DRAFT CONSERVATION MANAGEMENT PLAN:

WILD COAST SPECIAL ECONOMIC ZONE

(SEZ) :

DRAFT CONSERVATION MANAGEMENT PLAN FOR THE WILD COAST SPECIAL ECONOMIC ZONE (SEZ) MTHATHA, PROVINCE

DRAFT CONSERVATION MANAGEMENT PLAN

Prepared for: COEGA DEVELOPMENT CORPORATION

COEGA DEVELOPMENT CORPORATION (CDC)

Prepared by:

CES

EAST LONDON 25 Tecoma Street Berea, East London, 5214 043 726 7809 Also in Grahamstown, , Cape Town, Johannesburg and Maputo (Mozambique)

www.cesnet.co.za

SEPTEMBER 2019

DRAFT Conservation Management Plan

REVISIONS TRACKING TABLE

CES Report Revision and Tracking Schedule Document Title: DRAFT CONSERVATION MANAGEMENT PLAN FOR THE WILD COAST SPECIAL ECONOMIC ZONE (SEZ) MTHATHA Client Name & COEGA DEVELOPMENT CORPORATION (CDC) Address:

Status: Final Draft

Issue Date: September 2019

Lead Author: Caryn Clarke

Reviewer:

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

0 1 Simphiwe Silwana

Report Version Date

September 2019

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

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

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PROJECT TEAM

Dr Greer Hawley: Reviewer and Conservation and Botanical Specialist

Dr Greer Hawley has a BSc degree in Botany and Zoology and a BSc Honours in Botany from the University of Cape Town. She completed her PhD thesis (Microbiology) at Rhodes University. Greer has been involved in a number of diverse activities. The core academic focus has been in the field of taxonomy both in the plant and fungal kingdom. Greer's research ranges from fresh water and marine algae, estuarine diatoms, plant species classification in the fynbos and forest vegetation and fungal species identification and ecology. Greer has been involved in environmental and biodiversity impact assessments and environmental and biodiversity management projects both in South Africa and other African countries. Greer has recently assisted with the completion of the Eastern Cape Biodiversity Conservation Plan (2019), the Eastern Cape Biodiversity Strategy and Action Plan and assisted with the generation of the Western Cape State of the Coast Report. She is currently involved with finalising the Environmental Management Framework for the King Cetshwayo District Municipality.

Ms Caryn Clarke: Project Manager and Report Writer

Caryn holds a M.Sc. Environmental Science (2012), B.Sc. Hon. Environmental Science (2010), and a B.Sc. Environmental Science and Economics (2009) from Rhodes University. Her M.Sc. thesis was titled “Responses to the linked stressors of Climate Change and HIV/AIDS amongst vulnerable rural households in the Eastern Cape, South Africa”. Her B.Sc. Hon. thesis investigated climate change perceptions, drought responses and views on carbon farming amongst commercial livestock and game farmers within the Great Fish River Valley, Eastern Cape, from which a paper was published in the African Journal of Range and Forage Science 2012, 29(1):13-23. Caryn has further completed a Carbon Footprint Analysis Course (2013).

Caryn’s expertise includes project management, feasibility studies (aquaculture), environmental impact assessments including public participation, MPRDA applications, environmental compliance monitoring, various licensing and permit applications, and GIS mapping. Caryn is a registered Candidate Natural Scientist under the South African Council for Natural Scientific Professions.

Ms Jaclyn Smith: Aquatic and Wetland Specialist

Jaclyn has a BSc degree in Geology and Environmental Science and a BSc (Honours) Degree in Geology. Jaclyn has worked as an environmental consultant for over 5 years. She has experience in managing and undertaking Environmental Impact Assessments for both NEMA and NEMWA applications. She has prepared Environmental Screening Reports, aquatic and wetland assessments, managed water use licence applications and she has extensive experience in construction compliance auditing.

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TABLE OF CONTENTS

1 INTRODUCTION ...... 1

1.1 BACKGROUND ...... 1 1.2 PROJECT DESCRIPTION ...... 1 1.3 LOCATION ...... 2 1.4 AIMS AND OBJECTIVES ...... 1 1.5 METHODOLOGY ...... 1 2 LEGAL AND ADMINISTRATIVE FRAMEWORK ...... 2

2.1 RELEVANT LEGLISATION ...... 2 2.2 RELEVANT POLICY AND PLANS ...... 8 2.3 RELEVANT DOCUMENTS ...... 8 3 ROLES AND INSTITUTIONAL ARRANGEMENTS ...... 9

4 CONSERVATION VALUE ASSESSMENT ...... 10

4.1 BASELINE ASSESSMENT ...... 10 4.1.1 BIODIVERSITY PLANS AND STRATEGIES ...... 10 4.1.2 VEGETATION AND HABITAT ASSESSMENT ...... 12 4.1.3 WETLAND HABITAT ASSESSMENT ...... 13 4.1.4 SPECIES OF CONSERVATION CONCERN ...... 15 4.1.5 LAND USE ...... 16 4.1.6 SUMMARY OF EXISTING PRESSURES AND THREATS ...... 16 4.2 SITE ASSESSMENT...... 18 4.3 CONCLUSION...... 22 5 MANAGEMENT FRAMEWORK ...... 23

5.1 CONSERVATION OUTCOMES ...... 23 5.2 MANGEMENT ACTIONS ...... 23 5.2.1 CO 1: The Open Space: Grassland area within the Mthatha WCSEZ is conserved and further degradation is prevented ...... 24 5.2.2 CO 2: The Open Space: Wetland areas are rehabilitated and conserved ...... 27 5.2.3 CO 3: Land use activities within the adjacent areas must not contribute to the further degradation of the Open Space: Grassland and Wetlands areas ...... 32 5.2.4 CO 4: The Open Space: Grassland and Wetlands areas are regularly monitored and evaluated against the baseline...... 35 5.3 COSTING PLAN ...... 37 6 CONCLUSION ...... 39

7 REFERENCES ...... 40

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LIST OF TABLES

Table 1-1: Methodology ...... 1 Table 2-1: Legislative overview ...... 2 Table 4-1: Key conservation context of the study area (taken directly from Eco-Pulse, 2018)...... 10 Table 4-2: Summary of baseline wetland assessment ...... 14 Table 4-3: Summary of existing impacts to the wetland units (Eco-Pulse, 2018)...... 16 Table 4-4: Summary of existing impacts to the terrestrial ecological environment ...... 17 Table 5-1: Management plan for Open Space: Grassland area ...... 24 Table 5-2: Management plan for wetland rehabilitation and maintenance...... 27 Table 5-3: Management plan for surrounding land use activities ...... 32 Table 5-4: Monitoring plan ...... 35 Table 5-5: Costing Estimate ...... 37

LIST OF FIGURES

Figure 1-1: Site Layout Plan ...... 1 Figure 4-1: ECBCP Aquatic CBA map of the study area (Eco-Pulse, 2018)...... 11 Figure 4-2: ECBCP Terrestrial CBA map of the study area (Eco-Pulse, 2018)...... 12 Figure 4-3: Terrestrial vegetation communities found within the Mthatha WCSEZ (Eco-Pulse, 2018)...... 13 Figure 4-4: Wetland Map (Eco-Pulse 2018) ...... 15 Figure 4-5: Photo sequence ...... 18 Figure 4-6: Photo 1: View of the wetland system within the north western portion of the study site (looking south east)...... 18 Figure 4-7: Photo 2: Wetland within the north western corner of the study site...... 19 Figure 4-8: Photo 3: Eroded gabion within the wetland system, and bare soil requiring revegetation...... 19 Figure 4-9: Photo 4: Drive over stormwater outlet leading from the wetland system (above). Material placed near the road side has slowed the flow of the wetland and has resulted in more surface water pooling within the wetland system...... 20 Figure 4-10: Photo 5: View of the wetland system looking west...... 20 Figure 4-11: Photo 6: Erosion around the culvert structure...... 20 Figure 4-12: Photo 7: View of the wetland system looking west...... 21 Figure 4-13: Photo 8: Erosion of stormwater channel constructed for the airstrip...... 21 Figure 4-14: Photo 9: Mthatha Moist Grassland vegetation...... 21 Figure 4-15: Alien Invasive Plant (IAP) specie noted on site, Scottish Thistle (Onopordum acanthium)...... 22

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1 INTRODUCTION

1.1 BACKGROUND

The Department of Trade and Industry (DTI) developed the special economic zone (SEZ) policy to support and accelerate industrial development in targeted regions where socio-economic growth has been problematic. The Coega Development Corporation (CDC) was requested to assist DTI in the final development of a Feasibility and Business Plan for the proposed Wild Coast Special Economic Zone (WCSEZ). As part of the application made to establish the Wild Coast Special Economic Zone (WCSEZ), a detailed feasibility study was undertaken. This comprised of two broad components:

• Agro –processing study • A tourism corridor study

As a result of the feasibility study, an area of 226 ha (northern site: 161 ha and southern site: 65 ha respectively) located adjacent to the Mthatha was earmarked as Phase 1 of the proposed Wild Coast Special Economic Zone. An Environmental Impact Assessment (EIA) was completed in 2018, and the CDC was granted environmental authorisation (EA) for Phase 1 of the Mthatha WCSEZ on the 27 February 2019 (14/12//16/3/3/2/1064) for the following land uses:

• Agriculture • Commercial • Hotel and Conferencing • Industrial • Intensive agriculture and Business Process Outsourcing (BPO) • Open Space: Grassland • Open Space: Wetlands

1.2 PROJECT DESCRIPTION

Condition 12 and 13 of the EA for the Mthatha WCSEZ states:

12. The Environmental Management Programme (EMPr) submitted as part of the application for Environmental Authorisation is not approved. This EMPr must be amended and submitted to the Department for written approval prior to commencement of the activity. Once approved, the EMPr must be implemented and adhered to.

13. The amended EMPr must include the following: 13.1 A Conservation Management Plan; and 13.2 Proposed measures for rehabilitation and maintenance of wetlands on site.

It is CES understanding that the land uses to be zoned as Open Space: Grassland and Wetlands within the Mthatha WCSEZ are to be conserved and, as such, require a Conservation Management Plan (CMP) (as shown in Figure 1-1). The CDC has appointed CES to develop the CMP for the Mthatha WCSEZ. This CMP details management measures required for wetland rehabilitation and conservation management.

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A Terrestrial and Wetland Habitat Impact Assessment was conducted by Eco-Pulse Environmental Consulting Services (Eco-Pulse, report number EP341-02) during the EIA phase of the project, which has been used to inform the drafting of the CMP.

1.3 LOCATION

The Mthatha WCSEZ is located within the jurisdiction of King Sabata Dalindyebo Local Municipality (KSDLM) within the OR Tambo District Municipality (ORTDM). Phase 1 of the WCSEZ is located directly adjacent to the , bordering the airport both to the north and the south, as shown in Figure 1-1 below.

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Figure 1-1: Site Layout Plan

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1.4 AIMS AND OBJECTIVES

The aim of this CMP is to provide to necessary management guidelines and implementation framework for the long-term conservation of the areas designated for Open Space: Grasslands and Wetlands within the Mthatha WCSEZ (Figure 1-1), as well as the rehabilitation and maintenance of wetlands on site. This CMP should be read in conjunction with the existing EMPr (and associated documents detailed in Section 2.3 below).

The CMP should undergo internal review on an on-going basis and be externally reviewed by a suitably qualified environmental practitioner/specialist at least every five years to ensure its relevance and effectiveness in achieving the long-term protection of areas of conservation value identified within and surrounding the Mthatha WCSEZ.

1.5 METHODOLOGY

Table 1-1 below details the steps involved in establishing this CMP for the Mthatha SEZ:

Table 1-1: Methodology TASK DESCRIPTION Baseline Conservation - Establishing a baseline of the Mthatha WCSEZ through a desktop Assessment assessment based on existing biophysical and biological information applicable. Conservation value - Site visit to confirm desktop assessment. assessment Development of - Develop site specific management plans for the areas to be management conserved, detailing roles and responsibilities, mitigation and objectives and action rehabilitation measures to be implemented, monitoring plan requirements, and estimated budget implications for rehabilitation.

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2 LEGAL AND ADMINISTRATIVE FRAMEWORK

2.1 RELEVANT LEGLISATION

Table 2-1 below summarises the environmental legislation relevant to the proposed Mthatha WCSEZ development.

Table 2-1: Legislative overview LEGISLATION/POLICY DESCRIPTION The Constitution The Constitution of the Republic of South Africa is the supreme law of the land. As a result, all laws, including those pertaining to this Management Plan, must conform to the Constitution. The Bill of Rights - Chapter 2 of the Constitution, includes an environmental right (Section 24) according to which, everyone has the right:

a) To an environment that is not harmful to their health or well-being; and b) To have the environment protected for the benefit of present and future generations, through reasonable legislative and other measures that: i. Prevent pollution and ecological degradation; ii. Promote conservation; and iii. Secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.

National Environmental The objective of NEMA is: “To provide for co-operative environmental Management Act governance by establishing principles for decision-making on matters affecting (NEMA) (No. 108 of the environment, institutions that will promote co-operative governance and 1998), and its procedures for coordinating environmental functions exercised by organs of subsequent state; and to provide for matters connected therewith.” amendments. This CMP has been guided by the NEMA Principles, Section 2 of the Act: Environmental management must place people and their needs at (2) the forefront of its concern, and serve their physical, psychological, developmental, cultural and social interests equitably. (3) Development must be socially, environmentally and economically sustainable. (4)(a) Sustainable development requires the consideration of all relevant factors including the following: − That the disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied; − That pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied; − That waste is avoided, or where it cannot be altogether avoided, minimised and re-used or recycled where possible and otherwise disposed of in a responsible manner. (4)(e) Responsibility for the environmental health and safety consequences of a policy, programme, project, product, process, service or activity exists throughout its life cycle.

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LEGISLATION/POLICY DESCRIPTION (4)(i) The social, economic and environmental impacts of activities, including disadvantages and benefits, must be considered, assessed and evaluated, and decisions must be appropriate in the light of such consideration and assessment. (4)(j) The right of workers to refuse work that is harmful to human health or the environment and to be informed of dangers must be respected and protected. (4)(p) The costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment. (4)(r) Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal shores, estuaries, wetlands, and similar systems require specific attention in management and planning procedures, especially where they are subject to significant human resource usage and development pressure.

NEMA introduces the “duty of care” concept, which is based on the policy of strict liability. This duty of care extends to the prevention, control and rehabilitation of significant pollution and environmental degradation. It also dictates a duty of care to address emergency incidents of pollution. A failure to perform this duty of care may lead to criminal prosecution, and may lead to the prosecution of responsible persons, including companies, for the conduct of the legal persons.

National Environmental The NEMA EIA Regulations (2014, as amended) aim to avoid detrimental Management Act environmental impacts through the regulation of specific activities that cannot (NEMA): Environmental commence without prior environmental authorisation. Authorisation either Impact Assessment (EIA) requires a Basic Assessment or a Full Scoping and Environmental Impact Regulations (2014) and Assessment, depending on the type of activity. These assessments specify its subsequent mitigation and management guidelines to minimise negative environmental amendments. impacts and optimise positive impacts. Should any portion of an area be proposed for development (after proclamation) these Regulations should be consulted.

National Environmental The National Environmental Management: Protected Areas Act (NEMPAA), No. Management: Protected 57 of 2003, aims to protect, conserve and manage ecologically viable areas that Areas Act (No. 57 of represent South Africa’s biological diversity; this is achieved through a network 2003), and its of representative protected areas on state, private and communal land. This subsequent management plan has been guided by Section 17 of this Act which states: amendments. a) “To protect ecologically viable areas representative of South Africa’s biological diversity and its natural landscapes and seascapes in a system of protected areas; b) To preserve the ecological integrity of those areas; c) To conserve biodiversity in those areas;

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LEGISLATION/POLICY DESCRIPTION d) To protect areas representative of all ecosystems, habitats and species naturally occurring in South Africa; e) To protect South Africa’s threatened or rare species; f) To protect an area, which is vulnerable or ecologically sensitive; g) To assist in ensuring the sustained supply of environmental goods and services; h) To provide for the sustainable use of natural and biological resources; i) To create or augment destinations for nature-based tourism; j) To manage the interrelationship between natural environmental biodiversity, human settlement and economic development; k) Generally, to contribute to human, social, cultural, spiritual and economic development; and l) To rehabilitate and restore degraded ecosystems and promote the recovery of endangered and vulnerable species”.

National Environmental The National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) Management: Waste Act, (NEM:WA) is subsidiary and supporting legislation to the NEMA. The Act is a 2008 (Act No. 59 of 2008) framework legislation that provides the basis for the regulation of waste management. The Act also contains policy elements and gives a mandate for further regulations to be promulgated.

National Environment The National Environment Management: Air Quality Act, 2004 (Act No. 39 of Management: Air Quality 2004) (NEM:AQA), which repeals the Atmospheric Pollution Prevention Act of Act, 2004 (Act No. 39 of 1965 (APPA), came into effect on 11 September 2005, with the promulgation of 2004) regulations in terms of certain sections resulting in the APPA being repealed entirely on 1 April 2010. Persons undertaking such activities are required to possess an Atmospheric Emissions License (AEL), essentially the equivalent of a Registration Certificate under the APPA.

In terms of Section 32 of the NEM:AQA The National Dust Control Regulations (GNR 827) were promulgated, which aim at prescribing general measures for the control of dust in both residential and non-residential areas.

National Environmental The National Environmental Management: Biodiversity Act (NEMBA), No. 10 of Management: 2004, aims to assist with the management and conservation of South Africa’s Biodiversity Act (No. 10 biological diversity through the use of legislated planning tools. These planning of 2004), and its tools include the declaration of bioregions and the associated bioregional plans subsequent as well as other mechanisms for managing and conserving biodiversity. amendments. The objectives of the Act include inter alia:

• The management and conservation of biological diversity within the Republic and of the components of such biological diversity; • The use of indigenous biological resources in a suitable manner; • The fair and equitable sharing of benefits arising from bio-prospecting of genetic material derived from indigenous biological resources; and • To give effect to ratified international agreements relating to biodiversity which are binding on the Republic. • To provide for co-operative governance in biodiversity management and conservation; and • To provide for a South African National Biodiversity Institute to assist in achieving the objectives of the Act.

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LEGISLATION/POLICY DESCRIPTION

In addition to this, Sections 50-62 of the Act provide details relating to the protection of threatened or protected ecosystems and species, while Sections 63-77 of the Act provide details relating to alien and invasive species with the purpose of preventing their introduction and spread, managing, controlling and eradicating of alien and invasive species.

NEMBA National List of The National List of Ecosystems is in place for the ecosystems that are threatened Ecosystems (GNR 1002 of and in need of protection. The NEMBA provides for listing of threatened or 9 December 2011) protected ecosystems in one of the following categories: • Critically endangered (CR) ecosystems, being ecosystems that have undergone severe degradation of ecological structure, function or composition as a result of human intervention and are subject to an extremely high risk of irreversible transformation; • Endangered (EN) ecosystems, being ecosystems that have undergone degradation of ecological structure, function or composition as a result of human intervention, although they are not critically endangered ecosystems; • Vulnerable (VU) ecosystems, being ecosystems that have a high risk of undergoing significant degradation of ecological structure, function or composition as a result of human intervention, although they are not critically endangered ecosystems or endangered ecosystems; • Protected ecosystems, being ecosystems that are of high conservation value or of high national or provincial importance, although they are not listed as critically endangered, endangered or vulnerable.

The vegetation cover of the proposed Mthatha WCSEZ area is classified as Mthatha Moist Grassland (Gs 14), which is a listed ecosystem classified as Vulnerable (VU) according to NEMBA (GNR 1002 of 9 December 2011).

NEMBA: Alien Invasive Invasive alien species are plants, animals and microbes that are introduced into Species Regulations countries, and then out-compete the indigenous species. Invasive alien species (2014) are cause billions of Rands of damage to South Africa’s economy on an annual basis and are a major threat to the country’s biological biodiversity.

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

• Category 1a Listed Invasive Species – species which must be combatted or eradicated. • Category 1b Listed Invasive Species – species which must be controlled. • Category 2 Listed Invasive Species – species which require a permit and must not be allowed to spread outside of the designated area. • Category 3 Listed Invasive Species – species which are subject to exemptions in terms of section requiring a permit, but where such a species occurs in riparian areas, must, for the purposes of these regulations, be considered to be a Category 1b Listed Invasive Species and must be managed according to regulation 3. • National Veld and Forest The National Veld and Forest Fire Act, No. 101 of 1998 (amended in 2001), aims Fire Act (No. 101 of to prevent and combat forest, veld and mountain fires throughout South Africa.

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LEGISLATION/POLICY DESCRIPTION 1998), and its This includes the regulation of the establishment, registration, functioning and subsequent duties of Fire Protection Associations (FPAs). FPAs manage all aspects of forest, amendments. veld and mountain fire prevention and firefighting.

Eastern Cape is managed by the Eastern Cape Umbrella Fire Protection Association (ECUFPA) which was established in terms of the National Veld and Forest Fire Act No.101 of 1998 as an Umbrella Association to facilitate FPA participation in the management of fire and related risks within the Eastern Cape.

Conservation of The Conservation of Agricultural Resources Act, No. 43 of 1983 aims to control Agricultural Resources over-utilisation of the natural agricultural resources to promote the conservation Act, (No. 43 of 1983). of soil, water sources and vegetation through the combat of weeds and invader plants. Regulations 15 and 16 under this Act, which relate to problem plants, were amended in March 2001.

This is achieved by: • Production potential of land is maintained, • Preventing and combating erosion, • Preventing and combating weakening or destruction of the water sources, and • Protecting vegetation and combating of weeds and invader plants.

National Water Act (No. The purpose of this Act (Section 2) is to ensure that the Nation’s water resources 36 of 1998) are protected, used, developed, conserved and controlled in ways that take into account, including: a) Promoting sustainable use of water b) Protection of aquatic and associated ecosystems and their biological diversity c) Reducing and preventing pollution and degradation of water resources

Protection of Water Resources (Sections 12-20) Provides details of measures intended to ensure the comprehensive protection of all water resources, including the water reserve and water quality.

With respect to the establishment of water quality objectives, objectives may relate to (Section 13): • the presence and concentration of particular substances in the water • the characteristics and quality of the water resource and the in-stream and riparian habitat • the characteristics and distribution of aquatic biota • the regulation and prohibition of in-stream and land-based activities which may affect the quantity and quality of the water resources

Section 19 deals with Pollution Prevention (Part 4) The person (including a municipality) who owns, controls occupies or uses the land in question, is responsible for taking reasonable measures to prevent pollution of water resources. If such measures are not taken, the catchment management agency concerned, may itself do whatever is necessary to prevent

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LEGISLATION/POLICY DESCRIPTION the pollution or remedy its effects and recover all reasonable costs from the persons responsible for the pollution.

The ‘reasonable measures’ which have to be taken may include measures to: • Cease, modify or control any act or process causing the pollution; • Comply with any prescribed waste standard or management practice; • Contain or prevent the movement of pollutants; • Eliminate any source of the pollution; • Remedy the effects of the pollution; and • Remedy the effect of any disturbance to the bed and banks of a watercourse.

With respect to pollution of rivers, the following definition is relevant when considering the potential impacts of development on water resources. Pollution may be deemed to occur when the following are affected: • the quality, pattern, timing, water level and assurance of instream flow; • the water quality, including the physical, chemical and biological characteristics of the water; • the character and condition of the in-stream and riparian habitat; • the characteristics, condition and distribution of the aquatic biota.

The Act defines ‘instream habitat’ as including the physical structure of a watercourse and the associated vegetation in relation to the bed of the watercourse.

Riparian Ecosystems ‘Riparian habitat’ includes the physical structure and associated vegetation of the areas associated with a watercourse which are commonly characterised by alluvial soils, and which are inundated or flooded to an extent and with a frequency sufficient to support vegetation of species and physical structure distinct from those of adjacent land areas.

Section 21 deals with the Use of Water Section 21 (a-k) describes activities defined as a water use under the Act. These activities may only be undertaken subject to the application for, and issue of, a water use licence.

National Heritage The protection of archaeological and paleontological resources is the Resources Act (No. 25 of responsibility of the Eastern Cape Provincial Heritage Resources Authority 1999) (ECPHRA) and all archaeological objects, paleontological material and meteorites are the property of the State.

The objective of the Act states that “Any person who discovers archaeological or paleontological objects or material or a meteorite in the course of development must immediately report the find to the responsible heritage resources authority, or to the nearest local authority offices or museum, which must immediately notify such heritage resources authority”.

The Act provides for the identification and protection of all heritage resources. “For the purposes of this Act, those heritage resources of South Africa which are

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LEGISLATION/POLICY DESCRIPTION of cultural significance or other special value for the present community and for future generations must be considered part of the national estate and fall within the sphere of operations of heritage resources authorities.”

Spatial Planning and The Spatial Planning and Land Use Management Act (SPLUMA) provides a Land Use Management framework for the inclusive, developmental, equitable and efficient spatial Act (No. 16 of 2013) planning at the different spheres of Government. It also allows for the promotion of greater consistency and uniformity in the application procedures and decision- making by authorities responsible for land use decisions and development applications.

2.2 RELEVANT POLICY AND PLANS

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

• Provincial Nature and Environmental Conservation Ordinance (No. 19 of 1974), which lists species of special concern which require permits for removal. Schedules 1 to 4 list protected and endangered plant and animal species. • Environmental Conservation Decree (No. 9 of 1992); • OR Tambo District Municipality and KSD Local Municipality By-Laws and plans.

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

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

2.3 RELEVANT DOCUMENTS

The following documents are to be read in conjunction with this CMP:

• WSP Environmental Impact Assessment Report (EIAR) and its appendices for the proposed WCSEZ (Mthatha) (October 2018, WSP Project No. 41100611); • The Desktop Aquatic and Terrestrial Ecological Scoping Report, the Terrestrial Ecological Impact Assessment Report, and the Wetland Habitat Impact Assessment Report written by Eco-Pulse Environmental Consulting Services (2018); • EMPr for the proposed WCSEZ (Mthatha); and • EA (14/12//16/3/3/2/1064) issued by the Department of Environmental Affairs (DEA) for the proposed WCSEZ (Mthatha).

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3 ROLES AND INSTITUTIONAL ARRANGEMENTS

As the CDC is the holder of the EA for Phase 1 of the Mthatha WCSEZ, the CDC will be responsible for ensuring that the conditions of the EA and EMPr are adhered to during the construction and operation of the Mthatha WCSEZ.

Once established, the WCSEZ will have its own internal management structure, governed by management systems, zone rules and regulations. This WCSEZ Authority will be responsible for overseeing the administration and functioning of the various business units/zones and the respective tenants.

Each tenant of the WCSEZ will, in turn, be responsible for abiding by the management systems, zone rules and regulations in place, including all applicable environmental authorisations, management systems and plans.

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4 CONSERVATION VALUE ASSESSMENT

This section provides a summary of the previous EIA and specialist assessments, as detailed in Section 2.3 above, relevant to the terrestrial ecological and aquatic environment within and surrounding Phase 1 of the Mthatha WCSEZ.

The aim of the baseline conservation review and assessment is to provide a reference point from which to guide the management actions and implementation framework of the CMP for the Mthatha WCSEZ.

4.1 BASELINE ASSESSMENT

4.1.1 BIODIVERSITY PLANS AND STRATEGIES

The key national, provincial and regional conservation planning information relevant to the Mthatha WCSEZ is summarised in Table 4-1 below.

Table 4-1: Key conservation context of the study area (taken directly from Eco-Pulse, 2018).

According to the Eastern Cape Biodiversity Conservation Plan (ECBCP), the catchment draining north towards the Mthatha Dam (refer to Figure 4-1) has been identified as an aquatic critical biodiversity area (CBA) at level 1 (A1). This area represents critically important river sub-catchments in a natural state that are considered critical for conserving biodiversity and maintaining ecosystem functioning (Hayes et al., 2007). Aquatic CBA 1 areas require high levels of protection and the recommended management objective for these areas are to “Maintain biodiversity in as natural state as possible, manage for no biodiversity loss” (Hayes et al., 2007).

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The catchment draining south has been identified as an aquatic CBA at level 2 (A2b, E3b), which are critically important river sub-catchments in a near-natural state that are considered important catchment management areas and zones for conserving biodiversity and maintaining ecosystem functioning in order to support important downstream rivers and estuaries (Hayes et al., 2007).

Figure 4-1: ECBCP Aquatic CBA map of the study area (Eco-Pulse, 2018).

The proposed Mthatha WCSEZ also falls within a Terrestrial CBA level 1 and 2 (T2) area (Figure 4-2) which captures sections of near-natural landscape and the (potential) presence of Endangered vegetation types (Mthatha Moist Grassland) identified through the systematic conservation assessment. The central portion of the northern project area has been mapped as a CBA at level 1 and has further been identified as a potentially important ecological corridor for the movement of biota.

The applicable land-use guidelines for Terrestrial CBA 2 area (in the form of Biodiversity Land Management Classes (BLMCs)) are to “maintained in a near-natural state with minimal loss of ecosystem integrity and no transformation of natural habitat should be permitted”, and “Maintain biodiversity in as natural state as possible, manage for no biodiversity loss” for the CBA 1 area.

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Figure 4-2: ECBCP Terrestrial CBA map of the study area (Eco-Pulse, 2018).

4.1.2 VEGETATION AND HABITAT ASSESSMENT

According to the National Vegetation Map (Mucina and Rutherford, 2012 and 2018), the Mthatha WCSEZ is located within the Eastern Valley Bushveld (Least Threatened) and Mthatha Moist Grassland (Endangered). The Mthatha Moist Grassland is classified as Vulnerable (VU) according to NEMBA listed ecosystems (GNR 1002 of 9 December 2011).

The site assessment conducted by Eco-Pulse in March 2018 found the following:

• Slightly Modified Primary Mthatha Moist Grassland: found exclusively on the northern property and accounting for roughly 141 hectares (ha) of the property; and • Degraded Secondary Grassland: found exclusively on the southern property and accounting for roughly 45 hectares (ha) of the property. • The wetlands fall on the boundary between the Sub-Escarpment Grassland Group 7 and Sub Escarpment Savanna vegetation groups (as defined by NFEPA (SANBI & DWS, 2014)). At the wetland vegetation group (WVG) level, the Sub-escarpment Savanna wetland vegetation group has an ecosystem threat status of Endangered and the Sub-Escarpment Grassland Group 7 wetland vegetation type is Critically Endangered.

The vegetation within the southern portion of the site (south of Mthatha Airport) has been subject to years of historic and recent cultivation and settlement on portions of the site and it therefore covered by secondary grasslands. Following cessation of cultivation, relocation of locals and fencing of the

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property, a mixed secondary grassland community has become established through a natural successional process. Given abovementioned impacts and present vegetation status (structurally and compositionally), the Degraded Secondary Grassland has been assigned a condition class of seriously modified and is unlikely to resemble the natural reference vegetation type (Mthatha Moist Grassland, Endangered threat status).

Within the northern portion of the site (north of the Mthatha airport), it is evident that fencing the Mthatha Airport Precinct has allowed the grassland to recover from historic anthropogenic impacts such as overgrazing and poor veld management. Considering that weed and Invasive Alien Plant (IAP) infestation levels was typically low, and the structural integrity of the grassland was intact, it was concluded that the grassland is slightly modified but not entirely representative of reference state.

Figure 4-3: Terrestrial vegetation communities found within the Mthatha WCSEZ (Eco-Pulse, 2018).

4.1.3 WETLAND HABITAT ASSESSMENT

The baseline wetland assessment identified seven (7) wetland units, including six (6) wetland ‘seeps’ and one (1) artificial wetland that are likely to be affected by the Mthatha WCSEZ, as detailed below and illustrated in Figure 4-4. No rivers were identified as being at risk of impact from the Mthatha WCSEZ. Table 4-2 below summarises the findings of the Present Ecological States (PES) and the Ecological Importance and Sensitivity (EIS) of the wetlands identified on site. The recommended resource management objective (RMO) (based on a combined PES and EIS rating) should be to maintain the current status quo of aquatic ecosystems without any further loss of integrity/functioning (PES/EIS).

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Table 4-2: Summary of baseline wetland assessment UNIT AND TYPE PES EIS RMO W1: Seep D: Largely Modified Moderate Maintain PES/EIS W2: Seep C: Moderately Modified Moderate Maintain PES/EIS W3: Seep D: Largely Modified Moderate Maintain PES/EIS W4: Seep D: Largely Modified Moderate Maintain PES/EIS W5: Seep C: Moderately Modified Moderate Maintain PES/EIS W6: ‘Artificial’ Wetland N/A: Artificial Very Low N/A W7: Seep D: Largely Modified Low Maintain PES/EIS

The wetlands drain in a northly direction towards the Mthatha Dam and are located within quaternary catchment T20B, characterised by moderate precipitation and high evapotranspiration rates.

The site assessment conducted by Eco-Pulse (2018) confirmed that the wetlands are largely seasonal valley bottom wetlands and seepage wetlands fed primarily by a combination of surface/storm water runoff from existing airport infrastructure and sub-surface interflow following rainfall entering the ground surface. Seepage-type wetland systems contribute to the recharge of groundwater systems and the nature of the wetlands influences the nature of the groundwater in the area.

With the alteration of the land surface and construction of the Mthatha airport and airstrip, wetland hydrology has been largely altered, with increased water inputs as a result of enhanced surface water runoff from the airstrip, and concentrated storm water flows through artificial drains that discharge into the wetlands.

As a result, the wetlands are likely to have increased in size with the increased level of wetness, with the dominant vegetation types changing from short rushes and hydric grass species (under the natural reference state) to denser sedges and bulrushes that now dominate these systems.

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Figure 4-4: Wetland Map (Eco-Pulse 2018)

4.1.4 SPECIES OF CONSERVATION CONCERN

FLORA:

A desktop review of SANBI’s online threatened species database for the quarter degree grid square 3128DA, showed that two (2) species, namely Brachystelma caffrum (classified as Vulnerable) and Crinum macowanii (classified as Declining), were identified as potentially occur within the remaining untransformed grassland habitat within the study area.

The site assessment undertaken by Eco-Pulse in March 2018 noted protected plant species within the Mthatha WCSEZ. Two individuals of the species Gladiolus ecklonii were identified within the southern property of the WCESZ. It was recommended that a protected plant rescue and translocation plan be compiled and implemented and the relevant permit applications for the translocation of protected plants be submitted.

FAUNA:

Based on the findings of the faunal (wildlife) desktop assessment and subsequent site visit, it was concluded that the probability of the study site being important for hosting Red Data listed/threatened populations/individuals was considered to be relatively low, and that the proposed development is expected to have a low impact on faunal species of conservation concern.

In summary, the findings indicated the following:

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• The lack of species-specific habitat for most of the mammals, reptiles and amphibians greatly reduces the likelihood of their occurrence at the site. • The likelihood of occurrence of many of these species is further reduced by their proximity to human activities. Larger mammal species have either been eradicated or have moved away from the area due to high levels of human and domesticated livestock disturbance associated with human occupation in the area as well as increased grazing pressure. • Small mammal species are also extremely vulnerable to human impacts, poaching as well as dogs and feral cats. It is therefore quite unlikely that the development site itself constitutes significant habitat for any species of threatened mammal species as well as for mammal species in general. • Various endemic species of reptiles could potentially utilise the site but are unlikely to persist in great numbers. All reptile species are sensitive to major habitat alteration and fragmentation. As a result of human presence in the area coupled with livestock grazing disturbances, alterations to the original reptilian fauna are expected to have already occurred. • Amphibian species of conservation concern are unlikely to be present at the site or within the surrounding wetland/aquatic habitats due to the lack of suitable habitat provided for key species. • Grassland habitat lost is unlikely to support populations of nesting/breeding bird species of conservation importance. A pair of Grey-Crowned Crane (VU) was observed by the ecologists from Eco-Pulse in 2012 within the moist grassland adjacent to the wetlands on the site in the northern section of the project area, which probably exploits the site as the area is fenced and less vulnerable to predators. Stanley’s Bustard (VU) is also known to occur within the grasslands of the adjacent Luchaba Nature Reserve to the north. There is therefore a reasonably high probability that these birds may be present on the development site

4.1.5 LAND USE

The northern portion of the site (north of the Mthatha airport) falls within the Mthatha Airport Precinct, which has allowed the grassland to recover from historic anthropogenic impacts such as overgrazing and poor veld management. 4.1.6 SUMMARY OF EXISTING PRESSURES AND THREATS

The tables below provide a summary of the known pressures and threats to the ecological and aquatic environmental within the Mthatha WCSEZ and its immediate surrounds.

Table 4-3: Summary of existing impacts to the wetland units (Eco-Pulse, 2018). WETLAND UNIT PRESSURES AND THREATS • Historic habitat transformation (dam, road and runway infrastructure). • Discharge of concentrated storm water and sediment into the wetland. W1 • Intensive overgrazing of the wetland habitat outside the Airport precinct. • Limited excavation and infilling. • Historic habitat transformation (dam, road and runway infrastructure). • Discharge of concentrated storm water and sediment into the wetland. W2 • Intensive overgrazing of the wetland habitat outside the Airport precinct. • Limited excavation and infilling. • Historic habitat transformation linked with the old runway. W3 • Intensive overgrazing of the wetland habitat outside the Airport precinct. • Historic habitat transformation. W4 • Discharge of concentrated storm water and sediment into the wetland.

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• Intensive overgrazing of the wetland habitat outside the Airport precinct. • Limited excavation and infilling. • Limited flow impoundment resulting in pooling of water. • Limited erosion below storm water headwalls. • Historic habitat transformation. • Limited excavation and infilling. W5 • Limited flow impoundment resulting in pooling of water. • High levels of weed infestation. • Artificially created. W6 • High levels of weed infestation. • Historic habitat transformation. W7 • Limited excavation and infilling. • High levels of weed infestation.

Table 4-4: Summary of existing impacts to the terrestrial ecological environment SITE PRESSURES AND THREATS Southern portion of site (45 • Habitat transformation to establish greenhouse infrastructure, small- ha) scale potato and maize cultivation • Leaking water pipeline which has created an artificial wetland habitat • Historic habitation transformation – remains of concrete slabs and hardened surfaces which has had a restrictive effect on natural vegetation establishment. Northern portion of site (141 • Historic transformation from cultivation and overgrazing ha) • Historic habitat transformation linked to the Mthatha airport and old runway. Surrounding grasslands • Overgrazing • Frequently burned • High occurrence of unpalatable grasses, • Low herbaceous plant diversity • Historically cultivated

DEVELOPMENTAL IMPACTS:

The Mthatha WCSEZ EIR (WSP, 2018) detailed the following potential developmental and operational impacts of the proposed Mthatha WCSEZ relevant to the designated Open Space: Grasslands and Wetland area.

1. The Terrestrial Ecological Assessment (Eco-Pulse, 2018) found that the most significant ecological impact likely to be associated with the proposed development pertains to the potential permanent transformation and loss of a substantial amount of primary Mthatha Moist Grassland vegetation and habitat (~141 ha).

2. The Wetland Habitat Assessment (Eco-Pulse, 2018) concluded that the most significant aquatic impacts are likely to be the potential permanent transformation and loss of a substantial amount of wetland habitat (~56 ha), the risk of increased sediment inputs during construction, the establishment of invasive alien plants in disturbed areas during the construction and operation phases of the development, the risk of modifying natural/pre- development flow characteristics with the development of hardened surfaces in the wetland catchment area, and the risk of water quality degradation during construction and operation.

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4.2 SITE ASSESSMENT

A site visit and assessment were conducted on 19 June 2019 in order to verify the findings of the baseline assessment. The assessment only concerned the proposed Open Space: Grassland and Wetland areas within northern portion of the site.

The figures below provide a photo sequence taken of the Open Space: Grasslands and Wetlands within the northern portion of the site. It should be noted that the site visit was conducted in winter, therefore, seasonal variance of floral species could not have been assessed. However, the Eco-Pulse Terrestrial and Wetland impact Assessments provided a detailed account of the site investigations undertaken during September 2017 and March 2018, respectively.

W1 W2

Figure 4-5: Photo sequence

Figure 4-6: Photo 1: View of the wetland system within the north western portion of the study site (looking south east).

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Figure 4-7: Photo 2: Wetland within the north western corner of the study site.

Figure 4-8: Photo 3: Eroded gabion within the wetland system, and bare soil requiring revegetation.

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Figure 4-9: Photo 4: Drive over stormwater outlet leading from the wetland system (above). Material placed near the road side has slowed the flow of the wetland and has resulted in more surface water pooling within the wetland system.

Figure 4-10: Photo 5: View of the wetland system looking west.

Figure 4-11: Photo 6: Erosion around the culvert structure.

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Figure 4-12: Photo 7: View of the wetland system looking west.

Figure 4-13: Photo 8: Erosion of stormwater channel constructed for the airstrip.

Figure 4-14: Photo 9: Mthatha Moist Grassland vegetation.

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Figure 4-15: Alien Invasive Plant (IAP) specie noted on site, Scottish Thistle (Onopordum acanthium).

A detailed plant species list was included as Appendix B in the EcoPulse (2018) Wetland Habitat Impact Assessment Report for further reference.

4.3 CONCLUSION

The site visit confirmed the findings of the previous wetland assessment undertaken by EcoPulse (2018). Wetland 1 (WC1) has been largely modified from stormwater channels draining into the wetland system. In addition, stormwater attenuation measures for the airport have also allowed for surface water to pool, creating an artificially ‘wetter’ system. It is evident that the previous construction and upgrade of the Mthatha airport within the wetland catchment system has changed the flow characteristics to create a more channelled system with permanent open water present. The previous construction and maintenance of the existing service road which runs along the inside perimeter of the airport precinct has also created an artificial barrier which prevents flow and inundates Wetland 1 (Figure 4-9).

Pooling of surface water and channelling was less evident in Wetland 2 (WC2), however the culvert at the northern boundary of the airport precinct was heavily eroded and blocked (Figure 4-11Figure 4-9). This causes impounding of flows, inundating the wetland/riparian habitat which thus alters the natural saturation regime of the wetland system.

The Mthatha Moist Grassland was somewhat intact, with a few IAP species noted on site. No protected species were encountered.

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5 MANAGEMENT FRAMEWORK

The section below provides the overall conservation management framework of the CMP.

5.1 CONSERVATION OUTCOMES

The following conservation outcomes (CO) have been developed in order to achieve the long-term conservation and maintenance of the Open Space: Grassland and Wetlands areas within the Mthatha WCSEZ:

The Open Space: Grassland area within the Mthatha WCSEZ is conserved and further degradation is CO 1 prevented. CO 2: The Open Space: Wetland areas are rehabilitated and conserved. Land use activities within the adjacent areas must not impact on or contribute to the further CO 3: degradation of the Open Space: Grassland and Wetlands areas. The Open Space: Grassland and Wetlands areas are regularly monitored and evaluated against the CO 4 baseline.

For each CO, management actions have been developed that must be implemented to ensure that the COs for the Mthatha WCSEZ are achieved.

5.2 MANGEMENT ACTIONS

In addition to the conditions contained in all documents detailed in Section 2.3 above, the Conceptual Wetland Rehabilitation Plan (Appendix A), developed by EcoPulse (2018), should be read in conjunction with this CMP. Table 5-1 to below details the management actions associated with each conservation outcome, the responsible party/ies and the required frequency of implementation/monitoring for each management action. Cost-estimates for the role out of this CMP are provided in Section 5.2 below.

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5.2.1 CO 1: The Open Space: Grassland area within the Mthatha WCSEZ is conserved and further degradation is prevented

Table 5-1: Management plan for Open Space: Grassland area OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING Planning and Construction Operation Design CO1: The 1: LEGAL COMPLIANCE Open Space: • Ensure legislative compliance with: CDC Mthatha WCSEZ • Bi-monthly • Weekly • Monthly Grassland o Environmental Impact Assessment Report (EIAR) Authority; area within and its appendices (including all specialist reports Individual tenants; the for the proposed WCSEZ (Mthatha) (WSP Project Environmental Site Mthatha WCSEZ is No. 41100611); Officer (ESO) and conserved o EMPr for the proposed WCSEZ (Mthatha); Environmental Control and further o EA (14/12//16/3/3/2/1064) issued by the Officer (ECO) degradation Department of Environmental Affairs (DEA) for is the proposed WCSEZ (Mthatha). prevented. 2: INVASIVE ALIEN PLANT (IAPs) CONTROL

• IAPs are to be mechanically controlled as per the CDC Mthatha WCSEZ • Preplanning: • Immediately • Monthly requirements of the National Environmental Authority; requirements and monitoring of Management: Biodiversity Act (NEM:BA) guidelines for Environmental Site pertaining to throughout the success of alien species management and control, as well as per Officer (ESO) equipment construction IAP control the Alien Vegetation Management Plan included in the and labour and re- EMPr, and the EcoPulse Wetland Rehabilitation Plan must be establishment (attached as Appendix A) which details mechanical secured and of IAPs. control methods for alien plants. in place for construction and operation phases.

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OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING Planning and Construction Operation Design • Chemical control of IAPs is not recommended in • Monthly aquatic systems due to the risk of water pollution but monitoring of may be used in conjunction with cutting or slashing of the plants. Only herbicides approved for use in recommended wetland/riparian areas are to be used. Confirmation of IAP control approved herbicides to be used in these areas must be methods obtained from the relevant authority prior to use. being • Disturbance of the Open Space: Grassland area must implemented be avoided to minimize the spread of IAPs. by labourers. • Clearance of IAPs should be done immediately after the fencing of the larger wetland area has been completed, and thereafter monthly monitoring and clearing must be undertaken. • Concurrent rehabilitation and IAP control program within all Open Space Grassland and Wetlands must be implemented, where possible. 3: REVEGETATION • The Open Space: Grassland area was largely intact and CDC Mthatha WCSEZ • n/a • Immediately • Monthly recovering from historic anthropogenic impacts, Authority; where monitoring however, should re-vegetation be required during Environmental Site required construction and operation, the recommendations Officer (ESO) during made for “Method 1: Planting of plugs / sprigs (for construction disturbed grassland areas)” within the EcoPulse (2018) Terrestrial Impact Assessment Report should be followed. This can be done by transplanting 12 plugs/m2 of established Imperata cylindrical, Aristida junciformis or Themeda triandra (Red grass).

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OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING Planning and Construction Operation Design • All exposed earth and cleared areas must be rehabilitated with indigenous vegetation and top soil sourced from the local area. • Rehabilitation work must be done in low rainfall season and the use of heavy machinery is prohibited to avoid soil compaction.

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5.2.2 CO 2: The Open Space: Wetland areas are rehabilitated and conserved

Table 5-2 below details management actions for CO 2: Wetland rehabilitation and conservation. The Conceptual Wetland Rehabilitation Plan (Appendix A) developed by EcoPulse (2018) is used as a guideline and should be read in conjunction with the following management actions. Wetland 1 and 2 make up 35 hectares of the northern portion of the Mthatha WCSEZ. Each wetland catchment must be considered in its entirety as they are not isolated systems.

The recommended management objective for Aquatic CBA 1 areas are to “Maintain biodiversity in as natural state as possible, manage for no biodiversity loss” (Hayes et al., 2007). With regards to Wetland 1 and 2, the recommended management objective is to maintain the current status quo of aquatic ecosystems without any further loss of integrity (PES) or functioning.

Table 5-2: Management plan for wetland rehabilitation and maintenance. OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING PLANNING AND DESIGN CONSTRUCTION OPERATION CO 2: The 1: LEGAL COMPLIANCE Open Space: • Ensure legislative compliance with: CDC Mthatha • Water Use Licensing • Weekly • Monthly Wetland o Environmental Impact Assessment Report WCSEZ Authority; must be obtained areas are (EIAR) and its appendices (including all Individual tenants; rehabilitated specialist reports for the proposed WCSEZ Environmental and (Mthatha) (WSP Project No. 41100611); Site Officer (ESO) conserved. o EMPr for the proposed WCSEZ (Mthatha); and o EA (14/12//16/3/3/2/1064) issued by the Environmental Department of Environmental Affairs (DEA) Control Officer for the proposed WCSEZ (Mthatha). (ECO) • Water Use Licensing (WUL) must be obtained prior to the commencement of rehabilitation activities within the wetland areas. 2: STORMWATER MANAGEMENT

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OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING PLANNING AND DESIGN CONSTRUCTION OPERATION • 15-meter buffer zone must be implemented CDC Mthatha • Stormwater • Re-vegetation • Monthly around Wetland 1 and 2 to promote percolation WCSEZ Authority; management plan to of buffer zones monitoring and reduce surface water and sediment runoff; Individual tenants; be finalised and to commence of • All wetland and wetland buffer zones must be Environmental provisions made immediately stormwater demarcated and clearly marked as no-go areas to Site Officer (ESO) accordingly; • Weekly management limit disturbance. and • Planning for re- monitoring of plan • A stormwater management plan must be Environmental vegetation of buffer stormwater • Immediately developed by a qualified engineer which Control Officer areas – equipment, management after heavy incorporates source directed control measures to (ECO) resources, and labour plan rainfall minimise additional discharge into the wetland events catchment areas and must incorporate the stormwater management recommendations made by the EcoPulse Wetland Specialist (Table 17 in the Wetland Habitat Impact Assessment Report). • All stormwater management infrastructure must be located outside of the wetland areas and buffer zones. • A detailed method statement must be compiled which addresses existing erosion features immediately upslope and/or within the wetland habitat, and those that may be created during the construction or operation phase. Stabilisation measures must be proposed based on slope and soil type and could include gabion structures (e.g. retaining/diversion walls), concrete structures (e.g. weirs), earthen structures (e.g. berms or sloping); as well as re-vegetation.

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OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING PLANNING AND DESIGN CONSTRUCTION OPERATION • The stormwater infrastructure must be monitored for effectiveness in ensuring appropriate collection and discharge which does not significantly reduce nor enhance wetland flow regimes. • Operational monitoring of storm water and wastewater management infrastructure is to occur as per best-practice and in line with the engineer specifications. 3: INVASIVE ALIEN PLANT (IAPs) CONTROL • IAPs are to be mechanically controlled as per the CDC Mthatha • Planning required: • Immediately • Monthly requirements of the National Environmental WCSEZ Authority; equipment, resources Management: Biodiversity Act (NEM:BA) Environmental and labour to be guidelines for alien species management and Site Officer (ESO); secured. control, as well as per the Alien Vegetation Environmental Management Plan included in the EMPr, and the Control Officer EcoPulse Wetland Rehabilitation Plan (attached as (ECO) Appendix A) which details mechanical control methods for alien plants. • No form of chemical control (use of herbicides) should be permitted due to the close proximity of aquatic systems. • Disturbance to the Open Space: Wetland areas must be avoided to minimize the spread of IAPs. • Clearance of IAPs should be done immediately after the fencing of the larger wetland area has been completed, and thereafter monthly monitoring and clearing must be undertaken.

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OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING PLANNING AND DESIGN CONSTRUCTION OPERATION 4: REVEGETATION

• Eroded/bare areas within the Open Space: CDC Mthatha • Planning required: • Re-vegetation • Immediately Wetland zones are to be stabilised and WCSEZ Authority; equipment and of target areas as and when revegetated. All exposed earth and cleared areas Environmental labour to be secured. to commence required. must be rehabilitated with indigenous vegetation Site Officer (ESO); immediately and top soil sourced from the local area. Environmental • Weekly • Rehabilitation work must be done in low rainfall Control Officer monitoring for season and the use of heavy machinery is (ECO) first 8 weeks prohibited to avoid soil compaction. after planting. • The measures provided in Step 5 of the EcoPulse Conceptual Wetland Rehabilitation Plan (2018) detailing guidelines for site preparation, species to be used and planting methods are to be implemented. Established Phragmites australis, Typha capensis, Juncus spp. and various smaller sedges (Cyperus spp.) can be transplanted at 6 to 8 plugs/m2. • Eroded/bare areas within the 15-meter buffer areas must be re-vegetated as per the recommendations made for Method 1: Planting of plugs / sprigs for disturbed grassland areas within the EcoPulse (2018) Terrestrial Impact Assessment Report. This can be done by transplanting 12 plugs/m2 of established Imperata cylindrical, Aristida junciformis or Themeda triandra (Red grass).

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OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING PLANNING AND DESIGN CONSTRUCTION OPERATION • Regular visual inspections must be done weekly for first 8 weeks after planting to determine whether revegetation has been successful or whether further intervention is required.

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5.2.3 CO 3: Land use activities within the adjacent areas must not contribute to the further degradation of the Open Space: Grassland and Wetlands areas

Table 5-3: Management plan for surrounding land use activities OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING Planning and Design Construction Operation CO 3: Land 1: LEGAL COMPLIANCE use activities • Ensure legislative compliance with: CDC Mthatha WCSEZ • Relevant • Weekly • Monthly within the o Environmental Impact Assessment Report Authority; permits/licensing adjacent (EIAR) and its appendices (including all Individual tenants; obtained areas must specialist reports for the proposed WCSEZ Environmental Site not impact on or (Mthatha) (WSP Project No. 41100611); Officer (ESO) and contribute o EMPr for the proposed WCSEZ (Mthatha); Environmental to the o EA (14/12//16/3/3/2/1064) issued by the Control Officer (ECO) further Department of Environmental Affairs (DEA) degradation for the proposed WCSEZ (Mthatha). of the Open Space: 2: AGRICULTURE Grassland • No agricultural activities should be undertaken CDC Mthatha WCSEZ • n/a • n/a • Monthly and Wetlands within the 15-meter wetland buffer zones (no-go Authority; monitoring areas. area). Environmental Site of Zone 5 • Should organic and/or inorganic fertilisers be Officer (ESO) and tenant used within Zone 5, quarterly water quality Individual tenants. compliance sampling must be undertaken to monitor for the with possible impact this may have on water quality conditions. and wetland habitat integrity. • Quarterly wetland water quality sampling and monitoring.

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OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING Planning and Design Construction Operation • Should the water quality results indicate • Monthly contamination/eutrophication, a wetland monitoring specialist should be consulted regarding the of no-go continued use of fertilisers and possible mitigation areas being measures. adhered to by all staff and tenants. 3: POINT SOURCE CONTROLS

• A stormwater management plan must be CDC Mthatha WCSEZ • Stormwater • Immediately on • Quarterly developed as per conditions in Table 5-2 above. Authority; management commencement storm water • Simple surface water quality sampling and analysis Environmental Site plan to be of construction. and wetland and basic wetland habitat integrity (water quality) Officer (ESO) finalised. • Weekly water quality monitoring should be used to indicate any changes • Preplanning monitoring of sampling and to wetland condition and inform responsive required for implementation monitoring. management actions. monitoring – of stormwater equipment and management labour. plan during construction. 4: WASTE MANAGEMENT

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OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING Planning and Design Construction Operation • Waste must be managed as per the Waste CDC Mthatha WCSEZ • • Weekly • Monthly Management Plan included in the EMPr, as well as Authority/designated monitoring monitoring per future management plans authorized as part waste control officer; according to of tenant of the environmental authorisation processes for Environmental Site Waste compliance individual tenants. Officer (ESO); Management with Individual tenants Plan approved waste management plan/s. 5: ACCESS CONTROL • The Open Space areas and 15-meter wetland CDC Mthatha WCSEZ • Planning • Fencing to be • Daily buffer zones must be fenced off to prevent Authority; required: fenced, erected monitoring unauthorized activities within these areas. The Environmental Site equipment and immediately on of access style of fencing chosen should allow for free Officer (ESO); labour commencement control. movement of fauna. of construction. • Annual • The Open Space areas and buffer zones should be • Daily monitoring considered as no-go areas. monitoring for of fence • Access within these areas, apart from the access control. condition. construction of the fence, should only be permitted for IAP clearing, monitoring and rehabilitation purposes. • No vehicles should be permitted within the wetland areas.

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5.2.4 CO 4: The Open Space: Grassland and Wetlands areas are regularly monitored and evaluated against the baseline.

Table 5-4: Monitoring plan

OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING Planning and Design Construction Operation CO 4: The 1: MAINTENANCE AND MONITORING Open Space: • Step 6 of the EcoPulse Conceptual Wetland CDC Mthatha WCSEZ • n/a • Immediately • Immediately Grassland Rehabilitation Plan (2018) must be used as a Authority; after after and guideline for the maintenance, monitoring and Individual tenants; rehabilitation rehabilitation Wetlands evaluation of rehabilitation and revegetation Environmental Site and and areas are regularly efforts conducted. Officer (ESO) and revegetation, revegetation, monitored • Recovery of disturbed areas should be assessed Environmental and monthly and monthly and for the first 6 months to assess the success of Control Officer (ECO) thereafter. thereafter evaluated rehabilitation actions. Any areas that are not for the first 6 against the progressing satisfactorily must be identified (e.g. months, baseline state. on a map) and action must be taken to actively re- thereafter vegetate these areas. If natural recovery is biannual progressing well, no further intervention may be monitoring required. of selected • IAP monitoring and control must be done on a indicators is monthly basis. required. • Access restrictions and controls must be enforced at all times for designated ‘No-Go’ areas.

2: REVIEW OF CMP

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OBJECTIVE MANAGEMENT ACTIONS RESPONSIBILITY FREQUENCY OF IMPLEMENTATION/MONITORING Planning and Design Construction Operation • The CMP should be reviewed every five years by a CDC Mthatha WCSEZ • n/a • n/a • Every 5 years suitably qualified environmental specialist. This Authority; will provide an opportunity to re-assess and revise Environmental Site the management objectives and determine Officer (ESO) whether they are still relevant and are effective in achieving the vision.

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5.3 COSTING PLAN

The costing plan below provides cost estimates related to each management action. The costing plan does not account for personnel salaries, however, an indication on the number of personnel estimated to be required has been indicated.

Table 5-5: Costing Estimate CONSERVATION MANAGEMENT ACTIONS PLANNING AND DESIGN CONSTRUCTION OPERATION OUTCOME PHASE CO 1 1: LEGAL COMPLIANCE • n/a • Personnel salary: 1 Designated Environmental Site Officer (ESO).

2: INVASIVE ALIEN PLANT (IAPs) • R50 000 for equipment, • Personnel salaries: 3 labourers. CONTROL herbicides and PPE. 3: REVEGETATION • n/a C0 2 1: LEGAL COMPLIANCE • R40 000 to obtain WUL. • Personnel salary: 1 Designated ESO as included above.

2: STORMWATER • R50 000 for drafting of • Bill of quantities for • Personnel salary: 1 MANAGEMENT stormwater rehabilitation to be Designated ESO as management plan. confirmed by Engineer; included above. estimated at R500 000 depending on earthworks and whether rehabilitation work can be integrated into the scope of work of the construction contractor.

3: INVASIVE ALIEN PLANT (IAPs) • As per CO1 above. CONTROL

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CONSERVATION MANAGEMENT ACTIONS PLANNING AND DESIGN CONSTRUCTION OPERATION OUTCOME PHASE 4: REVEGETATION • n/a • R 50 000 for the • Personnel salaries as appointment of wetland per CO1 above. specialist; and • Personnel salaries as per CO1 above C0 3 1: LEGAL COMPLIANCE • n/a • Personnel salary: 1 Designated ESO. 2: AGRICULTURE • n/a • n/a • R60 000 per annum 3. POINT SOURCE CONTROLS • n/a • As per Engineer’s bill of for water quality quantities. sampling and monitoring. 4. WASTE MANAGEMENT • n/a • Personnel salary: 1 Designated Environmental Site Officer (ESO). 5: ACCESS CONTROL • n/a • R 500 000 to R 2 million • Personnel salaries: 1 for fencing, dependent guard/security on the type of fencing officer. used; and • Personnel salary: 1 Designated ESO. CO 4 1: MAINTENANCE AND • n/a • Personnel salaries: 1 Designated ESO and 3 labourers; MONITORING and • As per Engineer’s bill of quantities for maintenance of stormwater management infrastructure and/or erosion control measures. 2: REVIEW OF CMP • n/a • n/a • R50 000 every 5 years.

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6 CONCLUSION

The CMP must be available on site at all times during construction and operation. This plan should form part of future environmental management systems put in place for the Mthatha WCSEZ.

The CMP should be reviewed every five years by a suitably qualified environmental specialist. This will provide an opportunity to re-assess and revise the management objectives and determine whether they are still relevant and are effective in achieving the vision.

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7 REFERENCES

Eco-Pulse Consulting, 2018. Proposed Wild Coast SEZ, Eastern Cape. Terrestrial Ecological Assessment Report. Unpublished report prepared by Eco-Pulse Environmental Consulting Services for WSP. Report No. EP341-03. 12th July 2018

Eco-Pulse Consulting, 2018. Wetland Habitat Impact Assessment Report for the proposed Wild Coast Special Economic Zone (SEZ). Unpublished report prepared by Eco-Pulse Environmental Consulting Services for WSP. Report No. EP341-02. 10th July 2018.

WETRehabEvaluate: Guidelines for the monitoring and evaluation of wetland rehabilitation projects (Cowden and Kotze, 2008).

WET-RehabPlan: Guidelines for planning wetland rehabilitation in South Africa (Kotze et al., 2009).

WSP, 2018. Wild Coast Special Economic Zone: Final Environmental Impact Assessment Report. October 2018.

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