling sites. This will enable the determination of the baseline water quality in the watercourses.  Further SASS monitoring events need to be undertaken on a quarterly basis (every three months) for the duration of the construction phase of the structures.  The final SASS monitoring event must be scheduled to be 3 months after the cessation of the construction of the structures.  Feedback on the results of the SASS monitoring must be provided during the project management meetings of the month that the monitoring event took place. • It is suggested that this monitoring be conducted by an independent Environmental Control

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IMPACT DESCRIPTION MITIGATION

Officer (ECO) on a monthly basis for the duration of the construction phase; and • During decommissioning, all construction and decommissioned material is to be removed from the watercourses. Water Resources • Impacts on surface and ground water quality as result of the • An appropriate number of toilets (1 toilet for every 20 workers) must be provided for following: labourers during the construction phase. These must be maintained in a satisfactory - Contamination of ground and surface water and soil; condition and a minimum of 100m away from any water resources and outside of the - Accidental spillages of petrochemicals from vehicles and 1:100-year floodline; equipment, or concrete; • Appropriate silt control mechanisms must be installed around all soil excavations and - The additional hardened surfaces created during stockpiles in close proximity to watercourses / pans to prevent silt from entering these construction will increase the amount of stormwater runoff, systems; which has the potential to cause erosion and create • Should any excavations require dewatering, this is to occur through an adequately turbidity; designed silt trap prior to discharge. All silt traps are to be regularly monitored and - Poorly managed construction sediments waste and maintained to ensure efficient and effective use; hazardous waste; • Watercourse bank slopes must be planted with appropriate and locally occurring - Poor sanitation practices of construction workers; indigenous vegetation; • Polluted water bodies will be detrimental to aquatic life as well as • No surplus soil or other such material may be disposed of in the channels; to the health of people relying mainly on the river and streams as • A method statement (MS) is to be developed by the engineer / contractor, and reviewed by sources of water for drinking and other domestic uses; and the ECO, confirming the establishment of the coffer dam for the construction / • Waste generated during the construction phase may enter the decommissioning of the Coega River Bridge, and the widening of the Sundays River environment through surface water runoff; Bridge. Construction activities are not to commence prior to the coffer dam MS being • The establishment of coffer dams is to be confirmed via input from approved; and all relevant parties. • Appropriate measures must be taken to prevent the pollution of water courses and other water resources. Flora and fauna • Vegetation will be cleared adjacent to the existing alignment for • Minimization of vegetation clearing, and careful cutting of ground vegetation must be the widening of the road; implemented; • Loss of locally endemic Syncarpha recurvata found in the road • All construction fronts are to be rehabilitated with vegetation cover which matches that of verge at Grassridge; the surrounds; • Topsoil and vegetation may be lost during construction works; • Speed limits must be strictly adhered to by construction staff; • Faunal strikes by speeding construction vehicles; • The harvesting of plants and / or animals on site, by construction staff, must be prohibited; • Harvesting of muthi / traditional healing plants by construction • No animals are to be killed on site; staff; • Weekly toolbox talks are to be undertaken with all site staff regarding environmentally • Killing of snakes / fauna by construction staff; specific content including reference to working sensitive environments (wetlands / • Disturbance of the site may lead to encroachment of alien plant watercourses), the importance and protection of indigenous vegetation, soil erosion species on-site and into the surrounding areas; control, alien vegetation control, waste control etc. Copies of the presentation, with an • The realignment of the centre line of the road may impact attached signed register are to be kept in the on-site environmental file at all time; negatively on flora and fauna of Tregathlyn Game Farm, which is • It is not anticipated that the realignment of the centre line will impact the flora and fauna of bisected by the R335 road; and Tregathlyn Game Farm, as the realignment will still be situated within the existing

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IMPACT DESCRIPTION MITIGATION

• Protection of wildlife along the portions of the upgrade, at which SANRAL road reserve. In addition, all fences must be maintained to ensure animals the wildlife underpasses are to be constructed. cannot escape the game farm; • Prior to the construction of the underpasses, the contractor is to confirm with the Engineer how construction will take place to ensure that protection of wild animals within the areas at which the underpasses are to be constructed e.g. fencing of the underpass during construction until it becomes operational; • The proposed study is not situated within any formal National, Provincial or Local Protected areas; • The proposed road crosses the informal Tregathlyn Game Farm; • The Kaapse Grysbok Private Nature Reserve and the Zwartkops Valley Nature Reserve are located within 5 km of the proposed study area; • The Addo Elephant National Park is located within 5 km of the uppermost section of the study area (near Addo); and • Activities may not be carried out in threatened or protected ecosystems without first gaining authorisation for such activities. It should however be noted that no threatened or protected ecosystems as listed in NEM:BA have been identified within the study area and thus this is not considered to be relevant to this project. Loss of Natural Vegetation • The construction footprint must be surveyed and demarcated prior to construction • During the construction phase the development will require the commencing; clearance of natural and indigenous vegetation. Vegetation • No construction activities will be allowed outside the demarcated footprint; onsite is classified as Vulnerable (Grassridge Bontveld; Sundays • Construction activities must be limited , wherever possible, to areas where degraded Spekboom Thicket; Sundays Valley Thicket), Endangered vegetation is found; (Sundays Doringveld Thicket & Motherwell Karroid Thicket) and • Cleared vegetation must not be piled on top of natural vegetation but must be stockpiled Least Threatened (Koedoeskloof Karroid Thicket). temporarily on bare ground and removed to a registered landfill site. Alternatively, cleared vegetation may be mulched and used as ground cover during rehabilitation. Loss of SCC’s • The contractor's staff must not harvest any natural vegetation; • A total of three (3) species are listed as protected in the Eastern • Search and rescue must be implemented for all locally endemic plant species e.g. Cape PNCO list, and one (1) on the NEM:BA list. One (1) Syncarpha recurvata which are found within the upgrading / widening / construction protected tree species (Sideroxylon inerme) is likely to occur as footprint, prior to construction commencing. SCCs must be identified, rescued and stored scattered individuals within the study area. Two (2) species for rehabilitation and applicable permits must be obtained prior to removal of such. The classified as Endangered in the SA Red Data list was recoded. top layers of soil must be collected and stored for use in the rehabilitation phase; There may be a number of additional species of conservation • Should Syncarpha recurvata be found adjacent to but not within the construction footprint concern that could be found on site during construction that were i.e within a 50m distance from the construction footprint, it is to be fenced off for the not observed during this study. The loss of SCCs is likely to duration of the construction phase, to prevent being impacted upon; occur where these occur within the road upgrade footprint and • No forest or trees that form part of a forest or forest association may be damaged or where disturbance cannot be avoided. It should be noted that in destroyed without a permit; terms of Syncarpha sp and Sideroxylon sp., very few individuals • Development that comes within 50 metres of forest must be closely monitored during the

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of these have been observed within the development footprint. construction phase; • No protected tree species may be damaged or destroyed without a permit; • Several individual Sideroxylon inerme (Milkwood) trees have been identified to occur as scattered individuals within the study area and is listed as protected in terms of the NFA. hould these trees be disturbed, permits from the Department of Agriculture, Forestry and Fisheries (DAFF) will be required; and • No protected species may be removed or damaged without a permit. Alien vegetation • Disturbance of the site may lead to encroachment of alien plant • Alien plant encroachment must be monitored and prevented as outlined in the EMPr encroachment species onto the site; (Appendix 6); • Alien vegetation may encroach onto the surrounding lands due to • An invasive species management, control and eradication plan must be developed by the poor on site alien vegetation control. This poses a threat to the contractor, in accordance with CARA and Section 11 of NEMA for implementation agricultural potential of the lands in close proximity to the throughout the construction footprint and for the duration of the construction and development; and rehabilitation phases; • The proposed development will result in the clearance of alien • All exposed earth must be rehabilitated promptly with suitable vegetation to stabilize the vegetation within the project area. This will be a positive impact as soil and prevent the growth of alien vegetation; and alien invasive species will be removed and subsequently this will • It is important to note that the any use of fertilisers must be undertaken with caution and also improve the condition of the existing natural vegetation within must not be allowed, in any circumstances, to run into any drainage lines to avoid any the study area. possible eutrophication impacts. Waste • There is potential for the site and surrounding areas to become • All waste generated on-site during construction must be adequately managed. Separation polluted if construction activities are not properly managed (e.g. and recycling of different waste materials is supported; oil spills, litter from personnel on-site, sewage from ablutions etc.); • All solid wastes must be disposed of at a registered landfill site and records maintained to and confirm safe disposal; • Waste generation could be created by the following: • Adequate scavenger-proof refuse disposal containers must be supplied to control solid - Solid waste - plastics, metal, wood, concrete, stone, asphalt waste on-site; tec. • It must be ensured that existing waste disposal facilities in the area are able to - Construction waste – construction materials, bags, accommodate the increased waste generated from the proposed construction; aggregates etc. • Chemical waste must be stored in appropriate containers and disposed of at a licensed - Chemical waste- petrochemicals, resins and paints; and disposal facility by a licenced service provider; - Sewage as may be generated by employees. • Use of portable sanitation facilities must be enforced (these facilities must be kept clean so that they are a desired alternative to the surrounding vegetation). These facilities must also be monitored and serviced regularly so as to prevent contamination of the watercourses; • The construction site must be inspected for litter on a daily basis. Extra care must be taken on windy days. Precautions must be taken to avoid litter from entering the watercourses; • Soil that is contaminated with, e.g. cement, petrochemicals or paint, must be disposed of at a registered waste disposal site and is NOT to be deposited into the watercourses; • Site personnel (i.e. construction staff) must undergo environmental training and be educated on keeping any vegetation disturbance to a minimum and on the separation and

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correct disposal of different types of waste; • Drip trays and spill kits must be readily available for use should any construction machinery develop a leak; • Chemical waste must be stored in appropriate containers and disposed of at a licensed disposal facility by a licenced service provider where necessary; • All plant to be used for construction within watercourses is to be kept free of excess oil / fuel residue; and • Any leftover material must be appropriately disposed of. Hazardous materials • Hazardous (diesel, oils, cement) waste will be generated during • It must be ensured that all hazardous contaminants are stored in designated areas that are the construction phase and if spilled can cause contamination of sign-posted, lined with an appropriate barrier and bunded to 110% of the volumes of liquid the surrounding environment, including the watercourse. being stored to prevent the bio-physical contamination of the environment (ground and surface water and soil contamination). Hazardous substance storage must not take place within 100m of a watercourse / wetland or within the 1:100 year floodline. Bunded areas must contain a valve to allow draining of spillages / contaminated rainwater for appropriate disposal at an appropriately registered land fill; • All plant and equipment must be checked on a daily basis for leaks, any plant that is found to be leaking will be removed off site for maintenance; • No plant or equipment must be allowed to be parked within 50m of the identified wetland area; • Any significant spills on-site must be reported to the relevant Authority (e.g. Department of Water and Sanitation / Municipality etc.) and must be remediated as per the EMPr (Appendix 6); • Any contaminated water associated with construction activities must be contained in separate areas or receptacles such as Jo-Jo tanks or water-proof drums, and must not be allowed to enter into natural drainage systems; and • Routine checks must be done on all machinery on site and these must be kept in good working order. No washing of machinery or vehicles may take place on site and container washing must take place in a designated, bunded washing areas. Heritage • The Sundays River bridge was constructed in 1942 and by • Development will need to be done under an EC PHRA – BE Unit NHRA 1999, Section 34 implication formally protected by the NHRA 1999. The site site alteration permit. It is recommended that the permit application be made, and receives automatic SAHRA / EC PHRA protection as a site of considered by the EC PHRA – BE Unit, for the tenure of construction as per the EA, in the High Significance with a Provincial Grade II Field Rating. event of a positive EA being issued for the proposed development; Development will directly impact on the bridge; • Development will directly impact on the bridge, requiring demolition thereof to meet • The Coega River bridge is in excess of 60-years old and therefore development requirements in terms of the project proposal. Development will need to be receives heritage protection status in terms of the NHRA 1999. done under an EC PHRA – BE Unit NHRA 1999, Section 34 site demolishment permit. It is The site receives automatic SAHRA / EC PHRA protection as a recommended that the permit application be made, and considered by the EC PHRA – BE site of High Significance with a Provincial Grade II Field Rating; Unit, for the tenure of construction as per the EA, in the event of a positive EA being

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IMPACT DESCRIPTION MITIGATION

and issued for the proposed development; • A Colonial Period homestead site, still in use and fairly well • The realignment of the centre line of the road will probably entail the removal of the conserved is older than 60 years of age and formally protected by boundary trees and entrance structure of the Colonial Period homestead. As such, the NHRA 1999. The site receives automatic SAHRA / EC PHRA development will need to be done under an EC PHRA – BE Unit NHRA 1999, Section 34 protection as a site of High Significance with a Provincial Grade II site demolishment permit. It is recommended that the permit application be made, and Field Rating is situated within 15m from the proposed considered by the EC PHRA – BE Unit, for the tenure of construction as per the EA, in the development corridor. event of a positive EA being issued for the proposed development; and • Although development will encroach on the conservation fence of the Colonial period homestead, it will not impact thereon: Development will be restricted to the existing road reserve. Palaeontology • Although the Palaeontological sensitivity of these areas is rated • The EAP and ECO must be informed that sediments of the Sundays River and Kirkwood as very high no fossils have been found during a field survey. Formations of the Uitenhage Group, the Witteberg Group of the Cape Supergroup as well Thus, the impact on palaeontological material along the as the Algoa Group has a high to very high Palaeontological Sensitivity; Motherwell-Addo upgrade is negligible and regarded as • Should fossil remains be discovered during any phase of construction, either on the insignificant; and surface or exposed by fresh excavations, the ECO responsible for these developments • It is therefore recommended that no further palaeontological must be alerted immediately. Such discoveries ought to be protected (preferably in situ) heritage studies, ground truthing and/or specialist mitigation are and the ECO should alert SAHRA (South African Heritage Research Agency) so that required for the commencement of this development, pending the appropriate mitigation (e.g. recording, sampling or collection) can be taken by a discovery or exposure of any fossil remains during the professional palaeontologist; construction phase • Mitigation by a palaeontologist must entail the collection and recording of fossils as well as obtaining important data of the surrounding sedimentary matrix within the proposed development footprint. Excavation of this fossil heritage will require a permit from SAHRA and the material must be housed in a permitted institution. All fieldwork and reports should meet the minimum standards for palaeontological impact studies developed by SAHRA and; • These recommendations must be incorporated into the Environmental Management Plan for the Motherwell road upgrade project. Air quality and noise • Potential dust generation from soil stripping, excavations, • All construction machinery and equipment must be regularly serviced and maintained to pollution decommissioning of structures, vehicle traffic on the access roads keep noise, dust and possible leaks to a minimum, as per the requirements of the EMPr and motor vehicle fumes will have an impact on air quality; Appendix 6); • Potential increase in noise from the operation of machinery and • Road and soil stockpile dampening must be undertaken to prevent excess dust during equipment, as well as the construction vehicle traffic; and construction; • Dust and noise will be created during the construction phase, • Operational Hours: No works shall be executed between sunset and sunrise and on the which may impact on the local community and game farms non-working and special non-working days as stated in the construction contract unless adjacent to the site. otherwise agreed between the Engineer and Contractor; • Construction personnel must be made aware of the need to prevent unnecessary noise such as hooting and shouting; and

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CONSTRUCTION RELATED IMPACTS

IMPACT DESCRIPTION MITIGATION

• Burning of waste must be prohibited. Traffic • Increase in construction vehicles in the area; • In order to accommodate this traffic and to ensure the smooth flow of traffic during • Possible lane closures, traffic delays and congestion during the construction, a detailed traffic plan has been developed. This plan is based on construction construction phase; being split into two phases and that each phase will take approximately three years to • Slow-moving construction vehicles on the surrounding roads may complete. Two transport alternatives have been provided to R335 road users, namely; cause accidents; and  Providing alternative routes which may be used to access Addo Elephant Park; and • If not properly maintained, increased use of existing surrounding  Including specific written requirements in the engineering and tender documents which road infrastructure, for access purposes by construction stipulate that the road shall allow bi-directional traffic flow at all times and that no personnel, may cause damage to the road surface. closures shall be allowed during school holiday period. A STOP/GO will only be used at the Sundays River bridge, while the bridge is being widened. • The planned STOP/GO construction will have a negative impact on traffic and cycling times of 15 minutes will be implemented which should minimise waiting times; and • The following measures are proposed to be implemented along the portion of the R335 proposed for upgrading:  The construction of temporary deviations at major culverts.  Offset construction with 7m from the existing road centreline in order to accommodate bi- directional traffic while constructing the road in two halves.  Constructing the road alongside the existing road without affecting traffic. Effectively greenfields construction.  Half width construction with STOP and GO control during daytime and temporary traffic lights during night time.  Temporary widening on one side of the existing road to allow two-way traffic while the other half of the road is constructed. When the first half is complete, traffic is switched over and the newly constructed roadway and the originally widened section is constructed. Existing • If not properly mitigated against, existing powerlines (e.g. NMBM • Notify affected stakeholders as soon as possible, e.g. NMBM Electricity Division infrastructure Electrical Infrastructure 11kV overhead line), streetlights, • No-go areas must be demarcated prior to construction commencing; disturbance pipelines, cables and telephone lines could be damaged during • Cognisance must be taken of existing infrastructure at all times in order to prevent construction activities; and disruptions and damage; • An IAP noted that there are old graves opposite to SASSA office • Suitable rehabilitation of infrastructure damaged by construction activities must be near the old salt pan. undertaken where necessary; • Warning and danger signs must be erected at all times and trenches must be demarcated; and • The AIA noted that the Motherwell cemetery is located adjacent to the proposed upgrade footprint, but will not be impacted upon by the upgrade. Socio-Economic / • Creation of job opportunities for skilled personnel (e.g. engineers, • Inform the surrounding communities and general public of the proposed activity as soon as Community specialists etc.) and non-skilled personnel (e.g. labourers); possible. This will serve to ease potential social anxiety; Page | 118 DBAR: R335 Upgrade, Motherwell to Addo 41643

CONSTRUCTION RELATED IMPACTS

IMPACT DESCRIPTION MITIGATION concerns • Skills development of the local community through employment • The appointment of local contractors / SMME’s, must be undertaken in a transparent and opportunities; fair process and not be influenced by politicians and community members with vested • Social anxiety may arise should the surrounding community not interests (as per comments from IAP’s); be adequately notified of the proposed activity; • Local people e.g. from Motherwell, must be employed where ever possible; • Social anxiety may arise should the surrounding community not • A Community Liaison Officer should assist in raising any concerns / complaints noted by be adequately engaged with during the appointment of the affected community to the contractor and vice versa; contractors during the construction phase; • Safe disposal of waste must be undertaken and unwanted littering and discharge of waste • Possible positive economic benefits to local suppliers of building must be prohibited; materials as goods and services may be purchased from these • The Contractor must instruct all workers to act in a responsible manner within the working entities during the construction phase; premises; • Hazardous disposal of solids waste and improper sanitary • Skips in the working areas must be provided to collect waste and then finally disposed to conditions generated by construction workers may cause pollution an approved landfill site; of the surrounding environment and affect the health of local • A sub-consultant to SANRAL has been appointed to consult directly with impacted land people; owners regarding the alignment, purchasing of land, etc. Legal processes will be followed • Concerns from community members that they would lose their to ensure that land owners rights are observed and adhered to. houses due to the upgrading of the R335; and • Concerns from community members about a section of private property, where the new servitude will extend into, being taken by SANRAL. Safety and security • There is potential for construction labour to trespass onto • Health and safety requirements must be prepared by the contractor and will include the neighbouring properties; and need for all staff to use personnel protective equipment (PPE); • Construction personnel / construction vehicles – movement of • A first aid box must be kept at a proper and easily accessible place; construction personnel and vehicles may pose a potential health • The general public must be prohibited from all construction sites / areas; and safety risk to road users and local residents. • Any construction personnel found to be trespassing must be subjected to a disciplinary hearing; • Liaison with the surrounding community is to be maintained throughout the construction process; • Where necessary, security guards are to be placed on site to protect all construction and project related personnel; • Suitable and sufficient safety signage is to be established along the entire construction footprint. Signage is to be visible during the day and at night; and • The traffic management plan is to make provision for accidents (both during the day and night) along the alignment, as well as relevant mitigation measures for accidents.

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Table 12-2: Operational phase impacts identified and associated mitigation measures OPERATIONAL PHASE IMPACTS

IMPACT DESCRIPTION MITIGATION

Rehabilitation of During the Operational Phase, poor rehabilitation of disturbed areas • All cleared areas must be continuously rehabilitated with indigenous vegetation post- disturbed areas may lead to the permanent degradation of ecosystems as well as allow establishment. The site will be considered as rehabilitated when 75% or more of the alien vegetation species to encroach on natural vegetation. impacted areas are covered by primary growth (grasses and/or scrubs); and • Regular monitoring for erosion after construction to ensure that no erosion concerns have developed as result of the construction phase. Invasion of Alien During the operational phase the loss of natural vegetation will increase • The approved Alien Vegetation Management Plan must be implemented during the Species the potential invasion by alien plant species. This, coupled with the lack operational phase to reduce the establishment and spread of undesirable alien plant of implementation of the Alien Vegetation Management Plan may result species; and in large scale alien plant invasion. • Alien plants must be removed through appropriate methods such as hand pulling, application of chemicals, cutting, etc. as in accordance to the NEMBA: Alien Invasive Species Regulations.

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13. IMPACT ASSESSMENT

Table 13-1: Impact assessment findings in relation to the proposed construction activities

Severity / intensity Significance Significance Spatial extent Duration Resource Reversibility Probability Nature of project impact / magnitude without with loss mitigation mitigation Without With Without With Without With Without With Without With

Soil preservation and 4 2 4 2 3 1 7 7 1 1 0.3 25 3.9 erosion control

Flora and fauna 2 1 7 3 7 3 7 7 3 0.6 0.2 18 3.4

Air quality and noise 2 1 3 1 1 1 1 1 1 0.7 0.2 5.6 1 pollution

Traffic impacts 4 2 5 3 1 1 1 1 1 1 1 12 8

Waste impacts 3 1 4 1 3 1 3 3 1 0.9 0.3 14.4 2.1

Hazardous materials 3 2 5 3 3 1 5 7 3 0.5 0.2 11.5 2.8

Water resources / Contamination of surface 3 2 5 3 3 1 5 7 3 0.5 0.2 11.5 2.8

and groundwater ConstructionImpacts

Socio-economic / 2 2 5 2 1 1 3 1 1 0.6 0.3 7.2 2.7 Community concerns

Existing infrastructure 4 1 5 1 1 1 1 1 1 0.6 0.1 7.2 0.5 disturbance

Safety and security 2 1 3 2 3 1 1 3 1 0.4 0.2 4.8 1.2 impacts

Wetland and watercourse 5 3 5 4 3 1 7 3 3 1 0.4 23 7.2 impacts

Heritage 1 1 1 1 2 3 3 4 3 4 3 44 33

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Palaeontology 1 1 1 1 1 1 1 1 1 0.1 0.1 0.5 0.5

Alien vegetation 3 1 5 2 7 3 4 7 3 1 0.7 22 9.1 encroachment

14.7 5.5 Overall impact significance

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13.1 SIGNIFICANCE

Based on the outcome of the significance scoring noted in Table 13-1, the overall significance impact without mitigation, is considered to be MEDIUM i.e. the impact is important to investigate, with a score of 14.7. However, with the implementation of the mitigation measures provided, the overall significance impact is considered to be LOW i.e. the impact is marginal / slight / minor, with a score of 5.5.

The greatest impact of significance is considered to be the impact to heritage resources i.e. the Sundays and Coega River Bridges; these impacts cannot be avoided as the bridges will have to be upgraded, reconstructed and decommissioned. However, as per the Archaeological Impact Assessment Report, permits can be applied for with the relevant competent authority, and in this way the impact will be somewhat mitigated. Additional impacts of significance relate to the potential for soil and associated erosion impacts associated with the type of intrinsic development i.e. excavations for bridges, culverts, underpasses and road widening, to be undertaken. Impacts to wetlands and watercourses are also considered significant and are associated to works within the Coega and Sundays River Bridges, and pans situated adjacent to the alignment. However, with the correct mitigation measures employed as noted in Table 12-1 and as per the EMPr (Appendix 6), these impacts can be significantly reduced whist still allowing for the upgrading of the R335. As such, the Preferred Site Alternative and the Preferred Technology Alternatives are the only options for consideration.

14. ENVIRONMENTAL IMPACT STATEMENT

Based on the assessment undertaken, the following conclusions are made:

• In terms of the proposed development, the application is for the upgrading of an existing alignment; therefore, an area of disturbance already exists; • Extensive groundwork, engineering design requirements and the various specialist studies undertaken were all used to determine the impacts to the receiving environment, for the preferred route, which is considered the only feasible route alignment. Therefore, no layout alternative has been provided for the proposed road upgrade; • The preferred technology is the widening of the Sundays River bridge, as well as the construction of a new Coage River Bridge, and the decommissioning of the old Coega River Bridge as it is the only feasible alternative which meets the need and desirability of the application; • It is not anticipated that the proposed development will in any way impact upon the protected areas found within 5km of the site, or the Addo Elephant National Park found within 10km of the site. In contrast, the proposed development will improve access to the Addo Elephant Park, which could result in increased visits to the park, and surrounding area. With regards to the Tregathlyn Game Reserve, the upgrading will take place within the SANRAL road reserve, and as such the game reserve will not be impacted upon.

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Assuming all phases of the project adhere to the conditions stated in the EMPr (Appendix 6) it is believed that the impacts associated with the proposed development will have limited to no significant, adverse, long term environmental impacts on the surrounding environment.

Positive impacts associated with the development include:

• Provision of a safe, reliable and sustainable transport route between Port Elizabeth and Addo for commercial, agricultural, tourist and commuter use; • An upgraded transport network reduces road user costs, costs of maintenance and capital costs; • Skills development and knowledge transfer in the respective communities through job creation during the construction phase; • Continued local economic growth and development (e.g. tourism, agriculture and cement industries); • Compliance with the respective planning documents namely the NMBM Comprehensive Integrated Transport Plan: 2011/12, the NMBM Metropolitan Spatial Development Framework and the SRVM IDP.

It is perceived that these positive impacts will be long term and have sustainable benefits for the district.

It must be ensured that the construction phase, in no way, hampers the health of any of the ecological systems identified on site, and that post-construction and decommissioning rehabilitation leaves the surrounding environments in an as good, if not better, state.

After the construction phase of the project, the contractors must ensure that all hazardous materials are removed from the site and that rehabilitation of watercourses is undertaken according to the requirements of the EMPr (Appendix 6), as well as the recommendations put forward by the Wetland and Vegetation Specialists (Appendix 5). Alien vegetation control measures are to be strictly implemented throughout the construction phase.

The alien plant management programmes that are implemented during the construction phase must be maintained during the construction defects liability period. It is important that drainage lines, wetlands and the working strip are monitored regularly during the construction and operational phases for alien plant infestations and appropriate control measures are undertaken when necessary.

The Applicant is responsible for maintenance along the R335 route, following the closure of the Defects Liability Phase. The decommissioning of the Coega River bridge and associated rehabilitation of the river is to be undertaken to the satisfaction of the ECO and a designated Wetland / Watercourse Specialist.

15. RECOMMENDATIONS OF THE EAP

The proposed development should not result in impacts on the natural or social environment that are detrimental, nor result in undue risks to the natural environment. The nature and types of negative

Page | 124 DBAR: R335 Upgrade, Motherwell to Addo 41643 impacts do not outweigh the potential benefits of this project, provided that the short term localised impacts of the construction phase are adequately mitigated. In this regard, an EMPr has been compiled and is attached to this report (see Appendix 6). It is recommended that monthly EMPr monitoring takes place by an independent Environmental Control Officer (ECO) to ensure that the requirements of the EMPr are being correctly implemented, thus ensuring the protection of the surrounding environs during construction.

It is the recommendation of the EAP that the following management and mitigation measures be incorporated into any project approvals which may be issued:

• A rigorous programme of alien weed control must be implemented and sustained until the vegetation cover along the road alignment is well established and complete; • Areas of endemic and rare / endangered vegetation situated adjacent to the road alignment are to be fenced off for the duration of the construction phase; • Search and rescue operations are to be implemented prior to construction commencing, for all rare and endangered plant species found within the proposed road realignment route; • The recommendations of the Wetland Assessment Report must be adhered to (Appendix 5); • The recommendations of the Heritage Impact Assessment and the Palaeontological Assessment must be adhered to (Appendix 5); • The recommendations of the Vegetation Impact Assessment and Botanical Survey must be adhered to (Appendix 5); • The traffic mitigation measures must be strictly implemented along the road realignment route. Suitable warning signage must be erected along the entire working footprint; • Weekly environmentally orientated toolbox talks are to be undertaken with all site staff and records thereof maintained; and • Should fossils be observed during construction, the appointed Palaeontological Impact Assessment consultant must be notified immediately, and the fossils collected by a suitably qualified palaeontologist.

16. CONSTRUCTION TIMEFRAMES

Construction will be split into two phases and it is anticipated that each phase will take approximately three years to complete. Consequently, should no delays be encountered, it is anticipated that the construction period will last six years. However, the procurement process prior to construction commencing may be a lengthy process and is also dependent on future project projections and budgets within SANRAL. It is therefore requested that the Environmental Authorisation, if issued by the Competent Authority, be valid for a period of 10 (ten) years from date of signature, to the date of completion of construction / rehabilitation, in order to account for any unforeseen construction plan deviations.

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