Public Participation Process: Bayview Wind Farmdraft

PUBLIC PARTICIPATION PROCESS: BAYVIEW WIND FARM DRAFT AMENDED ENVIRONMENTAL IMPACT REPORT (EIR)

1. PROOF OF SITE NOTICE

DATE PLACED: 21 AUGUST 2020

LOCATION: 33°43'2.91"S, 25°35'42.66"E (along the R335 road)

2. UPDATED STAKEHOLDER AND I&AP DATABASE

BAYVIEW WIND FARM: UPDATED STAKEHOLDER AND I&AP DATABASE AFFECTED PROPERTY, COMPANY OR TELEPHONE CONTACT PERSON ADDRESS EMAIL ADDRESS DEPARTMENT NUMBER Remaining Extent of the Farm Jakkie Erasmus and Elma 0825745653 PO Box 1197, Uitenhage, 6230 [email protected] Oliphants Kop 201 Erasmus 0722295169 Portion 4 of the Farm Steins Valley 084 854 4774 SP Meiring PO Box 126, Kirkwood, 6120 [email protected] 202 042 230 0426 Remaining Extent of Portion 8 of the Johan Hugo 083 233 3176 - [email protected] Farm Ebb and Vloed 230, Portion 1 of the Farm Oliphants Kop 201 PPC Cement 011 386 9489 Private Bag 2016, North End, 6056, Port [email protected] Remaining Extent of the Farm Aili Zeeman 078 450 7009 Elizabeth Grassridge 225, Remaining Extent Coega Development Corporation Coega IDZ Business Centre, Corner (CDC) 041 403 0664 Remaining Extent of Coega Erf 248 Alcyon Road & Zibuko Street, Port [email protected] Operations project manager: 082 657 4648 Elizabeth, 6100 Andrea Shirley ESKOM 041 405 0515 Uitenhage Farms 612 - [email protected] Eddie Leach 011 800 8111 Remaining Extent of the Farm PPC Cement 011 386 9489 Grassridge 227 Aili Zeeman Private Bag 2016, North End, 6056, Port [email protected] 078 450 7009 Remaining Extent of the Farm Elizabeth Geluksdal 590 Magnus de Lange 082 411 1311 [email protected] Telkom 29 Hex River Rd, Winterhoek, Portion 2 of the Farm Grassridge 227 082 470 6293 [email protected] Johan Snyman Uitenhage, 6229 Remaining Extent of the Farm Coega Crown Chickens (Pty) Ltd 041 995 1700 9 Kruis River Road, Uitenhage, 6229 [email protected] Kammas Kloof 191 Clifford Bartman 041 995 1724 78 Bendor Drive Beverley Grove Port Remaining Extent of the Farm 717 Rudolf Cornelius Orban 082 417 5500 [email protected] Elizabeth 6070 Zoetgenoegd Citrus (Pty) Ltd 042 234 0123 Remaining Extent of the Farm 627 PO Box 94, Kirkwood, 6120 [email protected] Willem Bouwer 082 579 2066 Portion 15 of the Farm Lot De B Gates Graham George 084 506 1104 PO Box 206, Addo, 6105 Oliphants Kop 194 Portion 1 of the Farm Logan Braes 203 Tankatara Prop (Pty) Ltd 082 533 1895 - [email protected] Remaining Extent of the Farm Gordon Lake Tankatara Trust 643

BAYVIEW WIND FARM: UPDATED STAKEHOLDER AND I&AP DATABASE AFFECTED PROPERTY, COMPANY OR TELEPHONE CONTACT PERSON ADDRESS EMAIL ADDRESS DEPARTMENT NUMBER Portion 2 and 5 of the Farm Logan B F Joubert Familietrust 042 230 0309 PO Box 193, Kirkwood, 6120 [email protected] Braes 203 Francois Joubert 084 951 1922 Portion 3, 5, 6 and 7 of the Farm Steins Valley 202 Transnet Rail 041 507 1309 PO Box 23960, Port Elizabeth, 6000 [email protected] Portion 2 of the Farm Annex Nozipho Mgaga Tankatara 219 Coega Development Corporation (CDC) 041 403 0664 [email protected] Operations project manager: 082 657 4648 Coega IDZ Business Centre, Corner Andrea Shirley Surrounding CDC IDZ Land Alcyon Road & Zibuko Street, Port Firhana Sam (Spatial Planner 041 403 0471 Elizabeth, 6100 [email protected] Operations) Graham Taylor (CDC Spatial - [email protected] Development Manager) Jay-Jay Mpelane (DEA Case [email protected] Officer) Department of Environment, Environment House, 473 Steve Biko Milicent Solomons New 012 399 9404 [email protected] Forestry and Fisheries (DEFF) Road, Arcadia, Pretoria Wayne Hector New [email protected] Lerato Mokoena New [email protected] Shonisani Munzhedzi 012 399 9171 [email protected] DEFF: Biodiversity and Conservation Simon Malete 012 399 9511 [email protected] 473 C/O Steve Biko & Soutpansberg Mmatsatsi Maboko New [email protected] Street, Mokete Rakgogo New [email protected] DEFF: Appeals and Legal Review 012 399 8870 Environment House, Pretoria, 0001 Heloise Van Schalkwyk New [email protected] Terri-Ann Mokhonoana New [email protected] Corner of Mount Road and Diaz, Mount Department of Mineral Resources Mineral Regulation 041 403 6623 Croix, Port Elizabeth, 6001 | Private Bag [email protected] (DMR) (Eastern Cape) Deidre Watkins X6076, Port Elizabeth, 6000 Department of Energy (DoE) Mokgadi Mathekgana 012 444 4261 Private Bag X96, Pretoria, 0001 [email protected] Eddie Leach [email protected] Eskom 083 632 7663 PO Box 1091, Johannesburg, 2000 [email protected] John Geeringh [email protected] South African National Roads SANRAL [email protected] 012 426 6000 PO Box 415, Pretoria, 0001 Agency (SANRAL) Nanna Gouws [email protected] EC Department of Roads and Public Randall Moore [email protected] 041 403 6001 PO Box 1110, Algoa Park, Port Elizabeth Works Thys Groenewald [email protected]

BAYVIEW WIND FARM: UPDATED STAKEHOLDER AND I&AP DATABASE AFFECTED PROPERTY, COMPANY OR TELEPHONE CONTACT PERSON ADDRESS EMAIL ADDRESS DEPARTMENT NUMBER Peter Lotter [email protected] Eastern Cape Department of Assistant Director: 041 508 5808 [email protected] Economic Development, Andries Struwig Private Bag X5001, Greenacres, Port Environmental Affairs and Tourism Regional Director: Elizabeth, 6057 041 508 5800 [email protected] (DEDEAT) Jeff Govender South African Heritage Resource Phillip Hine 021 462 4502 PO Box 4637, Cape Town, 8000 [email protected] Agency (SAHRA) Sello Mokhanya [email protected] Eastern Cape Provincial Heritage 043 642 2811 P.O. Box 16208, Amathole Valley, 5616 [email protected] Resources Authority (ECPHRA) Mzikayise Zote [email protected] Department of Water and Sanitation 041 501 0717 | Marisa Bloem Private Bag X6041, Port Elizabeth, 6000 [email protected] (DWS) 083 232 9822 Department of Agriculture Forestry Izak van der Merwe 012 309 5771 [email protected] Private Bag x9087, Cape Town, 8000 and Fisheries (DAFF) Thabo Nokoyo 041 586 4884 [email protected] P/Bag X5001, Greenacres, Port DEDEAT (Waste) Chris Julius 041 508 5808 [email protected] Elizabeth, 6057 NMBM Municipal Manager Johan Mettler 041 506 2308/9 PO Box 116, Port Elizabeth, 6000 [email protected] Miss V Bazi 13th Floor, Lillian Diedricks Building, [email protected] NMBM: Govan Mbeki Ave; P.O. Box 116, Port 041 586 4210 [email protected] Environmental Sub-Directorate Ms Jill Miller Elizabeth

6000 041 506 3195 7th floor, Mfanasekhaya Gqobose [email protected] Chandré Barnard NMBM: building, Govan Mbeki Ave | P.O. Box Water (Bulk Supply & Reservoirs) 116, Port Elizabeth Paul du Plessis - [email protected] 6000 Mr Conrad Bruintjies 6th floor, Mfanasekhaya Gqobose (Deputy Director: Wastewater [email protected] 041-506 2418 building, Govan Mbeki Avenue Conveyance) NMBM: Wastewater conveyance Ms Amsha Muthayan (Director: Wastewater - - [email protected] Conveyance) 9th Floor, Lillian Diedricks Building, NMBM: Yusuf Gaffore 041 506 2109 Govan Mbeki Ave | P.O. Box 116, Port [email protected] Roads and Stormwater Elizabeth, 6000 Department of Rural Development Ms Thabile Mehlomakhulu 043 700 7030 PO Box 1958, East London, 5200 [email protected] and Land Reform

BAYVIEW WIND FARM: UPDATED STAKEHOLDER AND I&AP DATABASE AFFECTED PROPERTY, COMPANY OR TELEPHONE CONTACT PERSON ADDRESS EMAIL ADDRESS DEPARTMENT NUMBER Councillor: [email protected] Ward 53 073 430 5967 - Cllr Nomazulu Mthi [email protected] Ms Aseza Dlanjwa 083 890 3719 [email protected] SALGA Eastern Cape Mr Zamikhaya Mpulampula 073 008 6102 - [email protected] Ms Zona Cokie 073 504 0787 [email protected] Telkom Raymond Couch 031 459 1542 - [email protected] Vodacom Andre Barnard 082 990 0673 - [email protected] MTN Krishna Chetty 083 222 9022 - [email protected] Corner Cape and Greyville Roads CELL C Lindley Bowles 084 877 7222 [email protected] Greenacres, Port Elizabeth [email protected] | SENTECH Alishea Viljoen 011 471 4540 - [email protected] Lizelle Stroh 011 545 1232 [email protected] Civil Aviation Authority (CAA) Private Bag X73, Halfway House, 1685 Werner Kleynhans 011 545 1468 [email protected] Dr Hanneline Smit-Robinson 011 789 1122 PO Box 515, Randburg, 2125 [email protected] BirdLife South Africa Nndwandiyawe Muhali - - [email protected] BirdLife South Africa: Birds and Samantha Ralson 083 673 3948 PO Box 515, Randburg, 2125 [email protected] Renewable Energy Manager BirdLife South Africa: Policy & Simon Gear - [email protected] Advocacy Manager Endangered Wildlife Trust: CEO Yolan Friedman 082 990 3534 [email protected] Endangered Wildlife Trust: Head of Dr Harriet Davies-Mostert 011 372 3600 [email protected] Conservation Science Endangered Wildlife Trust: African Crane Conservation Programme Kerryn Morrison 011 372 3600 [email protected] The Endangered Wildlife Trust, Private Manager Bag X11, Modderfontein, 1609, Endangered Wildlife Trust: African Johannesburg Crane Conservation Programme Glenn Ramke 011 372 3600 [email protected] - Field Officer Endangered Wildlife Trust: Wildlife Lourens Leeuwner 011 372 3600 [email protected] & Energy Programme Endangered Wildlife Trust: Dr Jeanne Tarrant New 083 254 9563 [email protected] Threatened Amphibian Programme Eastern Cape Parks and Tourism Wayne Erlank [email protected] - Agency (ECPTA) Brian Reeves [email protected] Council of Geoscience Port Elizabeth Local Office 012 841 1911 Private Bag X112, Pretoria, 0001 | [email protected]

BAYVIEW WIND FARM: UPDATED STAKEHOLDER AND I&AP DATABASE AFFECTED PROPERTY, COMPANY OR TELEPHONE CONTACT PERSON ADDRESS EMAIL ADDRESS DEPARTMENT NUMBER 041 581 1164 P.O. Box 5347, Walmer, 6065

Addo Elephant National Park: Conservation manager [email protected] John Adendorff Nick de Goede – Park Manager 041 508 5422 PO Box 787, Pretoria 0001 [email protected] Addo Elephant Nat. Park Dr Angela Gaylard SANPARKS [email protected] Regional Ecologist Maretha Alant 083 455 4050 [email protected] Environmental planner New P.O. Box 3542, Knysna, 6570 Kristal Maze New [email protected] 041 508 5422 Marie Baard New [email protected] Lucky Ramabulana New - - [email protected] East Cape Game Management - - - [email protected] Association 046 622 5822 WESSA EC Regional Representative Jenny Gon - [email protected] 079 038 6809 Wildlife Ranching RSA Ankie Stroebel - - [email protected] Peakers Ajay Brijmohan - - [email protected] Louis Dewavrin [email protected] EDF Renewables as Grassridge Wind Warren Randall 041 506 4900 - [email protected] Farm Sheldon Vandrey [email protected] Jadon Schmidt 13 Stanley Street, Richmond Hill, [email protected] Red Cap Energy 041 582 1834 Simon Daniel (left) send to Jess Port Elizabeth, 6000 [email protected] * [email protected] 041 466 5698 Coega IDZ ECO Dr Paul Martin PO Box 61029, Bluewater Bay 6212 [email protected] 073 252 4111 117 Cape Road, Mill Park, Port Coega IDZ ECO Christelle du Plessis 074 148 5586 [email protected] Elizabeth, Eastern Cape, 6001 Cell C Hugo Dippenaar - - [email protected] Blue Horizon Wind Pierre Jonker - - [email protected] Tunnel project Integrated Wind Power Jonathan Visser New 073 268 7797 - [email protected] 082 825 6069 5th Floor, 125 Buitengracht Street, Cape G7 Renewable Energies (Pty) Ltd Veronique Fyfe New [email protected] (Mobile) 021 Town, 8001

BAYVIEW WIND FARM: UPDATED STAKEHOLDER AND I&AP DATABASE AFFECTED PROPERTY, COMPANY OR TELEPHONE CONTACT PERSON ADDRESS EMAIL ADDRESS DEPARTMENT NUMBER 300 0610 (Office) WKN Windcurrent SA (Pty) Ltd Zakiya Abrahams New 074 955 0118 PO Box 762, Wilderness, 6560 [email protected]

3. PROOF OF ADVERTISEMENT

DATE PLACED: 27 AUGUST 2020

NEWSPAPER: THE HERALD (THE HERALD CLASSIFIEDS, PAGE 17)

4. COMMENTS AND RESPONSE TRAIL

NOTIFICATION OF THE DRAFT AMENDED ENVIRONMENTAL IMPACT REPORT (EIR) AVAILABLE FOR PUBLIC REVIEW: PROPOSED BAYVIEW WIND FARM NEAR PORT ELIZABETH IN THE EASTERN CAPE PROVINCE (DEFF Reference Number: 14/12/16/3/3/2/1055).

Please find the Bayview Wind Farm Draft Amended EIR Letter of Notification attached. The Draft Amended EIR will be available for public review from today, the 28th of August, until the 29th of September 2020. You can access a soft copy of the Draft Amended EIR on the CES Email notification sent to all registered website, http://www.cesnet.co.za/bayview-windfarm- 28 August 2020 Stakeholders and I&APs. port-elizabeth.

Please do not hesitate to contact us should you require any additional information, should you have difficulty downloading the reports from our website, or should you wish to submit comments on the Draft Amended Bayview Wind Farm EIR.

Contact Person: Rosalie Evans Email Address: [email protected] Telephone Number +27 (0)46 622 2364 (Head Office): Postal Address (Head PO Box 934, Office): Grahamstown, 6140

Kind regards, Rosalie Maretha Alant 31 August 2020 (via email)

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE SANParks Can you please provide me with comments received from SANParks (Mr John Adendorff) became involved in the Tel.: 083 455 4050 SANParks for this application or records of any meetings or Bayview Wind Farm project during the pre-application Email: [email protected] fieldtrips attended and proof of documents sent to Public Participation Process (PPP), in November 2017. SANParks. The wind farm is located in the buffer zone of the Mrs Kim Brent received an email from Mr John AENP and this was not mentioned in the EIR. Adendorff (14 November 2017), in response to the email notification of intent to apply for Environmental

Authorisation (EA), below. In addition, SANParks was notified of the availability of the Draft EIR for public review from the 20th of August 2018 until the 20th of September 2018. This notification included the details of the public meeting on the Draft EIR, which was held in Bluewater Bay on the 5th of September 2018. (via letter attached to email) 1. Wake Impact Assessment. The Wake Impact Assessment did not consider the effect of the wind generated by the Wind turbines do not generate wind, the wind drives turbines on flying operations in AENP. Aerial monitoring the turbines and the minor residual impact or wake flights by means of light sport aircraft as well as ranger patrols have been assessed in the Wake Impact Assessment form the basis of the Parks rhino monitoring program. This is Report. The wake impact of the proposed Bayview Wind further supplemented by the use of camera traps and Farm specifically relates to the wake impact of the helicopter flights. Aerial monitoring is not only an essential proposed Bayview Wind Farm turbines on other Maretha Alant on behalf of Property component of the monitoring work, but also plays a major turbines in the vicinity, such as the operational Mokoena (SANParks managing role in the Parks anti-poaching operations. The use of light Grassridge Wind Farm. executive), Angus Tanner (Wilderness sport aircraft (one of which is permanently based in the Park) Foundation Africa senior manager) and allows for real-time information gathering and the ability to The impact of the proposed Bayview Wind Farm on Angela Stoeger (Department of 23 September cover large areas in a short period of time and to also cover flying operations in the area has been assessed with Air Behavioral and Cognitive Biology, 2020 rugged terrain that cannot be accessed by vehicle. Traffic Navigation Services (ATNS) with respect to University of Vienna) aircraft. SANParks Light sport aircraft have proven critical in the capture and Tel.: 083 455 4050 arrest of suspected poachers and regular patrols ensure a Ms Lizell Stroh, Obstacle Inspector, PANS-OPS Email: [email protected] constant visual presence that acts as a deterrent to would be (Procedures for Air Navigation Services-Aircraft poachers. Aerial monitoring also supports other Conservation Operations), Air Navigation Services, as representative objectives in the Park such as locating injured animals, carcass of the S.A. Civil Aviation Authority (SACAA), has been a detection, monitoring of remote water points and monitoring registered I&AP on the Bayview Wind Farm Registered of rare species using telemetry fitted to the aircraft. Stakeholder and I&AP Database throughout the processes. Pilots are already experiencing difficulty flying in AENP as a result of the Grassridge Wind Farm, which creates extreme turbulence downwind from the turbines. The turbulent air

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE pushed back from these turbines can be felt as far as 23 km away and although these pose no threat to heavy, transport aircraft the turbulence caused from these turbines can cause unsafe flying conditions for smaller, general aviation aircraft. There would thus be a constant threat to pilots operating in AENP and there have already been two such incidents while conducting low level patrols along the Western boundary of the Park. Please refer to the letter from Wilderness Foundation Africa’s pilot in Appendix A.

The existing Grassridge Wind Farm comprises 20 wind turbines with a blade tip height of 140 m and the proposed Bayview Wind Farm is for 43 wind turbines with a blade tip height of 225 m. The higher blade tip height (85 m higher that Grassridge turbines), 43 new turbines versus the 20 existing Bayview turbines and closer proximity to AENP will be very problematic for anti-poaching and monitoring operations and a constant threat to pilots. (via letter attached to email) It must be noted that the Bayview Wind Farm Draft 2. Noise Impact Assessment. Elephants use vocal signals in Amended EIR specifically relates to the inclusion of the the infrasonic range to communicate and this communication Wake Impact Assessment Report in the previously is used to mediate social and sexual interactions and to submitted Final EIR, as per the Minister’s decision on coordinate group movements between the various family the appeal by Grassridge Wind Power on the Bayview groups. Communication over long distances (up to 3 – 4 km) Wind Farm Environmental Authorisation. The Noise is an important part of elephant behaviour and other than Impact Assessment Report (SafeTech, 2018) has not smell, sound is the most important form of communication been amended in the Draft Amended EIR submission. between elephants. The Noise Impact Assessment Report (SafeTech, 2018) was previously available for public review during the It is suggested that infrasound generated by turbines can public review of the Draft EIR (20 August 2018 – 20 have a negative effect up to 15-20km away from the actual September 2018). SANParks, and specifically Ms turbines and thus the infrasound generated by the turbines Maretha Alant, were notified of the availability of the will have a strong negative effect on elephant behaviour and Draft EIR (and associated specialist reports) for public their ability to effectively communicate. This could influence review on the 20th of August 2018. their social structure and mating strategies and could potentially have an effect on their health and welfare. According to the Noise Impact Assessment Report (SafeTech, 2018) was submitted to the DEFF as part of A zoologist and bio-acoustician conducting research on the Bayview Wind Farm Draft EIR, Final EIR and Draft elephant in AENP for the past 9 years has indicated that the Amended EIR submissions: “The results of the study

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE proposed wind farm, in such close proximity to the Park, will indicate that the following conclusions can be drawn: produce intensive anthropogenic infrasonic noise which in ...g) The impact of the low frequency noise at the turn will impact on the elephant’s behaviour and boundary of the Addo National Elephant Park needs to communication. Furthermore, if the Bayview wind farm is be confirmed by an elephant specialist if deemed developed acoustic and behavioural research will no longer necessary by the National Parks Board.” – Bayview be feasible in AENP. Please refer to the letter from Dr Angela Wind Farm Noise Impact Assessment Report (SafeTech, Stoeger in Appendix B and her CV in Appendix C. 2018)

AENP is world renowned for the unique and special elephant “3.7. Low Frequency Noise and Infrasound (Animal population that has been extensively researched for a Receptors): As the development is close to Addo number of years. A long term individual identification National Elephant Park, a short literature survey was database, documenting the unique life history of the Parks conducted of the effects of low frequency noise on elephant still exists and is regularly updated and this elephant communication. This author could not locate combined with the characteristics of the population, makes it any specific information on the effects that wind turbine an ideal population for research. Close encounters with the generators have on elephants. A number of articles elephant of the Park are a major tourism drawcard which were however found on elephant communication in could potentially be negatively impacted should their general, which is of interest. behaviour and social structures be affected by the turbines, Larom, Garstang, Payne, Raspet and Lindeque (1996) as suggested by researchers. report the following: • Elephants mostly communicate around the 14-35Hz rang. • The threshold of hearing for an elephant is hypothesized as approximately 50dB. • The loudest unstressed sound made by an elephant is recorded as 117dB (sound pressure level). • The attenuation by distance to reach the elephants’ threshold of hearing is thus approximately 67dB. (Larom et al 1996:422)

This information was used to interpret the maximum sound pressure level from the turbines under no wind masking conditions at the Addo National Elephant Park boundary. It may be that there is more up to date research on this topic that the elephant specialist will have access to that will assist in the interpretation of the results.

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE As previously stated, the noise data that is presented in this report should be interpreted by a suitably qualified specialist should the Addo Elephant National Park have a concern with the effects of low frequency noise on the elephants and other animals.” – Bayview Wind Farm Noise Impact Assessment Report (SafeTech, 2018).

SANParks was included in all correspondence throughout the original Scoping and EIA process, and all documents (including the Noise Assessment Report) were made available to SANParks. No formal comments regarding the potential noise impacts were received from SANParks during the original Scoping and EIA Process. It must be noted that the Bayview Wind Farm Draft Amended EIR specifically relates to the inclusion of the Wake Impact Assessment Report in the previously submitted Final EIR, as per the Minister’s decision on (via letter attached to email) the appeal by Grassridge Wind Power on the Bayview 3. Visual Impact Assessment. The proposed Bayview wind Wind Farm Environmental Authorisation. The Visual farm will have a high negative impact on AENP during the day Impact Assessment Report (CES, 2018) has not been and at night and no mitigation is possible. amended in the Draft Amended EIR submission. The Visual Impact Assessment Report (CES, 2018) was The visual impact resulting from the Bayview Wind Farm will previously available for public review during the public have a significant negative effect on visitors to the AENP. The review of the Draft EIR (20 August 2018 – 20 September turbines will be visible from many tourist roads from 2018). SANParks, and specifically Ms Maretha Alant, Colchester to Zuurberg Mountains and viewpoints and will were notified of the availability of the Draft EIR (and detract from the natural sense of place experienced by associated specialist reports) for public review on the visitors to the park. The night skies, an important draw card 20th of August 2018. for tourists, will also be significantly negatively affected. AENP is considered the most sensitive visual receptor according to The Visual Impact Assessment Report (CES, 2018) the Visual Impact Assessment. The tourism product in AENP considered the visual impact that the proposed Bayview will be significantly degraded from visual pollution. Wind Farm will have on the Addo Elephant National Park as part of the assessment and this information was submitted to the DEFF as part of the Bayview Wind Farm Draft EIR, Final EIR and Draft Amended EIR submissions:

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE “In terms of identified sensitive receptors: The Addo Elephant National Park is considered the most sensitive receptor and is located roughly 4.5km from the nearest wind turbine. Turbines will be visible from sections of the park. This is considered a sensitive visual receptor.”

“Operations Phase Impact 1: Impact of wind turbines on visually sensitive points and areas Cause and comment The hub of the turbines proposed will be 150m (worst case scenario) above the ground. The blade length of each turbine is anticipated to be approximately 75 m in length. Therefore, the viewshed calculation has calculated the 47 turbines’ [7 of these turbines have been removed; 40 turbines remain in their original proposed locations] viewshed using a blade tip height of 225m. As seen in the cumulative viewshed, most of the turbines will be visible from the surrounding areas. Notable features in this area include Motherwell, Addo, Colchester, the R335 and multiple homesteads. More importantly to note is that all 47 turbines will be visible in some areas of the Addo Elephant National Park and it is these areas that are considered to be sensitive to the presence of the wind farm. Mitigation and management

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE Other than avoiding the site completely there are no mitigation measures that will reduce the visual intrusion of the wind turbines due to their size, height and visibility, and the lack of screening opportunities in the landscape. However, there are a number of measures and suggestions that can enhance the positive aspects of the impact. • Turbines must be properly maintained. A spinning rotor is perceived as being useful. If a rotor is stationary when the wind is blowing it is seen as not fulfilling its purpose and a negative impression is created (Gipe 1995). • Signs near wind turbines should be avoided unless they serve to inform the public about wind turbines and their function. Advertising billboards should be avoided. • According to the Aviation Act, 1962, Thirteenth Amendment of the Civil Aviation Regulations, 1997: “Wind turbines shall be painted bright white to provide maximum daytime conspicuousness. The colours grey, blue and darker shades of white should be avoided altogether. If such colours have been used, the wind turbines shall be supplemented with daytime lighting, as required.” • Lighting must be designed to minimise light pollution without compromising safety. Investigate using motion sensitive lights for security lighting. Turbines are to be lit according to Civil Aviation regulations (see Operations Phase Impact 4).”

(via letter attached to email) The Public Participation Process (PPP) which was 4. Poor Public Participation. The Environmental Assessment undertaken during the Bayview Wind Farm Scoping and Practitioners did a tick-box exercise and SANParks was not EIA Process was undertaken in accordance with Chapter

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE formally consulted during the EIA process. SANParks was 6 of the NEMA (Act No. 107 of 1998, as amended) EIA registered as an Interested and Affected Party and provided Regulations (2014 and subsequent 2017 amendments). brief initial comments in the pre-assessment phase of the project. Our concerns were noted in the proof of public SANParks was notified of the proposed Bayview Wind participation (Appendix C) in November 2017 but there was Farm development during the pre-application PPP no formal engagement with SANParks. The incorrect email notification, public review of the Draft Scoping Report, was used for the Park Manager. public review of the Draft EIR, notification of the submission the Final EIR, and notification of the The Bayview Wind Farm came to our attention formally after Environmental Authorisation issued by the DEFF. In the Minister Ms B.D. Creecy set aside the EA based on the addition, this included email invitations to the public appeal. SANParks would have objected during the EIA phase meetings which were held during the Scoping Phase and of the proposed project if we were engaged by the the EIA Phase of the process. consultants. AENP will be significant negatively affected from a management and visitor experience perspective and Mr John Adendorff provided the EAP with the incorrect wildlife behaviour will be negatively affected by this project. email address for Mr Nick de Goede. The EAP used the That the proposed site is in the AENP buffer zone was not email addresses provided verbatim. Dr Angela Gaylard mentioned in the EIA Reports and AENP was not included on and Ms Maretha Alant were both consulted (using their the maps in the documents. correct email addresses), as were all registered stakeholders, from the initial PPP stage throughout the PPP process.

All stakeholders are given equal opportunity to comment, attend public meetings and engage with the EAP during the formal PPP process. The fact that SANParks engaged with the EAP during the initial stages of the PPP and then failed to comment on reports or engage further is a failure on SANParks part and not on the part of the EAP’s PPP. The EAP followed all legislated PPP procedures.

Additional PPP, which was subsequently undertaken on the Draft Amended EIR, was undertaken in accordance with Chapter 6 of the NEMA (Act No. 107 of 1998, as amended) EIA Regulations (2014 and subsequent 2017 amendments) as well as the approved Public Participation Plan [a requirement since 5 June 2020 in response to the Covid-19 pandemic]. SANParks was

As per the email proofs available in the next section, and to correct the section of the SANParks comment “The Bayview Wind Farm came to our attention formally after the Minister Ms B.D. Creecy set aside the EA based on the appeal. SANParks would have objected during the EIA phase of the proposed project if we were engaged by the consultants.”, SANParks was initially notified of the Bayview Wind Farm on the 14th of November 2017 and were consulted throughout the process. All emails are available in the proofs section. (via letter attached to email) 5. Potential bad precedent for wind farms in National Park buffer zones. SANParks mission is to develop, protect, It must be noted that the Bayview Wind Farm Draft expand, manage and promote a system of sustainable Amended EIR specifically relates to the inclusion of the national parks that represents natural and cultural heritage Wake Impact Assessment Report in the previously assets, through innovation, excellence, responsible tourism submitted Final EIR, as per the Minister’s decision on and just socio- economic benefit for current and future the appeal by Grassridge Wind Power on the Bayview generations. If the Bayview wind farm receives Environmental Wind Farm Environmental Authorisation. Authorisation to go ahead it will set a bad precedent for wind farms in other National Park buffer zones and make it difficult There have been no changes to the description of the for SANParks to implement our mandate. no-go alternative, as referred to in the SANParks comment, in the Draft Amended EIR, however, it has The Draft Amended Environmental Impact Report, 27 August been noted that SANParks supports Activity Alternative 2020, states that should the proposed Bayview Wind Farm 2 – the No-go Alternative. development not proceed, it is likely that alien vegetation will continue to spread and encroach indigenous vegetation which will eventually be replaced by the alien vegetation. (via letter attached to email) To conclude, SANParks supports Alternative 2, the No Go Alternative. Alien vegetation can be managed fairly easily and provide jobs. If the project goes ahead anti-poaching and monitoring activities relying on aircraft will become dangerous as a result of extreme turbulence, the tourism experience will be degraded as a result of visual pollution and

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE elephant behaviour and communication compromised as a result of noise pollution. To whom it may concern, A signed 10 year Memorandum of Understanding for conservation support is in place between SANParks and Wilderness Foundation Africa (WFA), according to which WFA is presently supporting Addo Elephant National Park (AENP) with black rhino monitoring and security flights.

This population is thought to be the 3rd largest in South Africa and has African Rhino Specialist Group Key 1 status due to the population size being over 100 individuals, with a stable or increasing trend. This population is regarded as critical for the wider survival of the subspecies. AENP is currently solely reliant on WFA’s aerial support in order to maintain the Ms Lizell Stroh, Obstacle Inspector, PANS-OPS required level of rhino monitoring effort that is required for (Procedures for Air Navigation Services-Aircraft the management of this Key 1 black rhino population. Operations), Air Navigation Services, as representative

of the S.A. Civil Aviation Authority (SACAA), has been a Aerial monitoring flights by means of light aircraft as well as registered I&AP on the Bayview Wind Farm Registered ranger patrols form the basis of this rhino monitoring Stakeholder and I&AP Database throughout the program, which is further supplemented through the use of processes. The Applicant has had extensive motion activated trail cameras and occasional helicopter engagement with Air Traffic Navigation Services (ATNS) flights. Aerial monitoring is an essential component of the with respect to aircraft and the Applicant has submitted monitoring work as it enables fast and real-time information an Application to the SACAA. gathering over large areas of densely vegetated and rugged terrain, which is often inaccessible to vehicles or too remote for foot patrols to be deployed effectively.

The role of the light aircraft as a poaching deterrent and surveillance tool cannot be underestimated. In other protected areas in Southern Africa light aircraft have been proven to be critical in operations to capture and arrest poaching syndicates. The visual presence acts as a deterrent for poaching incursions and early carcass detection alerts the reserve staff to a poaching problem and may lead to further arrests.

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE With this information in hand, WFA is strongly opposed to constructing a wind farm near any formally protected area. As the wind turbine blades turn to generate power, they create extreme turbulence downwind. For large, heavy transport aeroplanes, this turbulence is not a great threat. For smaller general aviation aeroplanes and helicopters, passing behind a wind turbine introduces turbulence that can cause an unsafe or fatal flight. The spiralling turbulent air pushed back from turbines can be felt as far as 23km / 12.4NM (Nautical miles).

This is the distance between the already established wind farm north of the Coega harbour and the AENP western boundary. On two occasions, near incidents were narrowly avoided while on a low level patrol on the western boundary of AENP. Once flying recoveries were made and the aeroplane was under full control of the pilots, it was clearly determined that the spiral turbulence from the Coega wind farm was the cause both times.

Legal flying air space will also be of high concern to the rest of the general aviation community who fly through this area of the Eastern Cape. SANParks air space and height restrictions are enforced by the South African Civil Aviation Authority (SACAA) laws. No aircraft without permission may enter SANParks air space at a height lower than 2500ft, above the highest point of that park. These height restrictions also extends the AENP air space partially into the Port Elizabeth TMA (Terminal Control Area) which is Class C airspace.

The suggested location for this proposed wind farm will create an obstruction that stands too high for aircraft flying the maximum allowed altitude of 1500ft on the Northern VFR Route in or out of Port Elizabeth International Airport (FAPE). This will force general aviation aircraft to divert around the proposed wind farm and contravene SANParks airspace or fly over it contravening TMA height restrictions. I am a zoologist and bioacoustician working at the Addo As per the response relating to the Noise Impact, it must

Elephant National Park on elephant vocal communication be noted that the Bayview Wind Farm Draft Amended

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE since 2011. Elephants use vocal signals in the infrasonic range EIR specifically relates to the inclusion of the Wake (from as low as 10 Hz) to communicate in close and long- Impact Assessment Report in the previously submitted distance contexts. This communication is used to mediate Final EIR, as per the Minister’s decision on the appeal by social and sexual interactions and to coordinate group Grassridge Wind Power on the Bayview Wind Farm movements. Communication over long distances (up to 3-4 Environmental Authorisation. The Noise Impact km) is a crucial part of elephant behaviour, besides smell, Assessment Report (SafeTech, 2018) has not been sound is the most important communication channel for amended in the Draft Amended EIR submission. The elephants. Noise Impact Assessment Report (SafeTech, 2018) was previously available for public review during the public Anthropogenic noise (airplanes, cars travelling in the park but review of the Draft EIR (20 August 2018 – 20 September also on the roads outside the park) is already impacting 2018). SANParks, and specifically Ms Maretha Alant, elephant communication. However, wind turbines specifically were notified of the availability of the Draft EIR (and create strong infrasound. It is created by the movement of the associated specialist reports) for public review on the blades through the air, as the blades pass the tower and, 20th of August 2018. depending on the construction of the turbine, by the gearbox. Infrasound travels far and it is suggested that turbines can According to the Noise Impact Assessment Report have a negative effect up to 15-20 km. (SafeTech, 2018) was submitted to the DEFF as part of the Bayview Wind Farm Draft EIR, Final EIR and Draft It has been scientifically proven that elephants are able to Amended EIR submissions: “The results of the study perceive infrasound (also because it is part of the range of indicate that the following conclusions can be drawn: their communication), and I have no doubt that the ...g) The impact of the low frequency noise at the infrasound generated by the turbines will have a strong boundary of the Addo National Elephant Park needs to negative effect on elephant behaviour, their communication be confirmed by an elephant specialist if deemed (which in the long term will influence their social organization necessary by the National Parks Board.” – Bayview and mating strategies) as well as potentially their health and Wind Farm Noise Impact Assessment Report (SafeTech, welfare. 2018)

The Addo Elephant National Park is known (worldwide) for “3.7. Low Frequency Noise and Infrasound (Animal the special elephant population. In addition, it is such a Receptors): As the development is close to Addo valuable population for research due to the long-term National Elephant Park, a short literature survey was identification database, the unique life history, the nature conducted of the effects of low frequency noise on and characteristic of the elephants as well as because of the elephant communication. This author could not locate fantastic working conditions at the park. Unfortunately, with any specific information on the effects that wind turbine a wind farm near the park, impacting elephant behaviour and generators have on elephants. A number of articles communication, and producing intensive anthropogenic were however found on elephant communication in infrasonic noise, acoustic and behavioural research will not be general, which is of interest. feasible at Addo anymore. Larom, Garstang, Payne, Raspet and Lindeque (1996) report the following:

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE As an elephant researcher with 20 years of experience, I • Elephants mostly communicate around the 14-35Hz strongly advise against the creation of a wind park in the rang. buffer zone close to the Addo Elephant National Park. • The threshold of hearing for an elephant is hypothesized as approximately 50dB. • The loudest unstressed sound made by an elephant is recorded as 117dB (sound pressure level). • The attenuation by distance to reach the elephants’ threshold of hearing is thus approximately 67dB. (Larom et al 1996:422)

As previously stated, the noise data that is presented in this report should be interpreted by a suitably qualified specialist should the Addo Elephant National Park have a concern with the effects of low frequency noise on the elephants and other animals.” – Bayview Wind Farm Noise Impact Assessment Report (SafeTech, 2018)

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE recommendations made by the specialist in the Wake Effect comment on the final Bayview Wind Farm layout and Report and on this basis accepts the potential wake losses any updated wake effect reports, should the current referred to in the Wake Effect Report. However, Grassridge Wake Impact Assessment be updated. reserves any rights or remedies that may become available to it in terms of applicable law. Finally, Grassridge requests that it be provided with an opportunity to comment on any final layout and any updated wake effect reports.” The Application for Environmental Authorisation and amended Draft Environmental Impact Assessment Report (EIAr) received by the Department on 27 August 2020 and 01 September 2019, respectively, refer.

The amended Draft Environmental Impact Assessment Report (EIAr) stated the following: Bayview Wind Power (Pty) Ltd, is proposing the development of a wind farm on the outskirts of Port Elizabeth, Eastern Cape Province. The Bayview Wind Farm will host a maximum of forty-three (43) turbines, with potential net generating The Final Amended EIR includes the forty (40) turbine output capacity of one-hundred and forty (140) megawatts layout and updated descriptions. Turbines WTG 02, (MW). WTG 04 and WTG 09 have been removed from the Integrated Environmental Authorisations proposed Bayview Wind Farm layout. Department of Environment, Forestry The details of the proposed development includes: 12 October and Fisheries (DEFF) • Construction and operation of a maximum of forty-three It must be noted that the three (3) turbines were not 2020 Tel.: 012 399 8630 (43) wind turbines; initially removed from the proposed forty-three (43) Email: [email protected] • Expansion and possible construction of access roads turbine layout because the wake impact of the forty within the wind farm locality; (43) turbines was deemed to have a low negative • Construction of underground power cables to link to a impact on the Grassridge Wind Farm (increase of wind farm substation; between 0.4% and 0.5%). • Construction of an overhead powerline (132 kV); and • Construction of associated infrastructure.

The above-mentioned statement contradicts the recommendation of the Wake Effect Specialist Study, which reads as follows:

According to the 3E assessment, the existing wake losses on the operational Grassridge Wind Farm, in the absence of the development of the proposed Bayview Wind Farm, are likely

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE to be 4.2%. The establishment of the Bayview Wind Farm could contribute additional wake loss to the Grassridge Wind Farm ranging from between 0.4% and 0.5% depending on the turbine model. This is lower than the Électricité de France (EDF) Renewables study which indicated 1% wake loss of Bayview Wind Farm on the Grassridge Wind Farm.

Then results show that there is a limited additional wake loss on the Grassridge Wind Farm. This result can be explained by the wind rose on the site, which indicates that the proposed Bayview Wind Farm is in the lee of the existing Grassridge Wind Farm. As indicated in the table above, the wake impact of the Bayview Wind Farm on the Grassridge Wind Farm increases with an increase of rated power of the turbine types due to a higher thrust. 3E is of the opinion that this increase in wake loss could be partially compensated by selecting a higher hub height for the turbines. In addition to selecting turbines with higher hub heights, in order to further reduce the wake loss of the Grassridge Wind Farm, according to the wind rose on site, 3E suggest removing OR relocating three (3) of the proposed Bayview Wind Farm turbines, specifically turbines WTG 02, WTG 04 and WTG 09. Specific comments The Final Amended EIR includes the forty (40) turbine Please ensure that an amended layout plan as recommended layout and updated descriptions. Turbines WTG 02, by the Wake Effects Study is submitted together with the final WTG 04 and WTG 09 have been removed from the amended EIAr. proposed Bayview Wind Farm layout. The EMPr must be amended to be in line with the amended layout plan. All recommendations and mitigation measures The Amended EMPr has been included in the Final recorded in the final amended EIAr and the Wake Effect Study Amended EIR submission. must be considered and addressed. The Final Amended EIR includes the forty (40) turbine The project description must be amended to relate to the layout and updated descriptions. Turbines WTG 02, recommendation of the wake effect specialist. WTG 04 and WTG 09 have been removed from the proposed Bayview Wind Farm layout. The Final Amended EIR includes the forty (40) turbine New coordinates of the footprint that covers the location of layout and updated descriptions. The coordinates for the wind turbines must be submitted with the final amended turbines WTG 02, WTG 04 and WTG 09 have been EIAr. removed Table 2.3 in the Final Amended EIR. The corner

COMMENTS AND RESPONSE TRAIL (PUBLIC REVIEW OF THE DRAFT AMENDED EIR – 28 AUGUST TO 29 SEPTEMBER 2020) STAKEHOLDER AND I&AP DETAILS DATE RECEIVED STAKEHOLDER AND I&AP COMMENT EAP/APPLICANT RESPONSE point coordinates of the affected properties remain unchanged. The maps in the Draft Amended EIR have been replaced New maps that only shows the location of the wind turbines in the Final Amended EIR, to only include the forty (40) must be submitted with the final amended EIAr. turbine layout. An amended application form must be submitted together The Amended Application for Environmental with the final amended EIAr should there be any changes on Authorisation has been included in the Final Amended the form. EIR submission. Specialist Declaration of Interest The completed 3E Specialist Declaration has been Specialist Declaration of Interest Forms must be attached to included in the Final Amended EIR submission. For the the final amended EIAr. You are therefore requested to other specialists, the previously submitted specialist submit original signed Specialist Declaration of Interest Forms declarations have been resubmitted as there have been for each specialist study conducted. The forms are available no changes to these specialist reports since the on the Department’s website, please use the Department’s previous Final EIR submission. template. General Please also ensure that the final amended EIAr includes the period for which the Environmental Authorisation is required and the date on which the activity will be concluded as per Appendix 3 of the NEMA EIA Regulations, 2014, as amended. The period for which the Environmental Authorisation

is required is 10 years and the activity will be Should you fail to meet any of the timeframes stipulated in concluded/operational 24 months after construction Regulation 23 of the NEMA EIA Regulations. 2014, as has commenced. Once construction has been amended, your application will lapse. completed, the Bayview Wind Farm will be operational

for a period of 20-25 years. You are hereby reminded of Section 24F of the National Environmental Management Act, Act No. 107 of 1998, as amended, that no activity may commence prior to an Environmental Authorisation being granted by the Department.

5. PROOF OF EMAIL COMMENTS

6. PROOF OF OTHER WRITTEN COMMENTS (LETTERS)