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ENVIRONMENTAL STUDIES Proposed integration of the Concentrated Solar Park (CSP) into the Eskom network

DEA REF: 12/12/20/2606 to 12/12/20/2610 NEAS REF: DEA/EIA/0000767/774/778/785/786/2011

Issues and Responses Report Version 4

This Issues and Responses Report (IRR) captures the comments and issues raised by stakeholders during the five separate environmental studies and the proposed amendment of an existing environmental impact assessment for the proposed integration of the Concentrated Solar Park (CSP) just outside into the Eskom network.

As part of the announcement phase, a Background Information Document (BID), with a comment and registration sheet was distributed to potentially interested and affected parties during November 2011. The BID was also handed out and site notices were put up during the second week of November 2011 along the various alternative corridors being investigated for this proposed development. An advertisement was also placed in various newspapers along the proposed corridors during November 2011 to announce this project. The Draft Scoping Reports (DSRs) were available for public review from 23 January to 2 March 2012. Stakeholders were notified of the availability of the DSRs for comment through the placement of advertisements and notification letters. Meetings were also held from 6 to 9 February 2012 in Kathu, Olifantshoek, Upington, , and to discuss the content of the DSRs with stakeholders. Comments and issues raised at these meetings and as a result of the public review process of the DSR were captured in this report which were an appendix to the two Final Scoping Reports.

The two Draft Environmental Impact Reports (DEIRs), three Draft Basic Assessment Reports (DBARs) and the Amendment to an existing EIA were available for public review from 8 November 2012 to 25 January 2013. Stakeholders were notified of the availability of these various reports for comment through the placement of advertisements and notification letters. Meetings were held from 19 to 21 November 2012 in Kathu, the Olifantshoek district, Upington, Kakamas and Kenhardt to discuss the content of these reports with stakeholders. Comments and issues raised at these meetings and as a result of the public review process are captured in Version 4 of this report.

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TABLE OF CONTENTS

1 ENVIRONMENTAL PROCESSES...... 1 2 ALTERNATIVE ROUTES ...... 6 (2.1) Solar Park to Ferrum (Kathu) ...... 12 (2.2) Solar Park to Nieuwehoop ...... 15 (2.3) Solar Park to Aries (near Kenhardt) ...... 18 3 BIOPHYSICAL COMMENTS ...... 20 (3.1) Avi-fauna ...... 20 (3.2) Soils ...... 21 (3.3) Water-related matters ...... 22 (3.4) Climate ...... 23 (3.5) Biodiversity ...... 24 (3.6) Electromagnetic fields ...... 25 (3.7) Ecology ...... 26 (3.8) Visual...... 26 4 SOCIO-ECONOMIC COMMENTS ...... 27 (4.1) Social...... 27 (4.2) Land Use ...... 28 (4.3) Health issues ...... 29 5 CONSTRUCTION ...... 29 (5.1) Deterioration of roads ...... 30 6 TRANSMISSION LINE SERVITUDE ...... 31 7 OTHER ISSUES ...... 31 Issues and Responses Report (Version 4) iii 12726

(7.1) Solar Park ...... 35 8. DRAFT REPORTS – COMMENTS RECEIVED ...... 38 (7.1) Main Reports ...... 38 (7.2) Biophysical Report ...... 45 (7.2) Aquatic Report ...... 50 (7.3) Appendix F: Impact Assessment...... 52 (7.4) Appendix G: EMPr ...... 54 (7.4) Issues and Responses Report ...... 54 (7.5) General ...... 55

Issues and Responses Report (Version 4) 1 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES 1 ENVIRONMENTAL PROCESSES 1 The feasibility of the proposed project should be Mr Albert van Niekerk, Registration sheet Response by EAP: investigated. In this study, the specific area and its Klipkoppies, PO Box 1831, November 2011 The aim of the EIA and the specialist studies special features should be assessed. Upington, 8800 will be to determine the feasibility as well as the impacts of the project. 2 Why can the Solar Park not be built where there is Mr Theo Spengler, Rooiwal Registration sheet Response by EAP: a need for power such as in Sishen? That will Farmers Association, November 2011 The bulk of the power from the CSP will be minimise the length of the proposed power lines Olifantshoek and other fed into the Upington area and the Sishen- that has to be constructed now. stakeholders Saldanha railway line, not the mine. In Public meeting in addition a solar development has to be in an Mr John Becker, Stellaland Upington at area where there is enough sunlight to 18:00:30 on 7 generate the power, so the location of the February 2012 to plant was placed in an area with very high discuss the DSR solar radiation, and water is also vital for this process and the plant needs to be near a major water source such as the . 3 The local municipalities must be invited to these Mr Theo Spengler, Rooiwal Public meeting in Response by EAP: meetings in order to take part in the discussions Farmers Association, Olifantshoek on 6 All local and district municipalities in the regarding proposed projects taking place in the Olifantshoek February 2012 to study area have been invited. district. discuss the DSR 4 Who is funding this project? Mr Theo Spengler, Rooiwal Public meeting in Response by EAP: Farmers Association, Olifantshoek on 6 Eskom is funding the whole integration Olifantshoek February 2012 to project (transmission lines and substation discuss the DSR upgrades and construction). 5 How do you communicate with the local Stakeholder at meeting. Public meeting in Response by EAP: communities and municipalities? Olifantshoek on 6 Information on this project has been sent to February 2012 to affected communities, landowners and discuss the DSR municipalities and they were also invited to attend the stakeholder meetings. 6 Investigate the: Mr Rudi Oosthuizen, PO Box Comment sheet Response by EAP: impact on my farm, 3, Olifantshoek on 20 February The impact on the receiving environment the environment, 2012 (including all affected farm portions and the aesthetic impact of a transmission line, servitudes), aesthetics, access control and access control, deterioration of roads have been assessed, deterioration of roads and rated and mitigated in the basic assessment Issues and Responses Report (Version 4) 2 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES possible theft. reports by the EAP, with guidance and input from all the relevant specialists on the project. 7 Please send me all documentation relating to this Mr Daniel Schwab, Emails in January Response by EAP: process including the existing Environmental BrightSource Energy Inc, 2012 Zitholele Consulting has been instructed by Authorization and full EIA report including Eskom to focus more on the size (footprint) appendices and scoping report. that will be utilised than the exact number of heliostats, due to the various options BrightSource would like to request to allow many available in terms of heliostat technology. more heliostats than requested in the amendment. The reason is that BrightSource’s technology is based on using many more heliostats of smaller size for better and efficient performance saving money and natural resources. 8 Any proposed development which may take Lasantha Naidoo Sent via Email on Response by EAP: place within the water resource as defined in the Department of Water Affairs 6 November 2012 All reports and documents pertaining to the National Water Act, 1998 (Act No. 36 of 1998) Environment and Recreation Solar Park Integration Project (EIAs and Bas) (NWA) constitutes a section 21 water use in 185 Schoeman Street have been sent to the relevant DWA terms of chapter 4 of the NWA and requires a Room 435 B Sedibeng Regional Office. water use authorisation obtained from this Building Department Should the activity (proposed solar park and solar power plant) be identified as a section 21 (c) water use [impeding and diverting the flow of water in a water course] and/or a Section (i) water use [altering the bed, banks course and characteristics of a water course] taking place within the extent of a water course (the area within the 1:100 year flood line or delineated riparian habitat, whichever is the greatest, and/or within a 500m radius from the boundary of a wetland) the applicant must apply for a Section 21 (c) and (i) water use authorisation. Consequently, the review and comments /recommendations of environmental reports are a Regional Office competency. In line with DWA water use authorisation business process, and in Issues and Responses Report (Version 4) 3 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES order to avoid unnecessary setbacks in your environmental authorisation processes, please ensure that all environmental reports for review are submitted to your Regional Office ()-the Regional office will consult E&R should specific specialist information/input be required. 9 Was the Integrated Development Plans (IDPs) Mr Ivan Steenkamp, Northern Public meeting in Response by EAP: and Spatial Development Frameworks (SDF) of Cape Department of Kathu on 19 The study team looked at the IDPs and SDFs local government taken into consideration? Transport, Safety and Liaison November 2012. of the potentially affected local authorities, because it is stipulated in the environmental assessment processes. These proposed development are aligned with the SDFs. Linear projects such as this will, however, not have a great impact on the infrastructure of the local authorities. 10 Did you do a Social and Labour Plan and what are Mr Ivan Steenkamp, Northern Public meeting in Response by EAP: the advantages for local communities? Cape Department of Kathu on 19 A Social and Labour Plan is only needed for Transport, Safety and Liaison November 2012. a mining right application. A Social Impact Assessment is being done to assess and address social impacts. These proposed projects fall under Eskom Transmission which has a small labour requirement compared with Eskom Generation that needs thousands to build a power station. 11 Why is there a difference in the timelines of the Mr Ivan Steenkamp, Northern Public meeting in Response by EAP: study team and Eskom? Cape Department of Kathu on 19 There was a small delay in the study, but this Transport, Safety and Liaison November 2012. will not affect construction timelines. 12 Try and keep the proposed line between Upington Mr Theo Spengler, Rooiwal Public meeting Response by EAP: and Kathu next to the N14, because there is an Farmers Association, near Olifantshoek Noted. Comment has been taken into existing line and servitude that can be used. Olifantshoek on 19 November account in the consideration of final route 2012. alternatives. 13 You have not yet been on my farm to investigate Mr Rudi Oosthuizen, PO Box Public meeting at Response by EAP: potential impacts. 3, Olifantshoek Malley near It is impossible to visit each and every farm Olifantshoek on 19 in a project of this magnitude and only the November 2012 affected farms will be investigated to obtain Issues and Responses Report (Version 4) 4 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES an overall impression of each area. The impact on the receiving environment (including all affected farm portions and servitudes), aesthetics, access control and deterioration of roads have been assessed, rated and mitigated in the basic assessment reports by the EAP, with guidance and input from all the relevant specialists on the project. 14 Please make sure that inter alia Section 21 (c) and Mr Pieter Ackerman E-mail: 05 Response by EAP: (i) water use authorisations are not required. DWA: Sub Directorate November 2012 A Water Use Licence application is in the Environment and Recreation process of being finalised for areas where a It is very difficult in determining the floodlines for water use (i.t.o. Section 21 of the NWA) is small catchment and therefore stormwater triggered by an aspect of the proposed development. management is very important. Stormwater management best practices will be incorporated into the construction and operational/ maintenance phases of the different project from the onset to ensure that environments sensitive to erosion will not be adversely affected by the proposed projects. 15 Acknowledges letter dated 22 October 2012. Mr Maxwell Sirenya Letter: 05 Response by EAP: Director-General November 2012 Noted. All reports and documentation will be In terms of the National Water Act (Act no. 36 of DWA sent to the Regional Office (Northern Cape) 1998) the Sub-Directorate: Environment and for assessment as advised. Recreation’s responsibilities are toward ensuring compliance with regards to Inegrated Environmental Management (IEM) as it relates to water resource management and specifically with section 21(c) (impending and diverting the flow of water in a water course) and section 21(i) (altering the bed, banks, course and characteristics of a water course) water uses.

This unit’s role is mainly focused on the development, regulation, control and management of policy and protocol; performance and compliance monitoring, evaluation and auditing; Issues and Responses Report (Version 4) 5 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES and providing training and capacity building to the DWA Regional offices for the afore-mentioned sub-directorate’s responsibilities.

Any proposed development which may take place within the water resource as defined in the National Water Act, 1998 (Act No. 36 of 1998) (NWA) constitutes a section 21 water use in terms of chapter 4 of the NWA and requires a water use authorisation obtained from this Department. Should the activity (proposed solar park and solar power plant) be identified as a section 21(c) water use (impending and diverting the flow of water in a water course) and/or section (i) water use (altering the bed, banks, course and characteristics of a water course) taking place within the extent of a water course (the area within the 1:100 year flood line or delineated riparian habitat, whichever is the greatest, and/or within a 500m radius from the boundary of a wetland) the applicant must apply for a Section 21(c) and (i) water use authorisation.

Consequently, the review and comments /recommendations of environmental reports is a Regional Office competency, In line with DWA water use authorisation business process, and in order to avoid unnecessary setbacks in our environmental authorisation processes, please ensure that all environmental reports for review are submitted our Regional Office (Northern Cape) – the Regional Office will consult E&R should specific specialist information/input be required.

Please take note that a comprehensive, hard copy set of documents must be sent to the Regional Office. Issues and Responses Report (Version 4) 6 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES 2 ALTERNATIVE ROUTES 1 Please provide us with detailed maps of the final Mr Limpho Mongoato, Registration sheet Response by EAP: routes for the proposed power lines. Department of Agriculture, November 2011 Detailed maps will be provided at the public Forestry and Fisheries, meetings planned for February 2012. Pretoria Detailed maps will be sent to the different farmer associations to share with their members. 2 Please provide us a detailed map of the routes for Mr Andries Bodenstein, Registration sheet Response by EAP: us to provide detailed comment. Transnet Properties, Inland November 2011 Detailed maps will be provided at the public Region meetings planned for February 2012. Detailed maps will be sent to the different farmer associations to share with their members. 3 Are these lines only meant to transfer the energy Mr Donovan Richmond, Seeff Public meeting in Response by EAP: that will be generated by the Eskom CSP into Properties Upington at 09:30 400 kV lines will transport the 100MW to be Eskom’s national grid? on 7 February generated by Eskom as well as energy to be 2012 to discuss generated by the approved Independent the DSR Power Producers to the west and the Department of Energy’s site to the east of the Eskom site into Eskom’s national grid. 4 Will there be any additional transmission lines to Mr Fanie Lerm, Public meeting in Response by EAP: connect Upington Solar Park with the national Middelpost 60 Kakamas on 8 No, only the routes that are being grid? February 2012 to investigated in this study will be needed to discuss the DSR link Solar Park with the grid. 5 Will the final transmission line routes to be used Mr Nico Hugo, Rosynebos Public meeting in Response by EAP: only be available in March 2013? Kakamas on 8 Yes, once the specialist studies have been February 2012 to completed, the final report with the discuss the DSR recommended routes will be handed in to the Department of Environmental Affairs who will then decide which route must be used. 6 We would like to see the final EIA and details Mr C Cloete, Depot Letter on 20 Response by EAP: relating to the rail crossings when the final plans Engineering Manager February 2012 Final EIA reports and plans will be made are completed. (Kimberley South), Transnet available in the final EIR public review period for your comments. 7 The South African National Roads Agency Limited Ms Colene Runkel, Statutory Reply sheet on 27 Response by EAP: (SANRAL) required as final plan of your routes Control and Land February 2012 Final EIA reports and plans will be made with regards to all national roads. Should there be Administration, SANRAL, available in the final EIR public review period Issues and Responses Report (Version 4) 7 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES the need to cross a national road, then you have Private Bag X19, Bellville, for your comments. to apply for the necessary authorisation. 7535 8 There’s no clear distinction between the Eskom Mr Tieho Motloung, Project Email on 9 March Response by EAP: CSP plant and the DoE Upington Solar Park in the Manager: Solar Park Corridor, 2012 FSR amended to be clearer. reports. CEF Group 9 Comments on the Draft Scoping Report – Mr Tieho Motloung, Project Email on 9 March Response by EAP: Project 1: Manager: Solar Park Corridor, 2012 FSR for the Aries – Solar and Nieuwehoop – CEF Group Solar updated with all questions raised. Page 4 – The Government is proposing to establish a solar park at KLIPKRAAL farm and not on Olyvenhoutsdrift. The Government is not going to spend R150 billion but proposing to establish a R150 billion Solar Park programme. Page 5 – Is Eskom’s plant 100MW or 150MW CSP? What do you mean by ‘kicking off the development of the Solar Park’? Have the park parameters been defined? The Eskom CSP is not the first project in the Solar Park even if it may be the first project to use the Solar Park substation. Page 5 – can you provide references of World Bank backing for CSP? Page 5 – The DoE is NOT negotiating with any IPP’s. Furthermore, no technology selection has been finalised yet! The DoE/CEF will execute a feasibility study to determine the viability of the 5GW Solar Park Programme. If this proves to be feasible, the development of the first Solar Park in Upington will begin following Cabinet approval. Page 7 – The BA (1 and 3) do not indicate clearly which 132KV lines are for Eskom Plant and which are the DoE Solar Park. Page 19 – Section 3, are you focusing only on the Eskom CSP? Issues and Responses Report (Version 4) 8 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES Page 19 – The transformer rating for the Solar Park substation has relevance. Is it not 132/400KV step up transformer? Page 21 – Is the standard line voltage 7200 Volts in RSA? Page 58 – Is the history of the SAN community correct? This is a very sensitive matter. 10 Comments on Draft Scoping Report – Project 2 Mr Tieho Motloung, Project Email on 9 March Response by EAP: Most comments made for Project 1 are Manager: Solar Park Corridor, 2012 FSR for the Ferrum– Solar updated with all applicable to Project 2. CEF Group questions raised. Page 19 – Is the focus on the Eskom CSP and not the Upington Solar Park (USP). The focus should be on the USP since the Eskom CSP is ancillary to the 1 GW from the USP. 3. Proposals -CEF to review the preliminary final report for accuracy before it is issued -The Upington Solar Park EAP to liaise closely with Zitholele for the Klipkraal EIA. 11 Comments on: Mr NJ Toerien, Sub- Letter on 13 Response by EAP: Project 1 - Solar Park to Aries and Solar Directorate: Sustainable March 2012 Noted. All this will be included during the Park to Nieuwehoop; and Resource Management, specialist studies during the next phase of Project 2 - Solar Park to Ferrum Department of Agriculture, this EIA. The Department of Agriculture, Land Reform and Land Reform and Rural Rural Development is guided by Act 43 of 1983. Development With the development of these activities the developer must take care of the following: Article 7.(3)b of Regulation 9238: CONSERVATION OF AGRICULTURE RESOURCES, 1983 (Act 43 of 1983) Utilisation and protection of vleis, marshes, water sponges and water courses 7.(1) “….. no land user shall utilize the vegetation in a vlei, marsh or water sponge or within the flood area of a water course or within 10 meters horizontally outside such flood area in a manner Issues and Responses Report (Version 4) 9 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES that causes or may cause the deterioration of or damage to the natural agriculture resources.” 3)(b) “cultivate any land on his farm unit within the flood area of a water course or within 10 meters horizontally outside the flood area of a water course”.

Take also care of the following: Who is the current landowner; will it be a subdivision of land or a lease contract between the developer and the landowner? Rezoning will also be applicable because the land use will change from the current agricultural status. The Department foresee no problems in the development as mentioned above as long as the developer adheres to the articles of Act 43 of 1983. 12 Om ‘n beter verstandhouding tussen die Boere- Mnr Tim Spangenberg Letter: 10 January Die Boerevereniging se voorstelle is in ag vereniging en die projekspan te bewerkstellig het Sekretaris: Rooiwal 2013 geneem gedurende die oorweging van projek die Boerevereniging die lyne name gegee en Boerevereniging alternatiewe. punte aangebring. (Vir volledige beskrywing verwys na Translation: Aanhangsel XX) Response by EAP: Recommendation from the Farmer’s Moontlike voordele van die Lupanilyn: Association has been taken into account 1. Van punt A tot verby punt I (±60 km) is dit during the assessment of the project langsaan of baie naby aan die N14 en ander alternatives. Your comments have also been bestaande hoofpaaie. taken into account by relevant specialists for 2. Vanaf punt I tot byna by punt M (±40 km) is dit consideration. The project team welcomes langs ‘n bestaande lyn waar reeds ‘n goeie the opportunity to engage with the Farmer's sewituutpad is. Association in a constructive manner. 3. Ons meet die Skeerwaterlyn vanaf punt A oor punte 2, 3 en 4 tot by punt M ± 119 km en dit is dan ± 18 km langer as die Lupanilyn. 4. By die Skeerwaterlyn kruis die lyn alle paaie ± 90°, behalwe by punte 3 en 4 waar dit vir ± 12 km vêr sowat 1 tot 1.7 km vanaf ‘n swak Issues and Responses Report (Version 4) 10 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES ondergeskikte (of B ) pad loop. 5. Die Pearsonshuntpad, die Malleypad (R3331) en die Bartonpad is nie hoofpaaie nie en baie swak. 6. Daar is verskeie wild- en jagplase onder die Skeerwaterlyn en geen een waarvan ons weet onder die Lupanilyn nie. 7. Water onder die Skeerwaterlyn is baie beperk, terwyl water onder die Lupanilyn baie meer geredelik beskikbaar is. 8. Die Skeerwaterlyn loop van punt A tot amper by punt 3(73 Km) in waaisand. Soos jy weet groei daar nie maklik weer gras op kaal waaisand nie, en is rehabilitasie moeilik en duur. 9. Die Skeerwaterlyn gaan oor ‘n relatief ongerepte gebied, wat as ontvlugtingsoord dien vir baie mense wat in die oorheersende nywerheidsgebied (Kathu) woon. Om diesulkes te ontneem van ‘n geleentheid om dan en wan weg te kom van geraas, mynstof, spoorlyne, kragdrade en ligte sal ‘n onvergeefbare euwel wees.

Ons vertrou dat u aandag aan ons voorstelle sal gee, want ons glo dit is in die beste belang van al die betrokke partye en die omgewing.

Translation: To create a better understanding between the Farmers’ Association and the project team, the Farmer’s Association allocated names and points to the lines.

(For detailed description of the references, refer to Appendix XX)

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COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES Possible advantages to the Lupani Line: 1. From point A past point I (±60km) the route would be adjacent or very close to the N14 and other existing main roads. 2. From point I to close to point M (±40km) the route would be adjacent to an existing line and there is an existing servitude road which is in good order. 3. We’ve measured the Skeerwater line from point A over points 2, 3 and 4 up to point M (±119km) which is then ±18km longer than the Lupani Line. 4. The power line crosses all the road at ±90º at the Skeerwater line, except points 3 and 4 where for ±12km it would approximately 1km to 1.7km away from a substandard (or B) road. 5. The Pearsonshunt Road, the Malley Road (R3331) and the Barton Road are not main roads and in poor condition. 6. There are various game and hunting farms on the Skeerwater Line and none, that we know of, on the Lupani Line. 7. There are limited water available under the Skeerwater Line as under the Lupani Line the water resource is readily available. 8. The Skeerwater Line runs from point A close to point 3 (73km) in ‘blowing sand’. As the team know, grass does not easily grow back on bare blow sand and rehabilitation would be difficult and costly. 9. The Skeerwater Line would traverse a relative unspoiled area that is frequented by people who lives in Kathu’s industrial area and who needs a break. To deprived these people this sanctuary (away from noise, mine dust, railway lines, power lines, lights, etc) would be Issues and Responses Report (Version 4) 12 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES unforgivable.

We trust that our proposal would receive attention as we believe that it is in the best interest of all parties concerned in the area.

(2.1) Solar Park to Ferrum (Kathu) 1 Our environment is extremely sensitive for the Mr Theo Spengler, Rooiwal Registration sheet Response by EAP: construction of new roads. As far as possible, Farmers Association, November 2011 The shortest route between two points is construct the proposed power line next to existing Olifantshoek and email on 16 always chosen at first. Then the alternative roads or alternatively on farm boundaries. Farms February 2012 routes will be deviated to avoid major should not be cut in half by transmission lines. obstacles such as mountains, dams, human settlements, etc. However the aim of the EIA and the specialist studies will be to align the EIA routes as best possible within the proposed corridors. Please note that a 2km corridor will be investigated and once approved a servitude will be negotiated with the landowner inside that corridor. 2 The proposed power lines should be built as close Mr Koos Becker, Farms Registration sheet Response by EAP: as possible to the N14 to keep away from the Smalhoek, Koupan and November 2011 An optional alternative route next to the N14 sensitive Kalahari dunes (Duineveld). Witboom and email on 22 was discussed with Eskom. This was There are existing Eskom lines running parallel February 2012 approved and included in the FSR. with the N14. Maybe that servitude can be used Mr Theo Spengler, Rooiwal for this line. Farmers Association, Public meeting in Olifantshoek Olifantshoek on 6 February 2012 to discuss the DSR and email on 16 February 2012 3 According to my knowledge of the terrain the Mr Elias Laubscher, PO Box Email on 27 Response by EAP: Ferrum Solar 2 will be the best route to use. 225, Olifantshoek, 8450 December 2011 Noted. 4 The proposed line from Pearsons Hunt to Kathu Mr Gerrit Nell, PO Box Registration sheet Response by EAP: will clash with existing servitudes for water 28,Olifantshoek, 8450 December 2011 Noted and this will be confirmed during the pipelines next phase of this study. 5 Near Gringley the planned alternative will cross a Mr Gerrit Nell, PO Box Public meeting in Response by EAP: Issues and Responses Report (Version 4) 13 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES ridge at S27 40 48 E22 30 11. If the proposed 28,Olifantshoek, 8450 Olifantshoek on 6 Thank you. Your comments have been taken route is moved one kilometre south to S27 41 28.5 February 2012 to into account. E 22 30 20, the Kalahari Water Pipeline will be discuss the DSR avoided.

6 Why do you have two routes on your map Mr Freddie Drotskie, Gasep Public meeting in Response by EAP: between Solar Park and Ferrum? Olifantshoek on 6 Only one of the two will eventually be used, February 2012 to but both are being investigated to find the discuss the DSR route with the least impact. As part of the EIA process route alternatives have to be provided. 7 Which route is the better option at this stage? Mr Wouter Snyman, Public meeting in Response by EAP: Watermeyer Olifantshoek on 6 This is still not known, because the specialist February 2012 to studies during the next phase will determine discuss the DSR the route with the least impact. 8 The proposed route will cross our private line Mr Riaan Liebenberg, Koupan Public meeting in Response by EAP: going to the Kalahari farms. Farmers Association Upington at 09:30 Crossing another line is not a problem and on 7 February happens regularly. The engineers will 2012 to discuss ensure that the crossing is appropriately the DSR designed so that it does not interfere with the existing line. 9 The red ‘Duineveld’ (sand dune veldt) is very Mr Nico de Wet, Public meeting in Response by EAP: sensitive and does not recover very well after an Environmental Committee, Upington at 14:00 This is one of the main reasons why an impact. For example, the Kalahari pipeline was Orange Agricultural Union on 7 February additional alternative route along the N14 built in 1985 and now (27 years later) erosion is 2012 to discuss was proposed. This route is currently being still a problem. There is only 2% clay in the soil. the DSR investigated by the specialist and will be Please find a route that does not go through the presented all interested and affected parties ‘duineveld’. once specialist studies has been finalised. 10 I understand that an Environmental Control Officer Mr Nico de Wet, Public meeting in Response by EAP: (ECO) will monitor the construction and prevent Environmental Committee, Upington at 14:00 The Environmental Management Programme any environmental impacts. However, my Orange Agricultural Union on 7 February (EMPr) is the only mechanism there is to experience from a line that was built over my farm 2012 to discuss protect the environment during construction. is that the ECO and the contractor socialised the DSR Maybe an Eskom employee should every night. Eskom must find a way to oversee its supervise the contractor as well. The ECO contractors during the construction phase. must be from an independent company. The EMPr will contain a list of telephone numbers of Eskom personnel that can be Issues and Responses Report (Version 4) 14 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES contacted if a landowner is unhappy about something during the construction and operational phases. Eskom also does internal audits without warning a contractor. The Green Scorpions of the Department of Environmental Affairs can also be contacted if something illegal is taking place during construction or even operations. 11 I would like to comment on the Solar Ferrum 2 Mr GFD Becker, chairperson Email on 9 March Response by EAP: line. of the Dwaalhoek Farmers 2012 Comments noted. All these comments have Erosion: The proposed route runs through the Association been taken into account to inform the most soft Kalahari dunes that have grass veld environmentally suitable route for the Solar- vegetation. This area is very sensitive to impacts Ferrum line. and heavy machinery necessary for construction will damage these dunes and veld permanently. This will result in erosion. A good example of this is the Kalahari East pipeline that was built 20 years ago with light machinery. Today erosion is still a problem where the pipeline was built.

Properties: The proposed Solar Ferrum 2 route will cut many small farms about 30 to 60km outside Upington in two which will have a detrimental effect on farming activities. This could also be the case just outside Kathu where there are small farms outside the town.

Roads: Our gravel roads are already in a fragile state due to no maintenance. Even the addition of a few trucks will destroy the gravel top layer. These roads are our line to the outside world and very valuable to us.

Your last paragraph in the Draft Scoping Report Agriculture and land is a good summary of the fears of the local landowners: “The loss of Issues and Responses Report (Version 4) 15 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES agricultural land will most probably be significant for individual landowners….”

I ask on behalf of the whole community that your proposed line be built near an existing tar road and to stay away from the sensitive Kalahari dunes. 12 Should the line go over my property, will I be able Mr Rudi Oosthuizen, PO Box Public meeting at Response by EAP: to determine where it can be constructed? 3, Olifantshoek Malley near The landowner and the Eskom negotiator will Olifantshoek on 19 discuss the exact route within the two November 2012 kilometre wide corridor, however the chosen route must be reasonable and feasible to minimise impacts on the physical and socio- economic environment, while maximising the construction and maintenance aspects of the chosen route. 13 Why do we need a line between Upington and Mr Rudi Oosthuizen, PO Box Public meeting at Response by EAP: Kathu if there are already lines to the south? Build 3, Olifantshoek Malley near Eskom needs to strengthen the whole this line in the existing servitude. Olifantshoek on 19 network to prevent a specific area being November 2012 serviced by only one line. This will increase electricity security if all areas are provided by electricity from more than one line. Should one line go down, then the other line(s) can be used. Where possible new powerlines will be constructed within existing servitudes. Eskom is currently developing bigger and higher towers/pylons that can carry more lines to lessen the impact on landowners.

(2.2) Solar Park to Nieuwehoop 1 Could we please be provided with a map showing Mr Brennie Wiehahn, Registration sheet Response by EAP: the detail of exactly where the power lines are Rodelande Boedery, November 2011 Detailed maps were provided at the public proposed? We would like a detailed map showing Kanoneiland meetings in February 2012. Detailed maps the alternatives from the Solar Park to were further sent to the different farmer Nieuwehoop substation. associations to share with their members. 2 We are situated between the Solar Park and the Mr Fanie Lerm, Registration sheet Response by EAP: proposed Nieuwehoop substation, could you Middelpost 60 November 2011 Detailed maps were provided at the public please provide us with a detailed map? meetings in February 2012. Detailed maps Issues and Responses Report (Version 4) 16 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES were further sent to the different farmer associations to share with their members. 3 Please choose a route running next to the Mr Nico Heyns, Rateldraai and Public meeting in Response by EAP: Kenhardt road, because the current Mr Albert van Niekerk, Upington at 09:30 This was suggested to Eskom and this alternative runs down the middle of my farm. Klipkoppies, PO Box 1831, on 7 February stakeholder alternative was added to the Upington, 8800 2012 to discuss Solar Integration Project as an alternative. the DSR and Investigations into the identified alternatives comment sheet on are currently being finalised by the respective 25 February 2012 specialists. 4 Cross the Orange River along existing bridges. Mr Nico Heyns, Rateldraai Public meeting in Response by EAP: Upington at 09:30 Comment noted. This comment has been on 7 February taken into account during the evaluation of 2012 to discuss potential crossings over the Orange River. the DSR Investigations are currently being finalised by the respective specialists. 5 I have an airfield on my farm and the one Mr Kobus Luttig, Duinveld Public meeting in Response by EAP: alternative runs near the airfield as well as my Upington at Comment noted. The power line cannot be house. 18:00:30 on 7 built close to any registered airfields as the February 2012 to lines provide a flight hazard. discuss the DSR 6 I cannot exactly see where the line will run through Mr Barend Louw, Wildekeur Public meeting in Response by EAP: my farm. Upington at It is still too early in the process to pinpoint 18:00:30 on 7 the exact route of a line. The line on the map February 2012 to is a two kilometre wide corridor that is discuss the DSR currently being investigated. 7 The Orange River is very wide where you would Mr Kobus Luttig, Duinveld Public meeting in Response by EAP: like to cross it with your transmission line. Upington at Comment noted. That is one of the main 18:00:30 on 7 reasons of these public meetings. To get February 2012 to comments and suggestions from landowners discuss the DSR and affected people on what is the best possible solution to a problem. Alternative river crossings are being investigated and will be finalised in due course. Once the specialist reports has been received and approved, and the FEIR completed final responses to these points will be included in the IRR for final public review. 8 Build the lines next to existing roads. Mr John Becker, Stellaland Public meeting in Response by EAP: and Mr Albert van Niekerk, Upington at Noted. Transmission lines may not be Klipkoppies, PO Box 1831, 18:00:30 on 7 constructed in the road servitude and must Upington, 8800 February 2012 to be at least 95 metres away from a tar road. Issues and Responses Report (Version 4) 17 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES discuss the DSR However as per the earlier request, this suggestion was taken to Eskom and additional stakeholder alternatives were identified and were being investigated. 9 I have started in September 2011 with the process Mr Gerhard Kuhn, Farm Letter on 1 March Response by EAP: of sub-dividing Remainder 345/38 and Portion Swartkop, Louisvale, PO Box 2012 Noted, at this stage there are 5 possible 192/38 into 22 properties which are valued at 2431, Upington, 8800 crossings of the Orange River and the R250 000 each for a total value of R5.5 million. adjacent properties. At each crossing a 2 km The proposed power line route goes directly wide corridor will be investigated for across these properties. suitability for use as a crossing point. The land value and developments will be included in the social and land use assessments completed during the EIA phase. Once the route is established an expert land negotiation team will undertake land valuations to ensure that landowners are adequately compensated for losses, should properties be affected. 10 Your recommended route is not the route we Mr Nico Heyns, Rateldraai and Public meeting in Response by EAP: suggested at the previous meeting in February Mr Albert van Niekerk, Upington at 18:00 Comments noted. An alternative route to 2012. Your recommended route runs right through Klipkoppies, PO Box 1831, on 20 November minimise cross-cutting of farmers’ land the middle of our farms. Please investigate Upington, 8800 2012. portions have subsequent to this comment changing this to a route next to the gravel road been included and is currently being between Louisvale and Kenhardt. investigated. The specialists are finalising There is already a telephone line and a small their reports and conclusions and Eskom line running along the road .This road is recommendations regarding cross-cutting of also in good condition. farmers’ land portions will be available for review by the public during the final review period. 11 My farm is next to the Orange where you want to Mr Barend Louw, Wildekeur Public meeting in Response by EAP: cross the river. Eskom must come and discuss the Upington at 18:00 Additional alternative river crossings are route with us grape farmers rather sooner than on 20 November currently being investigated by the EAP and later. We want to further develop our farms, but 2012 specialists. These alternative crossings will we cannot put everything on hold. be presented to all affected parties for further comment during the final public review period once specialists have finalised their reports. Eskom will directly discuss this issue with Mr Louw. Issues and Responses Report (Version 4) 18 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES

(2.3) Solar Park to Aries (near Kenhardt) 1 Why does Eskom need two 400kV lines to Aries? Mr John Becker, Stellaland Public meeting in Response by EAP: Upington at The two lines are needed to transport 18:00:30 on 7 electricity to Aries due to a planned 100% February 2012 to increase in iron ore export on the Sishen discuss the DSR Saldanha railway line. One line is not sufficient to transport that amount of power. 2 This proposed line will run over our property, Mr Michael Stoeltzing, Solar Comment sheet Response by EAP: Olyvenkolk. Energy Land, Olywenkolk. on 14 February Noted, at this stage there are 2 Nieuwehoop 2012 and 3 Aries possible corridors. Each corridor is 2 km wide and will be investigated for suitability and the potential impact to man and environment. The land value and impacts to the land will be included in the social and environmental assessments, and made available for public review once specialist reports have been finalised. 3 I am involved with the planning of a solar photo Mr Johann Strauss, consultant Email on 16 Response by EAP: voltaic (PV) plant(s) close to Aries in the Northern to Solar Energy Land February 2012 Thank you for your email, which makes a lot Cape. The developers have purchased the farm of sense from a planning perspective. The known as Olywenkolk directly bordering the Aries-Neuwehoop issue will be raised with substation to the east. the Negotiator and the Environmental The portion of the farm right next to the substation Advisor involved establishing if your is where the PV plant development is planned. proposed alternatives are within the EIA We have left a considerable corridor of about 200 study area done for that line. It seems as if m wide between our western and southern border the “Second Alternative Aries Nieuwehoop” fence and where Section A starts. I will explain is the most viable option as it only affects why we did this below. one property. There are mainly two issues that I would like to Regarding the Solar Aries 2 x 400kV line you bring under your attention and/or that I would like are also providing valuable information, to address in some or other way. which I think Eskom’s Substation Design The first issue concerns the route of the planned Department needs to tackle as soon as line between Aries and the new substation possible. Normally the final substation Nieuwehoop. The current route goes across the designs are made available later in the EIA southern part where we would like to develop the phase. As an affected party you also provide plant. We would like to know whether it is possible very practical options, which are greatly to reroute the planned line by shifting the line appreciated. slightly to the south. Our preference is that of the ______first alternative, but this rerouting will then be Issues and Responses Report (Version 4) 19 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES subject to the permission by the neighbouring land Your comments have been forwarded to the owner I suppose. Substation Design Department. They have The second alternative route is however entirely not started with the designs as yet, however within our borders. This is part of the reason why in light of your enquiry they have promised to we left a southern 200 m corridor. The other start with the preliminary designs which will reason has to do with another developer to our determine if an extension of Aries substation south that is also planning a power plant of is required or not and the extent thereof. I substantial size. In discussions with Riaan Smit will notify you as soon as these designs (Chief network planner – Western Region) we did become available. come to the conclusion that a second line from The matter regarding the Aries Nieuwehoop Hydra via Kronos to Aries may be necessary line cutting across your property has also somewhere in future. It might just be that with all been forwarded to the relevant persons who of the planned plants in the Aries region, worked on the EIA for that line. They are also especially the one to the south that I have just looking into the matter. Should you have any mentioned, no room will be left to bring in another other queries regarding the Aries line from the south/south-east. Our 200 m corridor Nieuwehoop line you can contact the will at least make sure that such an option remains following persons directly: possible. Now, how do we proceed to have the current planned route rerouted? Vuledzani Thanyani – Eskom Senior Environmental Advisor The second issue is related to the planned Solar Phone: 011 800 5601 Park at Upington and the planned two Email: [email protected] transmission lines running down to Aries. Here Wimpie Henning – Eskom Senior the position of the feeder bay of the line running to Advisor, Negotiations is important. Eskom basically has two Office: 011 800 2962 options. Either you cross at least the line to Email: [email protected] Namibia (very close to Aries) or you expand the ______400 kV busbars to the east, i.e. towards our land, since the line to Namibia is fed by the most We have established that your property is eastern feeder bay. My opinion is that you will within the approved corridor. We have also have to expand the busbars in this case. Now, to established that it is possible to shift the line expand the busbars you have two further options, (within your property boundary), however namely to not shift your security fences to the east because the negotiations on this line (Aries that will leave you with a fairly narrow security Nieuwehoop) has already been completed buffer, or to expand your fences into our land. We and the options signed and exercised the have in principle decided to make this possible by cost of any deviation or shifting of the line leaving the western 200 m corridor. shall be paid by the person proposing the We would however like to discuss this with Eskom deviation. Your proposed alternatives to shift as soon as possible to come to some sort of an the line towards the boundary necessitate agreement. My opinion is that you will have to the addition of two (2) bend towers and the make a decision now already as part of the EIA minor addition on the length of the line. The Issues and Responses Report (Version 4) 20 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES processes that was started, since it will definitely approximate cost for your proposed have an impact on the routing of the lines in the alternatives could be around R2 million. A Aries area that will have a direct influence on us, more accurate quotation may be provided on as well as all possible future developments that request. we might envisage. I would like to propose that we approach this issue proactively, to ensure that the EIA process is not prolonged unnecessary. 3 BIOPHYSICAL COMMENTS

(3.1) Avi-fauna 1 What will be the impact of the proposed lines on Mr Brennie Wiehahn, Registration sheet Response by EAP: birds, especially in the area where the Orange Rodelande Boedery, November 2011 Avifauna have known issues with power lines River has to be crossed? Kanoneiland including electrocutions and flying into the lines. In order to adequately identify the impact to avifauna a specialist study is currently being undertaken and will be finalised in due course.

Additional comment: No electrocution risk is foreseen, as the 400kV tower structures do not pose an electrocution risk. There is a risk of collisions with the earthwire of the line where it crosses major flyways, e.g. the Orange River. In these areas, bird flight diverters would need to be fitted to the earthwire of the line to reduce the risk of collisions. Chris van Rooyen: Avifaunal specialist 2 The sociable weavers make nests in any upright Mr Theo Spengler, Rooiwal Email on 16 Response by Avifauna specialist: structure they can find. We also get a lot of Farmers Association, February 2012 Sociable Weavers will definitely nest in the lightning strikes in this area and veld fires when Olifantshoek towers. There is currently no way of these nests are set alight. This will increase our preventing that. Generally the weavers nest fire insurance. in the base of self-supporting towers and do not interfere with the electricity supply. Instances of structural damage to the towers have been documented after nests caught fire during veld fires. It is unlikely that the nests themselves will cause fires, as this generally happens only on small reticulation Issues and Responses Report (Version 4) 21 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES structures (11-22kV) when the nests are constructed around the insulators on the cross-arms. When the nest gets wet, it can become conductive and cause a short circuit, which sets the nest alight. Chris van Rooyen: Avifaunal specialist

3 There is a breeding pair of fish eagles on an island Mr Gerhard Kuhn, Farm Letter on 1 March Response by Avifauna specialist: that forms part of Portion 104/38. Swartkop, Louisvale, PO Box 2012 The location of the nest would need to be 2431, Upington, 8800 considered when the tower positions are finalised, to prevent disturbance to the birds. I will contact Mr. Kuhn to get more details of the nest position. The proposed lines do not pose an electrocution risk to the birds. Chris van Rooyen: Avifaunal Specialist 4 The big nests of the sociable weavers are a major Mr Ivan Steenkamp, Northern Public meeting in Response by Avifauna specialist: problem in this area. Cape Department of Kathu on 19 Sociable Weavers will definitely nest in the Transport, Safety and Liaison November 2012 towers. There is currently no way of preventing that. Generally the weavers nest in the base of self-supporting towers and do not interfere with the electricity supply. Instances of structural damage to the towers have been documented after nests caught fire during veld fires. Chris van Rooyen: Avifaunal specialist

(3.2) Soils 1 The Kalahari Dunes are extremely sensitive for Mr Jacobus Becker, Farms Registration Response by Biophysical specialist: erosion if the proposed construction is Smalhoek, Koupan and sheet November Comment noted and included in reports. implemented wrongly. Detailed studies with Witboom 2011 Ferrum 1 and 2 routes with dunes present regards to the type of soil have to be done. less suitable than other routes without dunes. Cognisance should also be taken with the low rainfall, prevalence of dunes and its unique plant species. 2 The impact of the service road that will be built for Mr Piet Kotzé, PO Box 69, Public meeting in Response by Biophysical specialist: this line must be investigated due to the fragile Olifantshoek, 8450 Olifantshoek on 6 Comments noted and included in the nature of the soil. February 2012 to specialist reports as well as the EMPr. discuss the DSR 3 Soil erosion is a big problem and must be Mr Nico Heyns and other Public meeting in investigated for the construction sites and access landowners Upington at 09:30 Issues and Responses Report (Version 4) 22 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES roads. on 7 February 2012 to discuss the DSR

(3.3) Water-related matters 1 The amount of water that will be required for the Mr Albert Nicolaas van Registration Response by EAP: construction of the project has to be investigated. Niekerk, Farm Klipkoppies sheet November No water will be extracted from any water 2011 and fax on courses. Where feasible, concrete for tower 24 February 2012 and other foundations will be sourced from a professional service provider. Where batching has to be done, water will be obtained from a water service provider. 2 What will be the impact of the proposed power Mr Brennie Wiehahn, Registration Response by EAP: lines on surface water and wetlands, especially Rodelande Boedery, sheet November In general, transmission line towers have where the Orange River will be crossed? Kanoneiland 2011 negligible adverse impacts on the receiving environment. With regards to river crossings, the main concern is that the river is too wide for the lines to traverse in a single span. If this is the case then a pylon or two will have to be placed inside the water and a water use license applied for with the Department of Water Affairs. If this is the case the WUL will be done as part of this EIA.

Response by Aquatic Specialist: From the aquatic specialist study two preferred crossings points were identified that are narrow enough to allow the crossing of the Orange River without placing any pylons within the river. 3 Please send us information on the application for Mrs Sarah Liebenberg, Farm Registration Response by EAP: a water use licence. Florida sheet November Details regarding the water use licence 2011 applications to DWA will be made available with the next public review period for comment from all stakeholders. 4 The amount of water to be used during Mr Andreas Kuhn, Kalkspruit Registration Response by EAP: construction of the power lines has to be Farmers Association sheet November No water will be extracted from any water investigated. 2011 courses. Where feasible, concrete for tower and other foundations will be sourced from a professional service provider. Where batching Issues and Responses Report (Version 4) 23 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES has to be done, water will be obtained from a water service provider. 5 How will this project impact on water resources? Mr Ivan Steenkamp, Northern Public meeting in Response by EAP: Cape Department of Kathu on 19 Solar Park will use the latest available Transport, Safety and Liaison November 2012. technology to reduce water usage and small quantities of water from a water services provider will be needed when constructing the transmission lines. The Orange River will be crossed at two points and two Water Use Licence Applications are being done to manage this. 6 Where will water be obtained from e.g. Orange Mr Shaun Cloete Public meeting Response by EAP: River, boreholes? Dept of Water Affairs reply sheet No water will be obtained from a watercourse Upington 07 January 2013 or wetland. 7 Where will waste water be stored e.g. pollution Response by EAP: control dams? Waste water will be captured and stored according to best practice construction principles and will be managed and monitored by an ECO through the EMPr. 8 Will any rivers, streams be cross during the Response by EAP: project? It is envisaged that the Orange River will be crossed at two locations. The river crossing alternatives are currently being investigated and finalised by specialists.

(3.4) Climate 1 What will be the impact of the Solar Park on the Mr Brennie Wiehahn, Registration sheet micro climate? Rodelande Boedery, November 2011 Response by EAP: Kanoneiland Please refer to the original CSP EIA report 2 It is possible that the energy used for the solar Dr David Holtzhausen, Farm Registration sheet for details on the impacts of the CSP – park may lead to a local high pressure which may Mooibult November 2011 www.eskom.co.za/eia. This project was impact directly on the rainfall of the area – this completed in 2007 and unfortunately this EIA should be investigated in details is only investigating the integration of the 3 The impact on our local weather patterns should Mr Andreas Kuhn, Kalkspruit Registration sheet power lines and sub stations, not the CSP be investigated, especially the possibility of Farmers Association November 2011 itself. increased temperatures and less rainfall. Issues and Responses Report (Version 4) 24 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES 4 Suggested that possible changes to the climate be Mr Inus Bezuidenhout Answer sheet investigated. Po Box 1 October 2012 Dyasonsklip

(3.5) Biodiversity 1 Will the impact on our traditional medicines be Mr Collin Louw, South African Public meeting in Response by EAP: investigated when you build the transmission San Council Upington at 09:30 The Environmental Management Programme lines? I am thinking especially of the area near on 7 February (EMPr) is used to prescribe to the Nieuwehoop where there is a large concentration 2012 to discuss construction team and the operations team of plants used for traditional medicines. the DSR on how to minimise impact on the environment. Plants used for traditional Mr William Peterson, National Public meeting in medicines will be identified. These plants will Khoisan Council Upington at 18:00 be avoided as far as possible. Should it be on 20 November impossible to avoid, then these plants will be 2012. moved to another location. All plants classed as sensitive that are found in the servitude will be moved.

Response by Biophysical specialist: The report concluded that the various corridors have very similar vegetation, especially the Nieuwehoop lines. It was therefore recommended that once the servitudes have been finalised along with the exact tower positions, then a detailed botanical study of the plants at each of these points should be undertaken. Then the medicinal plant can be removed and donated to the Khoisan and San people. 2 There are camel thorn trees on Portions 104/38, Mr Gerhard Kuhn, Farm Letter on 1 March Response by EAP: Remainder 345/38, 193/38 and 192/38. These Swartkop, Louisvale, PO Box 2012 Noted. Individual tree species of special trees are protected. 2431, Upington, 8800 concern will be identified during the post- authorisation walk-down of the preferred selected route prior to construction, and will be marked. Tree and plant species that require licences/permits from DAFF/DENC for relocation will be obtained prior to any construction works starting. The locations of species that will not be able to be relocated Issues and Responses Report (Version 4) 25 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES will be considered during micro-siting of tower structures. 3 The National Heritage Act is very important to us Mr Johannes Springbok and Public meeting in Response by EAP: and the inherent value of the land and plants must Ms Maggie Aly, Khoisan Upington at 18:00 During the route selection the possibility of be taken into consideration. Make use of our local Community Development on 20 November using local knowledge to assist with avoiding knowledge. 2012 vulnerable flora will be strongly considered. 4 Forestry and Natural Resource Management in Ms Jacoline Mans Letter: 21 January Response by EAP: the DAFF is mainly concerned about the potential Chief Forester: NFA 2013 Protected species that may and do occur in impact on protected tree species. See the National Regulation the study area will be identified by the Forests Act, Act 84 of 1998 (NFA) as amended, specialist in the final specialist report. section 12(1)(d) read with s15(1) and s62(2)(c). Further, all protected tree species occurring The list of protected tree species was published in within the corridor will be identified during the GN 716 of 7 September 2012. No protected tree site walk-down prior to commencement of may be cut, destroyed or disturbed without a construction. If any of these trees will have to license. be relocated of removed relevant permits will be applied for from the Department of The Department is also responsible for the Agriculture, Forestry and Fisheries. implementation and administration of the National Veld and Forest Fires Act, Act 101 of 1998 (NVFFA).

(3.6) Electromagnetic fields 1 Are the electromagnetic fields generated by the Stakeholder. Public meeting in Response by EAP: transmission lines dangerous? Olifantshoek on 6 The transmission lines and supporting towers February 2012 to are developed specifically to minimise any discuss the DSR potential negative impacts originating from electromagnetic fields. The size of the servitudes is also determined in relation to this factor. 2 Will the transmission lines have an impact on Mr Barend Louw, Wildekeur Public meeting in Response by EAP: people wearing an implantable Parkinson Disease Upington at The 400 kV transmission lines are brain device? 18:00:30 on 7 specifically designed that the February 2012 to electromagnetic field levels are kept at a safe discuss the DSR. level that will not harm humans or interfere and at the public with any device. meeting in Upington at 18:00 on 20 November 2012 3 Will the electromagnetic field of the 400 kV line Mr Ivan Steenkamp, Northern Public meeting in Response by EAP: Issues and Responses Report (Version 4) 26 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES affect radio transmissions, satellite transmissions Cape Department of Kathu on 19 A study done by Eskom on 400 kV lines and the health of humans and animals? Transport, Safety and Liaison November 2012. showed that although there is an EMF, it will not affect the health of humans and animals. It will also have no impact on radio and satellite transmissions if a specific distance is kept.

(3.7) Ecology 1 Investigate the impact on the ecology. Ds J P Strauss, PO Box 88, Registration sheet Response by EAP: Groot Brakrivier, 6525 December 2011 The impact on ecology has been investigated by the biophysical specialist. The final specialist report will be made available for public comment during the next public review period. It will also be available as part of the final EIR. 2 The Kalahari vegetation is extremely sensitive and Mr Theo Spengler, Rooiwal Email on 16 Response by EAP: some areas of your proposed route have the very Farmers Association, February 2012 Where possible existing roads will be used rare witgat bome (Sheppard’s trees). The Olifantshoek during the construction and operational/ sandveld is also known to stay bare around new maintenance phases of the Solar Park structures and erosion can become a serious Integration project. problem. Most of the farms on your planned route also have the Kalahari East pipline running over Response by Biophysical specialist: their properties. To have another road running The comments are correct. Therefore the over their farms is asking a lot, because then corridors with an existing access road are another strip of land will be bare for a long time preferred rather than creating a new impact while being rehabilitated. on virgin land. in addition the protected trees have also been included in the report and form part of the EMPr.

(3.8) Visual 1 What about the visual impact of the transmission Ms Estelle Visser Public meeting in Response by EAP: lines? We have many tourists visiting this area Upington at 14:00 All proposed transmission line alternatives and these lines could have a major impact on the on 7 February will have a comparatively similar impact on surroundings. 2012 to discuss the surrounding environment. the DSR Issues and Responses Report (Version 4) 27 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES 2 I am concerned about the visual impact of this Innus Burger, Welgevind Email on 8 Excerpt taken from visual impact assessment proposed project. February 2012 report: “With the exception of the anticipated impacts on rural farmsteads and settlements, The Kalahari is one of the few unspoilt areas in all impacts above are determined to have a the world and plays a vital role in eco-tourism. post mitigation significance of moderate or Tourists from all of the word visit the Kalahari for low. In addition, none are considered to be its unspoilt scenery. Hunters also come to the Kalahari to hunt. fatal flaws from a visual perspective. This is May we suggest that you keep the proposed line based on the relatively low density of visual running alongside the N14 to lessen the visual and receptors beyond the Orange River, and the ecological impacts? existing presence of power line, road and mining infrastructure within the region.

Furthermore, it is the opinion of the visual specialist that the anticipated visual impact is not likely to detract from the regional tourism appeal or numbers of tourists frequenting the area”.

4 SOCIO-ECONOMIC COMMENTS

(4.1) Social 1 The possible impacts on local labour and Mr Andreas Kuhn, Kalkspruit Registration sheet Response by EAP: labourers should be investigated. Farmers Association November 2011 A detailed social impact assessment is currently being finalised by the relevant specialist. 2 I am concerned that no employment will be given Mr Collin Louw, South African Public meeting in Response by EAP: to the San people, because the only jobs available San Council Upington at 09:30 When constructing long transmission lines, are always just for highly skilled people. on 7 February Eskom and its sub-contractors always make Eskom must talk to the San and Khoisan people 2012 to discuss use of local municipalities when looking to regarding employment on this project, because we the DSR employ people for semi-skilled and unskilled are poor and it is not easy to find employment. positions during construction. 3 The people of Kenhardt do not have many Ms Carin Nel, Kenhardt Comment sheet The Eskom contractor must employ a certain employment opportunities and hopefully this on 7 February percentage of local employees during the project will bring new employment opportunities to 2012 construction process. us. Issues and Responses Report (Version 4) 28 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES 4 Investigate the benefits of the project to Mr Inus Bezuidenhout Comment sheet Response by Social specialist: communities and agriculture. Po Box 1 October 2012 Eskom's employment policies ensure that Dyasonsklip local labour is used as much as possible. That labour will be recruited across all vulnerable communities. It must be stated that the construction of a transmission line creates limited opportunities due to the technical nature of the work. Benefits for communities and agriculture will mostly be indirect due to economic development in the region and secondary employment opportunities created by the presence of construction teams in the area. Local procurement will be done as far as practical. 5 Will the Solar Park be accessible to tourists Mr Inus Bezuidenhout Answer sheet Response by EAP: Po Box 1 October 2012 The original environmental impact Dyasonsklip assessment undertaken for the implementation of the Concentrating Solar Power plant (2007) did include the provision of a tourist centre as part of the proposed development. 6 How do we benefit as a community from this Mr William Peterson, National Public meeting in Response by EAP: project? Khoisan Council and Mr Upington at 18:00 Direct benefits include unskilled job Johannes Springbok, Khoisan on 20 November opportunities. The electricity supply of Community Development 2012. Upington will further be more secure resulting in economic growth for the region in the medium to long term.

(4.2) Land Use 1 We farm mainly with sheep and would not like to Mr Albert Nicolaas van Registration sheet Response by EAP: experience any disturbances should the proposed Niekerk, Farm Klipkoppies November 2011 Noted. Please note that once constructed project be implemented. the grazing can continue under the power lines. 2 Property prices in this area are high due to the Mr Theo Spengler, Rooiwal Email on 16 Response by Social specialist: unspoilt nature. There is a lot of potential for more Farmers Association, February 2012 Property prices are influenced by a number game farms in the area and a transmission line Olifantshoek of external factors. It must be noted that a will decrease the value of land. number of existing game farms and national parks do have transmission lines traversing them, so it cannot be excluded as a land use - although it is not ideal. The IA is sensitive to Issues and Responses Report (Version 4) 29 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES existing land uses. 3 We are concerned about the influence the lines Mr Antonie Jacobs, Farms Comment sheet Response by Social specialist: will have on tourism and game farming. We are Spence and Lewis, on 20 February Game farms and transmission lines are not totally against the proposed transmission lines. Olifantshoek, PO Box 3206, 2012 mutually exclusive land use. Although sense Matieland, 7602 of place is important, one should also consider the broader economic context. The route that will be selected will also determine the significance of this impact - if it is mostly adjoining existing infrastructure the impact will be far less.

(4.3) Health issues 1 Investigate the impact on human health. Ds J P Strauss, PO Box 88, Registration sheet Response by EAP: Groot Brakrivier, 6525 December 2011 A study done by Eskom on 400 kV lines showed that although there is an EMF, it will not affect the health of humans and animals. It will also have no impact on radio and satellite transmissions if a specific distance is kept. 2 If the servitude of a 400kV line is 55 m (27,5 m to Mr Gerhard Kuhn, Swartkop Public meeting in Response by EAP: either side of the line), what is a safe distance Upington at 18:00 People can live next to the servitude without away for humans to live? on 7 February having any problems. That is the reason why 2012 to discuss the transmission lines have high towers – to the DSR protect humans and animals. 3 Will the transmission lines have an impact on Mr Barend Louw, Wildekeur Public meeting in Response by EAP: people wearing an implantable Parkinson Disease Upington at A study done by Eskom on 400 kV lines brain device? 18:00:30 on 7 showed that although there is an EMF, it will February 2012 to not affect the health of humans and animals. discuss the DSR It will also have no impact on radio and satellite transmissions if a specific distance is kept. 5 CONSTRUCTION 1 The Solar Park to Ferrum route will have to cross Mr Charles Stafford, Public meeting in Response by EAP: a ridge. How are you going to get all the heavy O’Donoghue Olifantshoek on 6 The route will be planned to avoid going over steel parts of the pylons to the top of the ridge? February 2012 to high ridges. Should there be no other option, discuss the DSR then helicopters will be used. The pylons/towers are constructed off site and transport in various panels to site where it is assembled. Issues and Responses Report (Version 4) 30 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES 2 The proposed line will have an impact on the Mr Gerrit Nell, PO Box Public meeting at Response by EAP: environment. What will you do to lessen the 28,Olifantshoek, 8450 Malley near This is the reason why the route with the impact? Olifantshoek on 19 least impact will be recommended to lessen November 2012 the impact. The Environmental Management Programme will also guide construction to lessen impacts. There will, however, be impacts. The challenge is to keep them to the absolute minimum. 3 The local communities can assist in identifying Mr William Peterson, National Public meeting in Response by EAP: indigenous plants that could be harmed during Khoisan Council Upington at 18:00 This will be further investigated during the construction, because they are very on 20 November study, because no study is done in a vacuum knowledgeable about these plants. 2012. and local knowledge is invaluable to a study team. The lines will have a corridor of two kilometres in which it can be constructed to avoid any sensitive areas.

(5.1) Deterioration of roads 1 Most of our roads are gravel roads which are not Mr Terblanche, Diepdruppel Public meeting in Response by EAP: maintained regularly. During construction your and many other stakeholders Olifantshoek on 6 When Eskom starts with the construction trucks will destroy our roads. This happened February 2012 to phase of a new project, the transport of during the construction of the substation near discuss the DSR equipment and material is discussed with the Witsand. The local roads were also left in a bad relevant authority in charge of the road state of repair due to the heavy trucks used during infrastructure. The possible deteriorating of the construction of the Kalahari pipeline. roads during construction `will be discussed with the relevant Northern Cape authority and mitigation will be agreed on. 2 All our roads are gravel roads and already in a Mr Theo Spengler, Rooiwal Email on 16 Maintenance of the proposed power lines is bad state. Heavy trucks that will be used during Farmers Association, February 2012 not expected to create a notable impact on construction will destroy our roads. These roads Olifantshoek the local traffic patterns, therefore no traffic are vital to our economic survival. impact study is required. An investigation of 3 Suggested that congestion on the N14 be Mr Inus Bezuidenhout Answer sheet the congestion of the N14 is outside the investigated. Po Box 1 October 2012 scope of this project. Dyasonsklip 4 There will be an increase of trucks during Mr Ivan Steenkamp, Northern Public meeting in Response by EAP: construction which is a concern to us if not Cape Department of Kathu on 19 This will be discussed by Eskom and its sub- managed properly. Transport, Safety and Liaison November 2012. contractors with the relevant authorities before the construction phase. Issues and Responses Report (Version 4) 31 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES 5 The officials of the traffic department needs Mr Ivan Steenkamp, Northern Public meeting in Response by EAP: repeaters for its radios due to the vast distances in Cape Department of Kathu on 19 Eskom is prepared to discuss this with the the Northern Cape and the solar panels used to Transport, Safety and Liaison November 2012. Department before the construction phase charge these repeaters are continuously being commences. stolen. Could the new pylons/towers of the proposed lines host these repeaters 6 TRANSMISSION LINE SERVITUDE 1 Can the Eskom servitude for the transmission line Stakeholder Public meeting in Response by EAP: also be used as a road by the community? Olifantshoek on 6 No, an agreement regarding the servitude February 2012 to and who may enter it will be signed by the discuss the DSR land owner and Eskom. 2 Will the servitude be fenced in? Mr Fanie Lerm, Public meeting in Response by EAP: Middelpost 60 Kakamas on 8 No, it will not be fenced in the servitude will February 2012 to only have gates at existing fences. discuss the DSR 3 Livestock theft is a serious problem in South Mr Theo Spengler, Rooiwal E-mail on 16 Response by Social specialist: Africa. We live in a relatively safe area, because Farmers Association, February 2012 More people may bring more crime to the there are very few access roads. A transmission Olifantshoek area. Eskom should become member of the line will bring in more people which can have a community police forum. Construction negative impact on our safety. workers should wear uniforms and identification cards. Eskom will appoint a community liaison officer for the construction period to work with local communities to contribute to minimising crime. 7 OTHER ISSUES 1 Where can we discuss problems regarding the Stakeholder at meeting. Public meeting in Response by EAP: lack of electricity? Olifantshoek on 6 All electricity problems can be discussed with February 2012 to the relevant Eskom customer service centre. discuss the DSR The details for the Northern Cape are: email - [email protected] and Fax - 051 404 2627. 2 Why is a substation needed at Nieuwehoop? Mr Nico Heyns, Rateldraai Public meeting in Response by EAP: Upington at 09:30 This iron ore exported via the Sishen on 7 February Saldanha railway line will be doubled during 2012 to discuss the next few years and five new substations the DSR will be built to provide double the electricity as needed by this line. Issues and Responses Report (Version 4) 32 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES 3 What about lightning strikes on the transmission Mr Riaan Liebenberg, Koupan Public meeting in Response by EAP: line? Farmers Association Upington at 09:30 All pylons are earthed and this will not on 7 February present a problem. In actual fact the pylons 2012 to discuss provide better lightning management by the DSR earthing all strikes.

4 We were under the impression that the Solar Park Mr Stanley Peterson, National Public meeting in Response by EAP: will only provide electricity for Nieuwehoop Griqua Tribal Council Upington at 09:30 Nieuwehoop is being built to double the substation. on 7 February current load of the Sishen Saldanha railway 2012 to discuss line and will be one of the entry points into the DSR the national energy grid of the energy generated by the Upington Solar Park. Other points include Aries, Ferrum and Gordonia substations. 5 A high level risk assessment has been conducted Dr Adrian Tiplady Email response on Response by EAP: at the South African SKA Project Office to 17 Baker Street 16 November The comment s received was on the Draft determine the potential impact of such Rosebank 2012 to email sent Environmental Impact Reports, Draft Basic infrastructure on the Square Kilometre Array. This Johannesburg on 1 November Assessment Reports and Amendment to an letter serves to confirm the outcomes of the risk 2196 2012 existing Environmental Impact Report for the assessment, and proposals for any future proposed construction of several 400kV investigations associated with this facility: And transmission and 132kV distribution lines to i. The location of the proposed high voltage integrate the Concentrating Solar Park (CSP) transmission lines have been provided by near Upington. email as GIS shapfiles. The nearest SKA stations have been identified as Rem-Opt-9, Letter: 15 at a distance of approximately 1.5km from November 2012 Eskom response: the Aries-Niewehoop route, and Rem-Opt-8, at a distance of approximately 8.5km from Eskom and SKA-SA have had numerous the Ferrum Route; meetings since receiving the letter, around ii. Based on the distance to Rem-Opt-9, and the the issue of radio interference (RI) being limited information currently available on the generated by the 400 kV transmission lines detailed design of the Aries-Niewehoop high passing the two remote sites. Information voltage transmission line, and assuming a presented in your letter initially specified 400kV line, this installation poses a very high Rem-Opt-9 and Rem-Opt-8, after which it risk of detrimental impact on the SKA as a was corrected to specify Rem-Opt-9 and result of corona discharge from the Rem-Opt-12. transmission line, and the associated electromagnetic interference; From the study, the following issues were Issues and Responses Report (Version 4) 33 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES iii. Based on the distance to Rem-Opt-8, and the considered: limited information currently available on the Rem-Opt-9, is within 1.5 km from an detailed design of the Ferrum high voltage existing 132 kV distribution line. transmission line, and assuming a 400kV Rem-Opt-12 is approximately 12 km line, this installation poses a medium risk of from the proposed 400 kV ransmission detrimental impact on the SKA as a result of line. corona discharge from the transmission line, Any transmitter in the region, needs to and the associated electromagnetic comply with the Astronomy eographic interference; Advantage Act (AGA). iv. As a result of the very high and medium risks associated with the establishment of the high Focusing on the above issues, Eskom with voltage transmission line infrastructure, it is consultation and involvement of the SKA-SA advised that further detailed studies are personnel, embarked on a study to clarify the conducted to characterise the exact nature of RI risk. A technical in-depth discussion round electromagnetic interference to be generated the RI risk, can be found in the Eskom report from the transmission lines in question, and by KR Hubbard (Report attached). to determine mitigation measures that could be considered. The South African SKA From the outcomes of the RI study and Project Office is willing to assist in this consultation with SKA-SA, the following process, where possible; issued were raised and clarified: v. It is further recommended that a follow-up A technical working group be setup meeting is held with the South African SKA between Eskom and the SKA-SA team, Project Office to identify any further where the issues related to the RI being constraints, and develop a plan going generated can be discussed, especially forward for future engagement; the radio quiet zone (RQZ) and vi. Any transmitters that are to be established, acceptable levels that could be tolerated or have been established, at the site for the by the various remote SKA-SA sites. purposes of voice and data communication This is critical to ensure the success of will be required to comply with the relevant both projects. AGA regulations concerning the restriction The SKA-SA agreed, that the Rem-Opt- of use of the radio frequency spectrum 12, that is along the Eskom Solar– that applies in the area concerned. Ferrum EIA recommended routes was not a high risk for SKA-SA as the This technical advice is provided by the South distance between Rem-Opt-12 and the Africa SKA Project Office on the basis of the proposed alignment is approximately 12 protection requirements of the SKA in South km. Africa, and does not constitute legal approval of The SKA-SA Rem-Opt-9, is 1.5 km from Issues and Responses Report (Version 4) 34 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES the renewable energy projects in terms of the an existing 132 kV distribution line. The Astronomy Geographic Advantage Act, the new proposed 400kV solar park Management Authority, and its regulations or transmission line will pass Rem-Opt-9 declarations. approximately 2.5 km away. It is known, that the existing 132 kV line consists of a five pole wooden structure, sparking could be produced by these structures depending on the changing environ- mental conditions. SKA-SA team to look into moving the SKA site Rem-Opt-9 to another location if possible. The SKA-SA team has confirmed, that they have a mandate, to move Rem-Opt- 9 by 5-6 km. This is under consideration at present. Information from SKA-SA team on the reduction of the limit by applying the interferometric attenuation region for these remote sites be clarified as per the ITU-R recommendation RA.769. By considering the interferometric attenuation reduction of 40 dB at the remote sites, allows the power line and SKA-SA site to be closer than originally planned. The separation distance of 6 km would suffice, to meet these recommendations. Eskom to look at other servitude options, as well as look into other conductors with a smoother dimension, as well as compacting the line to reduce the RI being produced. SKA-SA to provide a comprehensive list of frequencies, an a study be conducted around these frequencies 6 How will this line benefit the farmers in the area? Mr Ben Kampfer and Public meeting at Response by EAP: Is this new electricity not just meant for the mines? Mr Gerrit Nell Malley near There will be no immediate direct benefit to Issues and Responses Report (Version 4) 35 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES Olifantshoek on 19 farmers in the Olifantshoek district. It is a November 2012 long process that starts with a big transmission line. Smaller distribution lines will be built later in the process. This electricity will be added to the Eskom network and is not specifically meant for the mines. 7 Local Eskom officials tell us that it is not cost Mr Gerrit Nell Public meeting at Response by EAP: effective to build distribution lines to farms in this Malley near Eskom will organise with the Northern Cape area. There is nothing positive for us farmers in Olifantshoek on 19 distribution office to do a presentation about this area November 2012 the future plans for the Olifantshoek district.

(7.1) Solar Park 1 When will the Concentrated Solar Park (CSP) be Ms Lizette Slabber, Volksblad Public meeting in Response by EAP: finished? Upington at 09:30 Eskom is currently running a separate on 7 February Environmental Impact Assessment to 2012 to discuss increase the size of the CSP from 400 to 800 the DSR ha. It is expected that the CSP will start delivering energy in 2016. 2 Property prices as far as 40 km from Solar Park Mr Donovan Richmond, Seeff Public meeting in Response by EAP: are going through the roof and land is becoming Properties Upington at 09:30 At this stage only energy generated by very expensive. on 7 February Eskom, the Independent Power Producers 2012 to discuss on the western border of Eskom’s property the DSR and the Department of Energy’s site on the eastern border will be connected to the national grid by the infrastructure included in this study. 3 A lot of discussion is currently taking place around Mr Stanley Peterson, National Public meeting in Response by EAP: Solar Park and other proposed solar Griqua Tribal Council Upington at 09:30 Eskom and the Department of Energy met developments in the Northern Cape. It is very on 7 February with the Khara Hais Municipality in Upington confusing due to all the new developments and 2012 to discuss during last year to discuss this project. many rumours are currently floating around the the DSR Three IPPs (Abengoa, Solar Reserve with Northern Cape. The local municipality should the third one to be announced in the near become involved to communicate what is really future) have been given permission to happening regarding solar energy generation. develop to the west of Eskom’s property. Only these three IPPs and the companies chosen by the Department of Energy for its site, will have contracts to supply Eskom with energy. Any new development must first go through Issues and Responses Report (Version 4) 36 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES an Environmental Impact Assessment process, which involves a public participation process to inform people of the new development. 4 Will Solar Park need water? Mr Stanley Peterson, National Public meeting in Response by EAP: Griqua Tribal Council Upington at 09:30 Yes, Eskom will apply for a Water Use on 7 February License Application to use water for a turbine 2012 to discuss necessary during the energy generation the DSR process as well as water to clean the heliostats (mirrors). 5 Everybody is tapping into solar energy and Mr Harry Bosman, Khoisan Public meeting in Response by EAP: nobody knows what this will do to the Community Upington at 09:30 The impact on the environment was environment. There are many companies trying to on 7 February investigated during the EIA done on the get into solar energy and it is creating a lot of 2012 to discuss Solar Park. confusion. the DSR The Department of Environmental Affairs is the regulator for renewable energy. 6 We are worried about the land the Khara Hais Mr Stanley Peterson, National Public meeting in Response by EAP: Municipality bought on behalf of the Department of Griqua Tribal Council Upington at 09:30 The development of this land must be Energy to the east of Eskom’s property at on 7 February preceded by an Environmental Impact Upington Solar Park. 2012 to discuss Assessment, which will give you the the DSR opportunity to raise your issues regarding this development. 7 Why do you build Solar Park in Upington if the Mr Nico de Wet, Public meeting in Response by EAP: electricity is needed in other cities and towns? Environmental Committee, Upington at 14:00 The Upington district has the highest Orange Agricultural Union on 7 February concentration of solar radiation in South 2012 to discuss Africa and the Orange River can provide the the DSR water needed for the development. The project will also strengthen the national electricity grid in the Northern Cape. 8 When did the Upington Solar Park project started? Ms Estelle Visser Public meeting in Response by EAP: Upington at 14:00 The Environmental Impact Assessment on 7 February started in 2005 and an authorisation was 2012 to discuss received in 2007. the DSR 9 Will this Environmental Impact Assessment (EIA) Mr Inus Longland Public meeting in Response by EAP: also include the area where the Independent Upington at 14:00 No, this EIA is only for the integration of the Power Producers (IPP) will be placed? on 7 February Upington Solar Park into the national energy 2012 to discuss grid. It is there for only for the transmission the DSR lines that will run from Upington Solar Park east to Ferrum (Kathu), down south to Nieuwehoop and also south to Aries near Issues and Responses Report (Version 4) 37 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES Kenhardt. The IPPs will each have to do a separate EIA for their respective developments. 10 How many power producers will there be at the Mr Barend Louw, Wildekeur Public meeting in Response by EAP: Upington Solar Park? Upington at It will be Eskom and the Department of 18:00:30 on 7 Energy to the east of Eskom that will search February 2012 to for Independent Power Producers (IPP) to discuss the DSR put up plants on its property. Three IPPs (Abengoa, Solar Reserve with the third one to be announced in the near future) have been given permission to develop to the west of Eskom’s property. Only these three IPPs and the companies chosen by the Department of Energy for its site will have contracts to supply Eskom with energy. 11 The area identified for the Solar Power plant Mr Ian Scholtz Email sent on 25 Response by EAP: lies to the West of Upington between the Engineering Technician October 2012 The proposed increase in CSP plant Upington Nakop and Upington Kakamas lines TRANSNET Infra-freight rail dimensions, including the increased at the following chainages: number of heliostats, is not expected to significantly alter the influence of the 1. Upington Nakop in the vicinity of Kalksloot development on areas of higher viewer Station a 21,924km incidence (observers travelling along 2. No public level crossings in vicinity. national, arterial/main or major secondary 3. Upington Kakamas between 12,46 and roads within the region). 15,55km (Klippunt Station is at 15.875km). On re-assessment of climate, air quality Our records show a public level crossing and surface water potential impacts, no at 12,820km. significant impacts are expected. The

original EIA report recommended that The plan provided shows very little detail of the erosion control measures such as berms, area where the solar plant will be constructed. gabions etc be constructed where Until more detailed information becomes necessary to minimise scour, during heavy available from a Civil point of view we can only rains and thunderstorms, and erosion. voice the following concerns No new level railway crossings will be 1. Position of solar panels possibly blinding required. train drivers; 2. Storm water run-off caused by development to the site; 3. To gain access to the site might require Issues and Responses Report (Version 4) 38 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES a new level crossing to cross the railway line. Due to safety associated risks. Transnet is reluctant to grant permission for new level crossings and this should be taken into account when the final planning is done.

We will have to keep track of this proposal and identify any further problem areas once the final design becomes available.

12 Will photo voltaic cells or concentrated solar Mr Theo Spengler, Rooiwal Public meeting at Response by EAP: power be used? Farmers Association, Malley, near The Eskom 100 MW will be using CSP Olifantshoek Olifantshoek on 19 technology, but eventually about 10% of November 2012 power to be generated by Government and Independent Power Producers will use photo voltaic cells and 90% CSP. 13 What is the connection between the solar Mr Hugh McGibbon, Eskom Public meeting in Response by EAP: developments near Prieska and Solar Park near Upington at 18:00 The Department of Energy (DoE) is looking Upington? on 20 November at developing a Solar Corridor of 5000 MW 2012 between Upington and Prieska and several other locations are being investigated for solar developments. This is due to challenges faced by the DoE in securing the land west of Upington next to the Eskom’s site. Now the DoE is first securing the land before announcing any developments. 8. DRAFT REPORTS – COMMENTS RECEIVED

(7.1) Main Reports 1 DEA Ref: 12/12/20/2610 Ms Jacoline Mans Letter: 21 January Response by EAP: Chief Forester: NFA 2013 Noted. Page 5 of the BAR stated that tall trees will be Regulation cleared along the entire length of the servitude (± 180m). Please note no protected tree may be removed without a license from the DAFF. Licenses must be obtained in time and before any construction activity commences. The application Issues and Responses Report (Version 4) 39 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES form is obtainable from the Forestry Offices in Upington (details provided). 2 Page 16 listed the applicable legislation. It failed to Response by EAP: mentioned the NFA and the Northern Cape Nature Noted and included. Conservation Act, Act 9 of 2009 (NCNCA), both of which will definitely be applicable. 3 Page 30 stated that no rare or endangered floral Response by Biophysical specialist: species were found in the study area. Although it Comment noted and included in the might be true, the applicant should assess the Biophysical Report as well as the EMPr. potential impact on protected species as no Please note that a detailed botanical survey protected plant may be removed or disturbed will be conducted once the servitude is without a license from DAFF and a permit from finalised and then all the protected species Nature Conservation (depending on the species will be identified and the required permits involved. obtained from DAFF/DEA/NC Nature Conservation. 4 The fact that the broad vegetation units present on Response by Biophysical specialist: site are classified as ‘least threatened’ does not Agreed, a post-authorisation pre-construction mean the vegetation on site has little conservation walk-down by appropriate specialists will value as stated in the report. There can be identify all protected, endemic, rare or species patches of unique vegetation worth conserving. Final placement of the proposed power lines of special concern. should take cognizance of protected plants and avoid areas with high density protected plants. In Response by Biophysical specialist: fact, some of the vegetation units mentioned are Comment noted and included in the dominated by protected tree species responsible Biophysical Report as well as the EMPr. for maintenance of biodiversity in arid ecosystems. 5 Page 35 – A direct impact during the construction Response by EAP: phase will be the removal of vegetation. Although Noted. not mitigation per se, it should be mentioned that no protected plant may be disturbed or removed without the necessary license or permit and that areas containing high densities of protected plants should be demarcated as ‘sensitive’ and avoided in the final placement of the proposed infrastructure. It should also be included in the EMPr. It is not mentioned on page 36. 6 It is not clear from the report which proposed Response by Biophysical specialist: alternative will have the least impact on plants of The three transmission line corridor sites are special concern such as protected plant species. very similar in nature. The plants of concern In fact, it is not clear whether such an assessment that occur in the area include Acacia erioloba was conducted. It is unlikely, since not all and Boschia albitrunca. These species are Issues and Responses Report (Version 4) 40 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES applicable legislation was consulted. very sparsely found in the study area, but more prone to drainage lines and the Gordonia Duneveld occurring along the northern boundary of the study site. Very few trees were observed inside the transmission line corridors. Also all the lines use the same alignment for the route to Gordonia, so the route alternatives are all identical. The substation sites are also very similar and no discernible difference was observed. If considering the piece of route prior to the joining of the three alternatives into a single route, the biophysical specialist suggest that route alternatives from the Solar substation site 1 has the highest potential for impact to the two protected trees as the alignment runs through a longer section of the duneveld. 7 DEA Ref: 12/12/20/777 Ms Jacoline Mans Letter: 21 January Response by EAP: Chief Forester: NFA 2013 Noted. The original EMPr for the CSP EIA The Directorate: Forestry Management (other Regulation further addressed vegetation clearance Regions) in the DAFF did not comment on the issues as follows: “Prior to site clearance, a proposed development during the initial EIA, detailed survey of the vegetation in the area because we were not aware of the project. Table 1 must be undertaken by a qualified vegetation (there is no page number) contains a summary of specialist and any protected plant species Statement from the initial EIA studies reviewed. recorded must be appropriately marked. The According to this table, the Ecology Assessment appropriate permit/s must be obtained from conducted in 2006 indicated that protected plants the Provincial Department of Conservation in do occur in the area of the proposed development the event that protected plants needs to be and search and rescue must be conducted to relocated. All cleared areas will be stabilised relocate protected plants. Please note that not all as soon as possible in order to minimise risk protected plants can be relocated successfully, as of erosion”. some species have deep taproots making transplantation impossible. The EAP supports and reiterates this post- authorisation activity as suggested in the EMPr. 8 No protected plant may be disturbed, removed or Response by EAP: destroyed without a license from DAFF and permit Noted. from Nature Conservation (depending on the species involved). New provincial legislation, the Northern Cape Nature Conservation Act, Act 9 of 2009 came into effect and must be consulted to Issues and Responses Report (Version 4) 41 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES determine which plant species present on site are protected and requires a permit from Nature Conservation. Contact the Permit Section of Nature Conservation at the provincial Department of Environment and Nature Conservation (DENC) in Kimberley for more information. 9 Page 14 of the report refers to the potential Response by EAP: environmental impacts. The DAFF is concerned An Ecological Impact Assessment report was that in terms of the biophysical environment, the produced by an experienced and qualified potential impact of fauna and flora was not plant ecologist on the proposed CSP site properly assessed, especially in light of the fact during the original EIA submitted in 2007. that new legislation became effective. The current Upon review by DEA in 2011 it was report refers to terrestrial ecology, but only to concluded that the existing Ecological Impact avifauna. No reference is made to the potential Assessment was sufficient to make an impacts on plant species of special concern. informed decision regarding the amendment of the EA for the CSP. 10 It is unavoidable that the proposed development Response by EAP: will have an impact on plants. Please note that The impact on plant has been assessed in environmental Authorisation does not imply that a the amendment of the CSP EA. Once Forest Act License or Nature Conservation Permit amendment application has been assessed will automatically be granted. It can be and has by DEA and an authorisation decision has been refused in the past should there be good been reached, further consultation with the reason to do so, therefore it is very important that DAFF and DENC will be undertaken. the developer consult with the relevant regulating authorities (DAFF and DENC) as soon as possible regarding the permit and license requirements. Sufficient time should be allowed for obtaining the permit and Forest Act License and it must be obtained before construction commences. 11 It is important that the licensing requirements in Response by EAP: terms of destruction of protected plants be Noted. included in the EMPr. 12 DEA Ref: 12/12/20/2608 Ms Jacoline Mans Letter: 21 January Response by Biophysical specialist: Chief Forester: NFA 2013 The comments were noted and included into It is not clear from the report what will be the Regulation the amended Biophysical Report, the anticipated impacts on protected trees in terms of updated legislation were also included as the different proposed alternatives. According to well as the referenced species lists. the reports, the anticipated impact on terrestrial fauna and flora is regarded as low because the broad vegetation units are classified as ‘least threatened’ in Mucina & Rutherford (2006). This is Issues and Responses Report (Version 4) 42 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES unacceptable. Although the information can be used as baseline information, it should be refined as there may be huge variation within the broad vegetation units. Sensitive areas should be identified and avoided. In order to do so, all applicable legislation should be consulted. This was not done. The consultants failed to mention the Northern Cape Nature conservation Act, Act 9 of 2009 (NCNCA). The NCNCA contains schedules of specially protected fauna and flora that may not be disturbed without a permit from the DENC. Neither the Act nor the permit requirement in terms of this Act was mentioned. Areas containing numerous protected plant species should be regarded as ‘sensitive’ and avoided as far as possible. 13 Some of the power lines will run from Upington to Response by EAP: Kathu, affecting the Kathu Bushveld vegetation Noted. The preferred option being the type. Please note that no impact will be tolerated shortest path between two points are simple on the nationally protected woodland, the Kathu the starting point of an EIA. The EIA will then Forest or the proposed buffer around the Kathu investigate, assess and rate the potential Forest. In addition, all trees in Kathu Forest are impacts, then only propose feasible and regarded as protected, not just the ‘protected reasonable alternatives to be further species’. No new power line may run through investigated by specialist. It is not the default Kathu Forest. It should go around the Forest. and accepted alternative as is suggested. Kathu Forest is a sensitive feature that should be avoided, yet no reference was made to it. Response by Biophysical specialist: Therefore, the DAFF is very concerned because The comments were noted and included into one of the reports stated that the preferred option the amended Biophysical Report. It should is always the shortest one between two points. If be noted that none of the proposed corridors so, it defeats the purpose of the EIA which is to are within 2km of the declared Kathu Forest identify impacts (positive and negative) and avoid area as shown in the report and associated those that will cause great harm to the natural maps. environment. Please note that this Department will refuse to issue a license if it affects Kathu Forest, irrespective of whether Environmental Authorisation was granted or not. Therefore it is best to take note of this early on and make properly informed decisions that will not be regretted later on. If you need more information on Kathu Forest and its delineation, please do not Issues and Responses Report (Version 4) 43 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES hesitate to contact the Forestry Office in Upington. 14 The DAFF is concerned about the river crossings Response by Biophysical specialist: affecting the ‘endangered’ Lower Gariep Alluvial The comments were noted and included into vegetation type. Neither the Aquatic Report nor the amended Biophysical Report, the the Draft Biophysical Report considered the updated river crossing section and protected presence of protected species in the riparian species section. vegetation as a factor carrying some weight. In fact, great emphasis was put on the presence of alien invasive species, but none on the presence of protected trees. The reports failed to point out that protected Euclea pseudebenus can be encountered. This species occur from Upington downstream towards Alexander Bay, mostly on the banks of the Orange River. It was not mentioned at all. This species may not be disturbed without a license from the DAFF. One of the reports mentioned the Olea europaea subsp. Africana (Wild Olive) was encountered at one of the proposed river crossing alternatives. The Wild Olive is protected in terms of the provincial legislation and may not be disturbed without a permit from Nature Conservation. Its protected status was not pointed out. Also, no reference was made to the Griqualand West Centre of Endemism which is of international conservation importance. The point is, it seems as if no botanist was consulted. Species of concern might have been encountered, but not recognized. The Department recommends that a botanist be appointed to investigate the proposed river crossing alternatives and proposed power line alignments to properly assess the potential impacts on plant species of special concern. This must include protected and endemic species. The reports only refer to endangered species. 15 The DAFF is op the opinion that the reports failed Response by Biophysical specialist: to properly assess the potential impacts on The comments were noted and included into terrestrial fauna and flora. Since some of the the amended Biophysical Report, the power lines will be running parallel to each other, updated protected species section and the impacts on the natural vegetation can be quite preferred corridor discussions. It should be significant considering the aridity of the area and noted that the occurrence of protected Issues and Responses Report (Version 4) 44 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES the fact that vegetation in these areas recover species as well as pristine land vs. existing slowly from disturbance and is sensitive to disturbances were the key factors upon disturbance as it may cause wind erosion, most of which the report recommended the preferred the protected trees that could be encountered are alternatives. extremely slow growing and valuable as they are considered to be keystone species upon which the whole ecosystem functioning depends. Therefore, it is important to minimize the impacts on such species by selecting the alternatives that will have the least impact. It was barely mentioned in the reports. 16 The reports refer to the Eskom vegetation Response by EAP: management procedures. Please note that Eskom Noted. The EIR has been amended no longer clear all woody vegetation in the accordingly. servitudes and they are busy revising their standards based on different vegetation types i.e. different standards in different vegetation types. When Eskom applies for licenses, the DAFF only issue a license for clearance of protected trees directly under the lines and up to 3 or 4 meters on either side. The same would apply to this development. We will not issue a license for total vegetation clearance in the servitude of 108 meters. Yet the reports stated that “tall trees will be cleared along the entire length of the servitude”. 17 Basic Assessment Report (BAR) Response by EAP: Noted and amended. Pages 16 and 17 of the BAR listed the applicable legislation. It failed to mention the following applicable legislation: National Forests Act, Act 84 of 1998 (NFA) Northern Cape Nature Conservation Act, Act 9 of 2009 (NCNCA) National Veld and Forest Fires Act, Act 101 of 1998 (NVFFA) 18 Page 30 stated that “no rare or endangered floral Response by Biophysical specialist: or faunal species were identified within the study The comments were noted and included into area”. As pointed out, ‘specially protected’ and the amended Biophysical Report, the ‘protected’ or endemic species are also species of updated legislation were also included as concern. No protected species may be removed or well as the EMPr updated. Issues and Responses Report (Version 4) 45 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES disturbed without a license (NFA) from DAFF or permit (NCNCA) from the Department of Environment and Nature Conservation (DENCD). It is important to consult all applicable legislation as many protected species are known to occur in the study site. 19 The DAFF is concerned about the ‘sensitivity map’ Response by EAP: in the BAR as it indicates vegetation types and No finer scale date was available to identifiy failed to identify possible sensitive areas in the sensitive areas within the vegetation types. different vegetation types. The sensitivity map was also only meant to give an indication of the distribution and sensitivity status of the broad habitat unit. The EAP further refers to a comment by the Biophysical specialist as shown below.

Response by Biophysical specialist: It is simply to mammoth a task to identify each and every plant within the 400 000 ha covered by the corridors. Hence the suggestion is that a detailed botanical survey be undertaken in the preferred servitude prior to construction. This survey will identify all the species of concern within the servitude and ensure that the plants are either avoided or that the relevant permit or license is obtained prior to the start of construction.

(7.2) Biophysical Report 1 DEA Ref: 12/12/20/2610 Ms Jacoline Mans Letter: 21 January Response by Biophysical specialist: Chief Forester: NFA 2013 The comments were noted and included into Page 29 of the biophysical report refers to Regulation the amended Biophysical Report, the terrestrial biodiversity. It describes the broad updated river crossing section and protected vegetation units as classified in Mucina & species section. Rutherford (2006) and emphasized that none of these vegetation units are classified as threatened. This can be used as baseline information, but in terms of the different proposed alternatives, the anticipated impact on protected plants should be assessed on micro level to determine which alternative would have the least Issues and Responses Report (Version 4) 46 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES impact on plants of special concern. Many of the plant species mentioned in the report are protected, but its protected status was not pointed out. 2 Page 41, number 3.6.5 refers to ‘sensitivities’ and Response by Biophysical specialist: to ‘endangered’ species. As pointed out protected The comments were noted and included into plant species are of concern as it is subjected to the amended Biophysical Report, the licensing requirements. Therefore, it is important updated river crossing section and protected to assess potential impacts on protected plants species section. and to avoid such impacts as far as possible. 3 Page 46, number 3.6.5.3 refers to three (3) Response by Biophysical specialist: protected species (NFA) that could occur in the The comments were noted and included into study site. Please note that there are more than the amended Biophysical Report, the three (3) protected species that could potentially updated legislation were also included as occur in the study area, especially if one includes well as the referenced species lists. species (which include some trees) listed as protected in terms of the provincial NCNCA. 4 Page 63 refers to the impact assessment on the Response by Biophysical specialist: terrestrial ecology. The DAFF is seriously The comments were noted and the rating concerned about the reasoning provided in revisited and amended. paragraph 5.2.1 where it stated that because the vegetation has been hardly disturbed and the area is almost natural in appearance with less than 5% transformation, “hence the impact on these areas is rated as ‘low’”. The different alternatives were not assessed to determine the impact on protected plant species; therefore such an overall generalisation is totally unacceptable. In terms of the temporal scale a rating of ‘short term or 2’ is given. The DAFF totally disagrees with this. Protected trees in arid regions are extremely slow- growing and any impact on such species could be regarded as permanent or very long term. 5 As already pointed out in earlier comments on BA Response by Biophysical specialist: report No 1, the DAFF cannot agree with the The comments were noted and included into consultant where it stated on page 63 that the amended Biophysical Report. The EMPr ‘standard operating procedure to clear the recommendations from the report states that vegetation in the servitude’ will be followed. A the vegetation should not be cleared unless it Forest Act License will not be issued for total poses a threat to the power lines. These vegetation clearance in the servitude. We only trees should be marked, identified by a issue licenses for removal of protected trees qualified botanist as part of the pre- Issues and Responses Report (Version 4) 47 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES located directly under the power line and 4m on construction assessments and the each side. The same approach will be used in this appropriate license or permits obtained prior case. In arid regions, total vegetation clearance is to the start of construction. regarded as irresponsible, as wind and water erosion is a serious problem in sandy, arid regions where the plant roots provide stability to soil and is of utmost importance to prevent further desertification. 6 Table 10 on page 64 can be used as baseline Response by Biophysical specialist: information, but it gave no useful information to The comments were noted and included into make an informed decision regarding the most the amended Biophysical Report. The EMPr appropriate alternative from an environmental recommendations from the report states that perspective specifically considering the impact on the vegetation should not be cleared unless it the natural vegetation. Within broad, national poses a threat to the power lines. These vegetation units there are different plant trees should be marked, identified by a communities present, each with a different qualified botanist as part of the pre- sensitivity rating. construction assessments and the appropriate license or permits obtained prior to the start of construction. In addition areas with known sensitive species have been identified and shown on the sensitivity map in the report. 7 Page 66 contains a suggested mitigation and Response by Biophysical specialist: stated that the Environmental Control Officer The comments were noted and included into (ECO) should identify any sensitive large the amended Biophysical Report. The EMPr terrestrial species along the servitude and notify recommendations from the report states that the fauna specialist so that advice can be given on the vegetation should not be cleared unless it how to best deal with the situation. This is exactly poses a threat to the power lines. These what was referred to in 3.6 (above comment). The trees should be marked, identified by a sensitivity assessment should be done during the qualified botanist as part of the pre- EIA to determine in advance which alternative construction assessments and the would be the most environmentally friendly with appropriate license or permits obtained prior the least negative impact on the natural to the start of construction. In addition areas vegetation. It cannot be done at such a late stage with known sensitive species have been when construction is already underway. What if identified and shown on the sensitivity map in the regulating authorities then refuse a license or the report. permit, because sensitive vegetation is encountered on site? 8 Page 66 under the bullet ‘sensitive Response by Biophysical specialist: habitat/species’, reference is made to tree The comments were noted and included into removals requiring permit from DAFF or NEM:BA. the amended Biophysical Report, the Issues and Responses Report (Version 4) 48 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES Please note DAFF issue licenses, not permits. updated legislation were also included as However, a permit will also be required from well as the EMPr updated. Nature conservation in terms of NEM:BA, CITES and NCNCA species. Both may be needed, a permit and a license. 9 The species list contained in Appendix A listed Response by Biophysical specialist: numerous ‘specially protected’ and ‘protected’ The comments were noted and included into trees that may occur on site. It is very important the amended Biophysical Report, the that the developer consult as early as possible updated legislation were also included as with DAFF and DENC regarding the license and well as the EMPr updated. permit requirements for the removal of such species. 10 DEA Ref: 12/12/20/2608 Ms Jacoline Mans Letter: 21 January Response by Biophysical specialist: Chief Forester: NFA 2013 The comments were noted and included into The biophysical report focuses too much on soils Regulation the amended Biophysical Report, the and too little on terrestrial ecology and biological updated legislation were also included as diversity. Although it pointed out that the Orange well as the EMPr updated. River area is sensitive, Kathu Forest was not mentioned neither was the Griqualand west Centre of Endemism. It basically only described the affected vegetation units as found in the Mucina & Rutherford (2006). No consideration was given to the potential impact on plant species of special concern. The report only refers to endangered species (page 42), but it fails to assess impacts on protected species which may not be removed or disturbed without a license (DAFF) or permit (Nature Conservation). It also failed to consult the relevant provincial legislation in terms of fauna and flora (Northern Cape Nature Conservation Act, Act 9 0f 2009). 11 Pages 46 and 47 of the report described three Response by Biophysical specialist: nationally protected tree species that might be The comments were noted and included into encountered in the study sites. It failed to point out the amended Biophysical Report, the that protected Euclea pseudebenus can occur in updated vegetation section as well as the the riparian vegetation where power lines must protected species section. cross the Orange River. Although it acknowledges the potential impact on protected trees, no indication is given on where the impact would be the greatest in terms of the different alternatives under investigation. Therefore, this Department Issues and Responses Report (Version 4) 49 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES cannot comment on the most appropriate alternative. We can only point out that a license and permit will be required for removal of protected vegetation. Environmental Authorisation does not imply that such a license will be granted automatically. Licenses can be and has been refused in the past. 12 Page 46 refers to Acacia erioloba and stated that Response by Biophysical specialist: “the area around Kathu is especially rich in these The comments were noted and included into trees”. Please note that the Kathu Forest is a the amended Biophysical Report. It should nationally declared Protected Woodland be noted that none of the proposed corridors earmarked for conservation. It is a no-go area for are within 2km of the declared Kathu Forest development of this nature. No license will be area as shown in the report and associated issued for removal of trees in Kathu Forest. maps. 13 The impact assessment methodology refers Response by Biophysical specialist: (pages 57 onwards). The DAFF has a serious The comments were noted and the rating problem with the assessment done on page 63 revisited and amended. regarding the impacts on terrestrial ecology. The only factor considered in terms of vegetation impact is the impact on soils. What about the impacts on plants and animals of special concern? Animals can move away, but plants cannot. This assessment should be rejected. A qualified botanist should be appointed to do a proper assessment of the anticipated impacts on ecology and biodiversity. According to Table 7, the impact on vegetation is regarded as low and the temporal scale is short term (which is defined as 0 – 5 years). The DAFF disagrees. In arid regions, recovery to vegetation is slow and periodic due to climatic constraints. Protected trees are extremely slow growing and reach ages of 300 to 400 years; therefore any impact can be regarded as long term or permanent. 14 Table 10 on page 64 only points out the surface Response by Biophysical specialist: area of each vegetation unit affected by the The comments were noted and included into proposed alternatives. It does not assess the the amended Biophysical Report. Areas with impact on vegetation per se in terms of the known sensitive species have been identified different proposed alternatives. Within those and shown on the sensitivity map in the vegetation types there can be sensitive areas that report. As mentioned above none of the should be avoided. For example, the Kathu Forest corridors are within 2km of the declared Issues and Responses Report (Version 4) 50 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES occurs in the Kathu Bushveld vegetation type and Kathu Forest area. should be avoided. Some alternatives may have a greater impact on protected trees than others. Unfortunately, this information was not forthcoming from the reports and thus this Department cannot make any comment in terms of which alternative would be the most appropriate from an environmental perspective. 15 Page 66 contains some suggested mitigation Response by Biophysical specialist: measures, to mitigate impacts on terrestrial The comments were noted and included into ecology. It stated that alternative 1 should be the amended Biophysical Report, the considered as the preferred alternative. It is not updated protected species section and clear what criteria were used to come to this preferred corridor discussions. It should be conclusion. noted that the occurrence of protected species as well as pristine land vs. existing disturbances were the key factors upon which the report recommended the preferred alternatives. 16 Page 66 refers to sensitive habitat and species Response by Biophysical specialist: and the license requirement from DAFF. As The comments were noted and included into pointed out, a permit may also be required from the amended Biophysical Report. Nature Conservation. In addition, there are no guarantees that a permit of license will be issued. 17 Appendix A of the draft biophysical report contains Response by Biophysical specialist: species lists. The DAFF would recommend that The comments were noted and included into those species with protected status be pointed the amended Biophysical Report. out.

(7.2) Aquatic Report 1 DEA Ref: 12/12/20/2608 Ms Jacoline Mans Letter: 21 January Response by Aquatic specialist: Chief Forester: NFA 2013 The comments were noted and included into As pointed out earlier, insufficient consideration Regulation the amended Biophysical Report, the was given to terrestrial protected plant species updated river crossing section and preferred known to occur in the riparian vegetation. The fact corridor discussions. that the Lower Gariep Alluvial Vegetation unit is classified as endangered is of utmost importance. The best river crossing alternative should be the one with the least impact on the endangered riparian vegetation, probably where the river is narrow enough that the towers will be outside the Issues and Responses Report (Version 4) 51 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES riparian zone and thus no impact on the river banks. 2 The DAFF is of the opinion that it is wrong to focus Response by EAP: on factors such as the presence of alien invasive Noted. plant species. The presence and impact on plant species of special concern, which include protected and endemic species, should carry much more weight. Alien invasive species can be easily removed, but it will take many years to replace slow growing indigenous protected trees growing naturally in the endangered riparian vegetation. 3 The final recommendation in the aquatic report is Response by EAP: that two alternatives are deemed suitable, namely A suitable qualified aquatic specialist was 1 and 5. Yet, alternative 1 has a riparian appointed to undertake the specialist study. vegetation index (RVI) score of B which means the vegetation is still largely intact, natural and Response by Aquatic specialist with few modifications. Alternative 5 falls in class The recommended river crossing was D, meaning that it is largely modified. The other determined by considering the results from alternatives are falling in between. As all the aquatic assessments, and the results applicable legislation was not consulted, this should not be viewed in isolation. Department recommends that a suitably qualified Furthermore, the scope of the report did not botanist be appointed to assess the proposed river allow for detailed botanical assessment. A crossing alternatives and determine which one will detailed botanical assessment will be have the least impact on the endangered riparian performed as part of the pre-construction vegetation and protected plant species. servitude/EMP walk down process. 4 Page 10 refers to riparian thickets and mentioned Response by EAP: that it is dominated by species such as Euclea Noted. pseudebenus, Acadia erioloba, Comretum erythrophyllum. Page 51 refers to the riparian Response by Aquatic specialist vegetation analysis as crossing alternative 4(C4) The scope of the report did not allow for and mentioned that Olea europaea subsp. detailed botanical assessment. A detailed africana was encountered at this site. All of these botanical assessment will be performed as species are protected, some nationally and others part of the pre-construction servitude/emp provincially, yet it was not mentioned or pointed walk down process. out. 5 Page 29, the bottom of the page number 5.1.5 Response by EAP: recommended that “… any proposed activities The Basic Assessment has assessed and which could affect the system be comprehensively addressed all the identified impacts. assessed to define and understand the impacts to ensure that suitable and sufficient mitigation Issues and Responses Report (Version 4) 52 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES measures are put in place to protect the system Response by Aquatic specialist …” There must be a problem if the No additional response. recommendation is to assess the impacts, as the whole purpose of the basic assessment is to assess impacts and recommend the most suitable options. 6 Page 60 of the aquatic report contains some Response by EAP: recommended mitigation measures. No reference Noted. is made to protected plant species. The DAFF would like to recommend that impacts on protected plants be avoided and where it cannot be avoided, no construction activity may commence without the necessary license or permit. 7 Page 73, table 32 contains a summary of impacts. Response by Aquatic specialist: As pointed out, it is of great concern that the The scope of the report did not allow for impact on protected riparian vegetation and the detailed botanical assessment. A detailed associated biodiversity was not worth mentioning, botanical assessment will be performed as especially in light of the fact that this riparian part of the pre-construction servitude/EMP vegetation is considered endangered. Although walk down process. the aquatic report should focus on aquatic matters, the river bank with the associated riparian vegetation is an integral part of the aquatic system. The issue of impact on terrestrial plant species of special concern was also not adequately addressed in the draft biophysical report.

(7.3) Appendix F: Impact Assessment 1 DEA Ref: 12/12/20/2610 Ms Jacoline Mans Letter: 21 January Response by Biophysical specialist: Chief Forester: NFA 2013 The comments were noted and included into Page 74 refers to the impact on terrestrial ecology Regulation the amended Biophysical Report legal in this part of the assessment report, no reference section. is made to impact on protected plants and there will be protected plants on site. Again, this Department seriously question the reasoning provided, that because the effected broad, national vegetation units were classified as least threatened in 2006, that one can just infer that this rating applies to all alternatives. The DAFF Issues and Responses Report (Version 4) 53 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES strongly disagrees, as not all legislation was consulted and impacts on protected trees were not assessed. 2 Page 75 contains mitigation measures. The DAFF Response by EAP: recommends that the following be included: Noted. All permits and licenses for disturbance of Response by EAP: protected fauna and flora must be obtained Noted. from the relevant regulation authority prior to commencement of any construction activity. • Protected trees and plants should be avoided Response by EAP: as far as possible and the final placement of Noted. power lines should take cognizance of such species. 3 The DAFF is not satisfied with the impact Response by Biophysical specialist: assessment that was done on terrestrial ecology The comments were noted and included into and recommend that a proper assessment be the amended Biophysical Report. See conducted to determine which alternative would Biophysical specialist report in the Appendix. have the least impact on plants of special concern (this include fauna and flora listed as protected, endemic, etc. 4 DEA Ref: 12/12/20/2608 Ms Jacoline Mans Letter: 21 January Response by Biophysical specialist: Chief Forester: NFA 2013 The comments were noted and included into The DAFF cannot agree with the final statements Regulation the amended Biophysical Report. See made on pages 73 and 74 regarding impacts on Biophysical specialist report in the Appendix. terrestrial ecology. Impacts are said to be low based purely on the fact that the broad vegetation units are classified as ‘least threatened’ in Mucina & Rutherford (2006). As pointed out earlier, this approach is unacceptable. The proposed developments may impact on sensitive features such as the endangered Lower Gariep Alluvial Vegetation, the Kathu Forest and individual slow growing protected trees and plants. Given the aridity of the study site, the duration of such impacts on vegetation may be long term to permanent. Not all relevant legislation was consulted, thus it is impossible to predict the extent of the impact on protected plants. Issues and Responses Report (Version 4) 54 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES

(7.4) Appendix G: EMPr 1 DEA Ref: 12/12/20/2610 Ms Jacoline Mans Letter: 21 January Response by EAP: Chief Forester: NFA 2013 Noted and inserted. Page 14 contains the steps to be taken during the Regulation construction phase. Step 8 refers to vegetation clearance. The DAFF recommends that a step be included prior to step 8 to get the necessary permits and licenses that will be required for vegetation clearance. It can be time consuming to get and therefore the developer should not wait until he/she wants to start with construction. Sufficient time should be allowed. This office recommends that you apply for the NFA License and Nature Conservation permit 3 months prior to construction, In fact, it would be best to include such a term in the planning phase. 2 Page 16 refers to fauna and flora and Response by EAP: recommends that a botanist ascertain the Noted and amended. presence of threatened plant species. As pointed out, protected species is subject to licensing and permit requirements. Thus, the statement should be amended to include protected species. 3 Page 18 refers to fire prevention. Please take note Response by EAP: of the requirements in terms of the National Veld Noted and included. and Forest Fires Act, Act 101 of 1998. One of the requirements is to have trained personnel in fire fighting and adequate fire fighting equipment on site. 4 DEA Ref: 12/12/20/2608 Ms Jacoline Mans Letter: 21 January Response by EAP: Page 17 of the EMPr refers to the presence of Chief Forester: NFA 2013 Noted and included. threatened plant species. It must include protected Regulation species, as no protected species may be disturbed without a permit or license from the relevant regulating authority.

(7.4) Issues and Responses Report 1 DEA Ref: 12/12/20/2608 Ms Jacoline Mans Letter: 21 January Response by Biophysical specialist: Chief Forester: NFA 2013 Your concern is duly noted. However the In the issues and response report, reference is Regulation scope of the biophysical study was to assess Issues and Responses Report (Version 4) 55 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES made to biodiversity. Some farmers pointed out the general ecological state of the corridors that protected Acacia erioloba (Camel thorn) and and to identify potential protected species Boscia albitrunca (Shephard’s Tree) trees can be that could occur in the corridors. affected. The response was that the “biodiversity study will identify all possible protected trees along It is simply to mammoth a task to identify the proposed routes that will require permits from each and every plant within the 400 000 ha DAFF prior to any construction works starting”. covered by the corridors. Hence the The draft biophysical study failed to do so. It is suggestion is that a detailed botanical survey exactly what should have happened in order to be undertaken in the preferred servitude prior identify the most suitable alternative that will have to construction. This survey will identify all the least impact on protected trees. the species of concern within the servitude and ensure that the plants are either avoided or that the relevant permit or license is obtained prior to the start of construction. 2 Page 5 of version 3 of the issues and response Response by EAP: report, number 2.1 refers. Mr Spengler pointed out Noted. Such rationale was most definitely not that the environment is extremely sensitive for used and the phase was simply used to construction of roads and power lines. The indicate that the starting point for any response was that the shortest route between two exercise to identify alternatives theoretically points is always chosen first. The DAFF can only commences with a straight line. However, hope that this rationale was not used throughout determining alternatives are notably more the basic assessment to determine the most complex than this phrase. appropriate alternatives. There should be a balance between what is economically feasible, socially acceptable and environ-mentally friendly.

(7.5) General 1 DEA Ref: 12/12/20/777 Ms Jacoline Mans Letter: 21 January Response by EAP: Chief Forester: NFA 2013 Noted. Consultation with the Forestry Office Ct 84 of 1998 (NFA) as amended, section 12(1)(d) Regulation in Upington will be undertaken before read with s15(1) and s62(2)(c). the list of protected construction commences. tree species was published in GN 716 of 7 September 2012. No protected tree may be cut, destroyed or disturbed without a license.

Protected trees are known to occur in the vicinity of Upington and due to the size of the development footprint of 800ha it is very likely that protected trees will be affected by this development. Please apply for the Forest Act Issues and Responses Report (Version 4) 56 12726

COMMENTS, QUESTIONS AND COMMENTATOR(S) SOURCE(S) RESPONSE(S) ISSUES License for the disturbance or removal of protected trees before any construction activity take place. Applications can be submitted to the Forestry Office in Upington. It is imperative that you consult with this office before construction commence.