Final Basic Assessment Report

FINAL BASIC ASSESSMENT REPORT

BASIC ASSESSMENT REPORT

BASIC ASSESSMENT REPORT IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998) AND ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS, 2014 (AS AMENDED)

October 2017

PROJECT TITLE

PROPOSED EXPANSION OF THE INDUSTRIAL AREA IN BREDASDORP, CAPE AGULHAS MUNICIPALITY, WESTERN CAPE

[09 July 2019]

REPORT TYPE CATEGORY REPORT REFERENCE NUMBER DATE OF REPORT Pre-Application Basic Assessment Report (if applicable)1 Draft Basic Assessment Report2 16/3/3/1/1E/5/1022/19 26 April 2019 Final Basic Assessment Report3 or, if applicable Revised Basic Assessment Report4 (strikethrough what is not applicable)

Notes:

1. In terms of Regulation 40(3) potential or registered interested and affected parties, including the Competent Authority, may be provided with an opportunity to comment on the Basic Assessment Report prior to submission of the application but must again be provided an opportunity to comment on such reports once an application has been submitted to the Competent Authority. The Basic Assessment Report released for comment prior to submission of the application is referred to as the “Pre-Application Basic Assessment Report”. The Basic Assessment Report made available for comment after submission of the application is referred to as the “Draft Basic Assessment Report”. The Basic Assessment Report together with all the comments received on the report which is submitted to the Competent Authority for decision-making is referred to as the “Final Basic Assessment Report”.

2. In terms of Regulation 19(1)(b) if significant changes have been made or significant new information has been added to the Draft Basic Assessment Report , which changes or information was not contained in the Draft Basic Assessment Report consulted on during the initial public participation process, then a Final Basic Assessment Report will not be submitted, but rather a “Revised Basic Assessment Report”, which must be subjected to another public participation process of at least 30 days, must be submitted to the Competent Authority together with all the comments received.

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DEPARTMENTAL REFERENCE NUMBER(S)

Pre-application reference number: File reference number (EIA): 16/3/3/1/1E/5/1022/19 NEAS reference number (EIA): DEA&DP/ EIA

File reference number (Waste): NEAS reference number (Waste):

File reference number (Air Quality): NEAS reference number (Air Quality):

File reference number (Other): NEAS reference number (Other):

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CONTENT AND GENERAL REQUIREMENTS

Note that: 1. The content of the Department’s Circular EADP 0028/2014 (dated 9 December 2014) on the “One Environmental Management System” and the Environmental Impact Assessment (“EIA”) Regulations, 2014 (as amended), any subsequent Circulars, and guidelines must be taken into account when completing this Basic Assessment Report Form. 2. This Basic Assessment Report is the standard report format which, in terms of Regulation 16(3) of the EIA Regulations, 2014 (as amended) must be used in all instances when preparing a Basic Assessment Report for Basic Assessment applications for an environmental authorisation in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (“NEMA”)and the EIA Regulations, 2014 (as amended) and/or a waste management licence in terms of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (“NEM:WA”), and/or an atmospheric emission licence in terms of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) (“NEM:AQA”) when the Western Cape Government: Environmental Affairs and Development Planning (“DEA&DP”) is the Competent Authority/Licensing Authority. 3. This report form is current as of October 2017. It is the responsibility of the Applicant/ Environmental Assessment Practitioner (“EAP”) to ascertain whether subsequent versions of the report form have been released by the Department. Visit the Department’s website at http://www.westerncape.gov.za/eadp to check for the latest version of this checklist. 4. The required information must be typed within the spaces provided in the form. The size of the spaces provided is not necessarily indicative of the amount of information to be provided. The tables may be expanded where necessary. 5. The use of “not applicable” in the report must be done with circumspection. All applicable sections of this report form must be completed. Where “not applicable” is used, this may result in the refusal of the application. 6. While the different sections of the report form only provide space for provision of information related to one alternative, if more than one feasible and reasonable alternative is considered, the relevant section must be copied and completed for each alternative. 7. Unless protected by law, all information contained in, and attached to this report, will become public information on receipt by the competent authority. If information is not submitted with this report due to such information being protected by law, the applicant and/or EAP must declare such non-disclosure and provide the reasons for believing that the information is protected. 8. Unless otherwise indicated by the Department, one hard copy and one electronic copy of this report must be submitted to the Department at the postal address given below or by delivery thereof to the Registry Office of the Department. Reasonable access to copies of this report must be provided to the relevant Organs of State for consultation purposes, which may, if so indicated by the Department, include providing a printed copy to a specific Organ of State. 9. This Report must be submitted to the Department and the contact details for doing so are provided below. 10. Where this Department is also identified as the Licencing Authority to decide applications under NEM:WA or NEM:AQA, the submission of the Report must also be made as follows, for-  Waste management licence applications, this report must also (i.e., another hard copy and electronic copy) be submitted for the attention of the Department’s Waste Management Directorate (tel: 021-483-2756 and fax: 021-483- 4425) at the same postal address as the Cape Town Office.  Atmospheric emissions licence applications, this report must also be (i.e., another hard copy and electronic copy) submitted for the attention of the Licensing Authority or this Department’s Air Quality Management Directorate (tel: 021 483 2798 and fax: 021 483 3254) at the same postal address as the Cape Town Office.

DEPARTMENTAL DETAILS

CAPE TOWN OFFICE GEORGE REGIONAL OFFICE REGION 1 REGION 2 REGION 3 (City of Cape Town & West Coast District) (Cape Winelands District & Overberg District) (Central Karoo District & Eden District)

Department of Environmental Affairs Department of Environmental Affairs Department of Environmental Affairs and Development Planning and Development Planning and Development Planning Attention: Directorate: Development Attention: Directorate: Development Attention: Directorate: Development Management (Region 1) Management (Region 2) Management (Region 3) Private Bag X 9086 Private Bag X 9086 Private Bag X 6509 Cape Town, Cape Town, George, 8000 8000 6530

Registry Office Registry Office Registry Office 1st Floor Utilitas Building 1st Floor Utilitas Building 4th Floor, York Park Building 1 Dorp Street, 1 Dorp Street, 93 York Street Cape Town Cape Town George

Queries should be directed to the Queries should be directed to the Queries should be directed to the Directorate: Development Directorate: Development Directorate: Development Management (Region 1) at: Management (Region 2) at: Management (Region 3) at: Tel.: (021) 483-5829 Tel.: (021) 483-5842 Tel.: (044) 805-8600 Fax: (021) 483-4372 Fax: (021) 483-3633 Fax: (044) 805 8650

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TABLE OF CONTENTS:

Section Page(s) Section A: Project Information 11-18 Section B: Description of the Receiving Environment 19-32 Section C: Public Participation 33-34 Section D: Need and Desirability 35-38 Section E: Details of all the Alternatives considered 39-41 Section F: Environmental Aspects Associated with the Alternatives 42-46 Section G: Impact Assessment, Impact Avoidance, Management, Mitigation 47-59 and Monitoring Measures Section H: Recommendations of the EAP 60-61 Section I: Appendices 62 Section J: Declarations 63-67

ACRONYMS USED IN THIS BASIC ASSESSMENT REPORT AND APPENDICES:

BAR Basic Assessment Report CBA Critical Biodiversity Area DEA National Department of Environmental Affairs DEA&DP Western Cape Government: Environmental Affairs and Development Planning DWS National Department of Water and Sanitation EIA Environmental Impact Assessment EMPr Environmental Management Programme ESA Ecological Support Area HWC Heritage Western Cape I&APs Interested and Affected Parties NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998) NEM:AQA National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) NEM:ICMA National Environmental Management: Integrated Coastal Management Act, 2008 (Act No. 24 of 2008) NEM:WA National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) NHRA National Heritage Resources Act, 1999 (Act No. 25 of 1999) PPP Public Participation Process

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DETAILS OF THE APPLICANT

Applicant / Organisation Cape Agulhas Municipal Manager / Organ of State: Contact person: Mr Dean O'Neil Postal address: Cape Agulhas Municipality PO Box 51, Bredasdorp, Postal Telephone: (028) 425 5500 7280 Code: Cellular: Not provided Fax: (028) 425 1019 E-mail: [email protected]

DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (“EAP”)

Name of the EAP organisation: Coastal and Environmental Services (CES) Person who compiled this Report: Dr Anthony (Ted) Mark Avis EAP Reg. No.: EAPSA Certification from 19 April 2004 Contact Person (if not author): Zweli Nkosi Postal address: Suite 408, 4th floor, The Point, 76 Regent Road, Sea Point, Cape Town Postal Telephone: (021) 045 0900 8000 Code: Cellular: 082 783 6393 Fax: 046 622 6564 E-mail: [email protected] EAP Qualifications: BSc, BSc (Hons); PhD

Please provide details of the lead EAP, including details on the expertise of the lead EAP responsible for the Basic Assessment process. Also attach his/her Curriculum Vitae to this BAR.

Dr A.M (Ted) Avis

Ted Avis is a leading expert in the field of Environmental Impact Assessments, having project- managed numerous large-scale ESIAs to international standards (e.g. International Finance Corporation). Ted was principle consultant to Corridor Sands Limitada for the development of all environment aspects for the US$1billion Corridor Sands Project. He has managed ESIA studies and related environmental assessments of similar scope in Kenya, Madagascar, Egypt, Malawi, Zambia and South Africa. Ted has worked across Africa, and also has experience in large scale Strategic Environmental Assessments in southern Africa, and has been engaged by the International Finance Corporation (IFC) on a number of projects.

Ted was instrumental in establishing the Environmental Science Department at Rhodes University whilst a Senior lecturer in Botany, based on his experience running honours modules in EIA practice and environmental. He is an Honorary Visiting Fellow in the Department of Environmental Sciences at Rhodes. He was one of the first certified Environmental Assessment Practitioner in South Africa, gaining certification in April 2004. He has delivered papers and published in the field of EIA, Strategic Environmental Assessment and Integrated Coastal Zone Management and has been a principal of CES since its inception in 1990, and Managing Director since 1998.

Ted holds a PhD in Botany, and was awarded a bronze medal by the South African Association of Botanists for the best PhD adjudicated in that year, entitled “Coastal Dune Ecology and Management in the Eastern Cape”. Ted is a Certified Environmental Assessment Practitioner (since 2002) and a professional member of the South African Council for Natural Scientific Professionals (since 1993).

SACNASP: South African Council for Natural Scientific Profession EAPSA: Environmental Assessment Practitioner Southern Africa Royal Society of South Africa Visiting Fellow – Dept. of Environmental Science, Rhodes University Botanical Society of South Africa

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SAAB: South African Association of Botanists South African Institute of Ecologists & Environmental Scientists International Association of Impact Assessment

EXECUTIVE SUMMARY OF THE BASIC ASSESSMENT REPORT:

The Cape Agulhas Municipality (here-in referred to as the Municipality) proposes to expand the industrial area of Bredasdorp town in the Western Cape Province.

The Municipality have contracted CES to undertake the necessary assessment and assume a role of the EAP to conduct a Basic Assessment (BA) for this proposed. The BA is for the proposed expansion of the industrial area in Bredasdorp.

Project Description

The Cape Agulhas Municipality intends to subdivide the Erf 1148 for the purpose of establishing Section A of Erf 1148 and the Remainder thereof.

It is the intention of the Municipality to then Rezone Section A of Erf 1148 into a Sub-divisional Area. The “Rezoned Section A” into Sub-divisional Area will then be further subdivided into fourteen (14) Industry Zoned Erven and one (1) Street Zoned erf.

The proposed property sizes (in m2) of the 14 proposed Industry Zoned (Figure 2.2) erven have been presented on the table below:

Table 1: Property Sizes Industry Zoned Erven Size (m2) 1 1089m² 2 1418m² 3 1379m² 4 1379m² 5 1379m² 6 1379m² 7 1379m 8 1379m² 9 1379m² 10 1719m² 11 1724m² 12 1731m² 13 1732m² 14 1216m² Street Zoned Erf Size (m2) 15 5218m2 Total 25 500 m2

The area is surrounded by several industrial services or activities, this includes but not limited to agroindustry, aluminium and glass industry, a fuel depot as well other agricultural/commercial shops.

It is our understanding that following the conclusion of this Basic Assessment, and based on the positive outcome of the assessment, it is the intention of the Municipality to auction or sell this proposed property area to a private developer. Therefore, the design, layout plans as well as detailed service infrastructure plans associated with any specific development (that is consistent with the

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existing activities) were not provided by the Municipality, which is still in possession of the proposed land parcel.

Figure 1: Map showing proposed Subdivision for 14 Industrial erven on Section A

Environmental Assessment

It has been investigated that the proposed development will trigger activities listed under Listing Notices (LN) 1 and Listing Notice 3.

In terms of NEMA (Act 107 of 1998): EIA Regulation as amended in 2017, any Activities that are triggered under LN1 and/or LN 2 require that Basic Environmental Assessment process be undertaken. This Basic Assessment is undertaken in line with the above triggered activities under Listing Notices 1 and 3.

Site/Area Description

Location The proposed site is located on subdivided Section A of Erf 1148 in Bredasdorp. The area is surrounded by several industrial services or activities, this includes but not limited to agroindustry, aluminium glass industry and fuel depot as well other agricultural/commercial shops (see figure 1).

Current Land use The area proposed for development falls on land with undetermined zoning, which is an area where no development is currently allowed without approved rezoning. The Municipality’s intention to expand the industrial area of Bredasdorp is not inconsistent with the existing land use activities of the area as the proposed site for subdivision and potential development is bordered by industries on the East across the banks of the river and by an agricultural warehouse and commercial industrial buildings on the West.

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municipality keeps near/on the site until owners reclaim them. It appears vagrants use the area to sleep. Other areas seem to be used for gatherings, there is evidence of open fires rubbish and alcohol bottles.

Climate Bredasdorp has a Mediterranean climate and receives most of its rain during winter seasons. Cape Agulhas usually receives about 344mm of rain annually. The monthly distribution of average daily maximum temperatures indicates that the average midday temperatures for Bredasdorp range from 17.5°C in July to 26.2°C in January. Bredasdorp is also known to be coldest during the July months, with temperatures achieving an average low of 6.3°C at night.

Topography The proposed industrial area where the 14 proposed industrial erven will be accommodated is located on a relatively flat area which slopes from the northern section at Swellendam Road to the south-eastern section on Ou Meule Street, with an altitudinal gradient of 9m.

Geology The site falls completely within the Ceres geological type of formation. This rock type is characterised by shallow marine siliciclastics which are defined by alternating sandstone- and mudrock-dominated formations (SAHRA, 2013)

Flora A site visit, conducted by an ecological specialist. According to the Mucina and Rutherford, 2006, only one vegetation type will be impacted on by subdivision and expansion of the industrial area, Central Ruens Shale Renosterveld. This was confirmed during the site, where field survey recorded two vegetation types on site; Degraded Renosterveld and Riparian Vegetation (found on the river banks and dominated by Typha capensis). The indigenous species recorded at the site were compared to the South African Red Data List, the Threatened and Protected Species list and the Provincial Nature Conservation Ordinance Act (PNCO) (No. 19 of 1974). Only one species (Ruschia cf lineolata) of conservation concern, which is listed as Schedule 4 species on the PNCO list, was recorded. This species will require permits for their destruction.

Although the site was found to be degraded and the species diversity is lower than expected, “Portion A” of Erf 1148 still functions as an important terrestrial and aquatic ecological corridor through the town of Bredasdorp, linking the natural areas (and CBA2 areas) to the north-west of the town to the areas in the south-east. As such, this site is considered to be of moderate sensitivity.

Fauna 19 of reptile species have been recorded within the Study area Quarter Degree Square (QDS) 3420CA. These species are listed as least concerned and unlikely to be found on site (SARCA, 2014). Approximately 9 species of amphibians have been recorded in QDS. No SCC amphibians are likely to occur on site. Approximately 46 mammal species have been recorded in QDS 3420CA (ADU, 2018) the majority of these are likely located at the Heuningberg Nature Reserve. Of the bird species, 359 bird species are estimated to occur within the Bredasdorp region. 12 birds were seen on site during the field visit including the Southern Red Bishop, Cape Canary, Helmeted Guinea fowl, Hadeda Ibis, Yellow billed kite, Speckled Pidgeon, Cape Sparrow, Common starling, Red winged starling, Cape Weaver, Cape white eye and pearl breasted swallow. The site also falls within 16 species of conservation concern and five endemic distribution ranges (Lepage, 2018). The study area QDS includes an ocean portion approximately 25km away, given that marine and shoreline species are restricted to their habitat and are highly unlikely to occur in the study area.

Socio-Economic Description

Cape Agulhas Municipality The Cape Agulhas municipality is located approximately 190, 4 km from Cape Town. The municipal area covers approximately 2411km² and it includes the towns of Bredasdorp and Napier, the coastal towns of Arniston, Struisbaai, L’Agulhas and Suiderstrand as well as the rural settlements of Protem and Klipdale. The main economic sectors include finance, insurance, real estate and business services (26%), general government (19.1%) and manufacturing (17%).

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Population Distribution The total population of Cape Agulhas Local Municipality is approximately 33,038 people who live in informal and formal settlement areas in 10,162 households. The below table shows the population distribution of people residing in the Cape Agulhas Municipality by their population group. Table below also shows that in 2011, the Coloured population group had the highest percentage, followed by Whites, the Black Africans, Indians or Asians and “other” population groups that live in the area.

Table 2: Population Distribution by Population Group in Cape Agulhas Municipality (2011) Population Group Number Percentage Black African 3 808 11.53% Coloured 21 662 65.57% Indian or Asian 111 0.34% White 7 149 21.64% Other 308 0.93% Total 33 038 100%

Age and Gender Structure A majority of the population in Cape Agulhas (67.6%) falls within the economically viable age group of 15-64 years with the dependency ration of 47.9%.

The Gender profile of the Cape Agulhas Local Municipality shows an almost equal percentage of both genders with males being 49.12% and females being 50.87%.

Level of Education Learner enrolment in Cape Agulhas increased at an annual average growth rate of 1.7% between the years 2014 and 2016.

Impact Summary

The following impacts were identified:

Significance rating Significance rating of impacts Before of impacts after Impacts mitigation (Low, mitigation (Low, Medium, Medium- Medium, Medium- High, High, Very High, High, Very High): High): Planning, design and construction phases 1. Loss of Degraded Renosterveld Moderate - Moderate - 2. Loss of Biodiversity Moderate - Low - 3. Loss of Species of Conservation Concern Low - Low - 4. Habitat Fragmentation Moderate - Low - 5. Invasion of Invasive Alien Plant Species Moderate - Low - Operational phase 6. Degradation of the site due to poor High - Low - management

Conclusion The Cape Agulhas Municipality proposes to expand the industrial area of Bredasdorp town in the Western Cape Province. The impacts associated with the proposed industrial expansion with and without mitigation measures have been assessed.

 In terms of ecological impacts: o The proposed infrastructure is located within an ESA that currently functions as an ecological corridor through the town of Bredasdorp.

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o Although the site is degraded with some invasive alien species present, this site is considered to be of moderate sensitivity due to the important ecological processes it performs. o Five out of six identified negative impact can be mitigated from high and moderate sensitivity to low sensitivity. o 2.4 ha of degraded Renosterveld will be lost as a result of clearing for the construction of the road and buildings anticipated for the 14 erven. As a result, the impact remains moderately negative before and after mitigation measure have been considered. o The development will also lead to further fragmentation of an important ecological corridor that links the northern section of Bredasdorp to the southern section

Since developmental footprint is fairly small and provided: o the development footprint is as indicated on proposed 14 industrial erven; and o an ecological corridor or green belt is developed as part of the development and becomes a condition of the environmental authorisation

the impacts associated with the development are considered acceptable.

Recommendations It is recommended that if this development proceeds, an ecological corridor along the Droë River is delineated and preserved in perpetuity to ensure that the current ecological processes, such as seed dispersal and movement of fauna, can continue unhindered.

It is further recommended that future expansions do not limit or block the established ecological corridor, and ways to achieve this and manage the corridor should and should be included in the Environmental Management Programme.

Some of the ‘Development Phase’ specific recommendations have been included below and include, inter alia:

 Construction Phase- o Clearing must be kept to a minimum; o Top soil (20 cm, where possible) must be collected and used elsewhere on the property and for the rehabilitation of lay down areas and other impacted areas no longer required during the operational phase; o An alien management plan must be designed and implemented to prevent the spread of alien species; o Prohibit open fires; o An Environmental Control Officer (ECO) must be employed to demarcate areas for use during construction, and to ensure that the construction activities remain within the designated area and that no unauthorised activities occur outside of the construction footprint.

 Operation Phase- o An invasive alien management plan must be in place o A storm water management plan that minimises erosion must be implemented o Prevent illegal harvesting of plant material, illegal dumping and illegal fires by active enforcement

The Basic Assessment for this proposed expansion of the Bredasdorp industrial area is only for the Listed Activities triggered. It is therefore important to note that if new or any other Activities are triggered by the new property owners under Listing Notices 1, 2 and/or 3, they are required to obtain their own Environmental Authorisation from the relevant and competent authorities.

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SECTION A: PROJECT INFORMATION

1. ACTIVITY LOCATION

Location of all Erf 1148 in Bredasdorp, Western Cape proposed sites: Farm / Erf name(s) and number(s) Erf 1148 (including Portions thereof) for each Subdivided ‘Portion A’ of Erf 1148 proposed site:

Industry Zoned Erven Size (m2) 1 1089m² 2 1418m² 3 1379m² 4 1379m² 5 1379m² 6 1379m²

Property size(s) in m2 7 1379m for each proposed 8 1379m² site: 9 1379m² 10 1719m² 11 1724m² 12 1731m² 13 1732m² 14 1216m² Street Zoned Erf Size (m2) 15 5218m2 Total 25 500 m2

Development 20 282 m2 footprint size(s) in m2: Surveyor General (SG) 21 digit code for C01100030000114800000 each proposed site:

2. PROJECT DESCRIPTION

(a) Is the project a new development? If “NO”, explain: YES NO

(b) Provide a detailed description of the scope of the proposed development (project).

The Cape Agulhas Municipality (here-in referred to as the Municipality) proposes to expand the industrial area of Bredasdorp town in the Western Cape Province. The Locality map is presented in Figure 2.1 below.

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Figure 2.1: Locality Map

The Cape Agulhas Municipality intends to subdivide the Erf 1148 for the purpose of establishing Section A of Erf 1148 and the Remainder thereof.

The proposed property sizes (in m2) of the 14 proposed Industry Zoned (Figure 2.2) erven have been presented on the table 1 below:

Table 1: Property Sizes Industry Zoned Erven Size (m2) 1 1089m² 2 1418m² 3 1379m² 4 1379m² 5 1379m² 6 1379m² 7 1379m 8 1379m² 9 1379m² 10 1719m² 11 1724m² 12 1731m² 13 1732m² 14 1216m²

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Figure 2.2: Proposed Subdivision for Industrial erven on Section A

Please note: This description must relate to the listed and specified activities in paragraph (d) below.

(i) the period within which commencement must occur, 7 years

(ii) the period for which the environmental authorisation should be granted and the date by which the activity must have been concluded, where the 7 years environmental authorisation does not include operational aspects;

(iii) the period that should be granted for the non- operational aspects of the environmental 7 years authorisation; and

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(iv) the period that should be granted for the operational aspects of the environmental authorisation. 7 years

Please note: The Department must specify the abovementioned periods, where applicable, in an environmental authorisation. In terms of the period within which commencement must occur, the period must not exceed 10 years and must not be extended beyond such 10 year period, unless the process to amend the environmental authorisation contemplated in regulation 32 is followed.

(d) List all the listed activities triggered and being applied for.

Please note: The onus is on the applicant to ensure that all the applicable listed activities are applied for and assessed as part of the EIA process. Please refer to paragraph (b) above.

EIA Regulations Listing Notices 1 and 3 of 2014 (as amended): Identify if the activity is Describe the relevant Basic Describe the portion of the development / Listed Assessment Activity(ies) in development that relates to development and Activity writing as per Listing Notice the applicable listed operational / No(s): 1 activity as per the project decommissioning / (GN No. R. 983) description. expansion / expansion and operational. The area to be developed The clearance of an area of according to distribution of 1 hectare or more, but less 27 properties will require that than 20 hectares of more than 1 hectare be indigenous vegetation. cleared. Listed Identify if the activity is Activity Describe the relevant Basic Describe the portion of the development / No(s): Assessment Activity (ies) in development that relates to development and writing as per Listing Notice the applicable listed operational / 3 activity as per the project decommissioning / (GN No. R. 985) description. expansion / expansion and operational. The clearance of an area of 300m2 or more of indigenous The proposed expansion vegetation except where might result in the clearance such clearance of of 300m2 of the indigenous indigenous vegetation is vegetation and of which 12 required for maintenance Central Ruens Shale purposes undertaken in Renosterveld might be part accordance with a as the proposed sites occurs maintenance management within this vegetation type plan.

Waste management activities in terms of the NEM: WA (GN No. 921): Category Describe the relevant Category A waste Describe the portion of the development A management activity in writing as per GN that relates to the applicable listed Listed No. 921 activity as per the project description Activity No(s): N/A N/A N/A Note: If any waste management activities are applicable, the Listed Waste Management Activities Additional Information Annexure must be completed and attached to this Basic Assessment Report as Appendix I.

Atmospheric emission activities in terms of the NEM: AQA (GN No. 893):

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Listed Describe the relevant atmospheric Describe the portion of the development Activity emission activity in writing as per GN No. that relates to the applicable listed No(s): 893 activity as per the project description.

N/A N/A N/A

(e) Provide details of all components (including associated structures and infrastructure) of the proposed development and attach diagrams (e.g., architectural drawings or perspectives, engineering drawings, process flowcharts, etc.).

Buildings YES NO Provide brief description below: The Municipality has intentions of putting up this land parcel for sale. Therefore, development component and diagrams (including associated structures and infrastructure and architectural drawings or perspectives, engineering drawings, process flowcharts, etc.) are not known and available at this stage for what will be individual developments by respective business in the future. Infrastructure (e.g., roads, power and water supply/ storage) YES NO Provide brief description below: As above. Processing activities (e.g., manufacturing, storage, distribution) YES NO Provide brief description below: As above. Storage facilities for raw materials and products (e.g., volume and substances to be stored) YES NO Provide brief description below: As above. Storage and treatment facilities for effluent, wastewater or sewage: YES NO Provide brief description below: The site will be linked to existing sewage reticulation network. It is unlikely that any of the potential businesses to be located in the industrial park will generate effluent other than sewage from their operational activities. Storage and treatment of solid waste YES NO Provide brief description below: The municipality landfill will be utilised for waste disposal, the individual businesses will have to implement their respective water management strategies. Facilities associated with the release of emissions or pollution. YES NO Provide brief description below: Unknown at this stage, but unlikely to be of concern of significance. Other activities (e.g., water abstraction activities, crop planting activities) – YES NO Provide brief description below: None anticipated.

3. PHYSICAL SIZE OF THE PROPOSED DEVELOPMENT

See Table (a) Property size(s): Indicate the size of all the properties (cadastral units) 1 above m2 on which the development proposal is to be undertaken m2 (b) Size of the facility: Indicate the size of the facility where the 20 282 m2 m2 development proposal is to be undertaken (c) Development footprint: Indicate the area that will be physically altered as a result of undertaking any development proposal (i.e., the physical 20 282 m2 m2 size of the development together with all its associated structures and infrastructure) (d) Size of the activity: Indicate the physical size (footprint) of the As above m2 development proposal

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(e) For linear development proposals: Indicate the length (L) and width (W) (L) m of the development proposal (W) 270 m

(f) For storage facilities: Indicate the volume of the storage facility Unknown m3

(g) For sewage/effluent treatment facilities: Indicate the volume of the Not facility m3 applicable (Note: the maximum design capacity must be indicated

4. SITE ACCESS

(a) Is there an existing access road? YES NO (b) If no, what is the distance in (m) over which a new access road will be built? m

(c) Describe the type of access road planned: The property is accessed from the R319 (Swellendam Rd) and the proposed site will be accessed via existing internal roads. Please note: The position of the proposed access road must be indicated on the site plan.

5. DESCRIPTION OF THE PROPERTY(IES) ON WHICH THE LISTED ACTIVITY(IES) ARE TO BE UNDERTAKEN AND THE LOCATION OF THE LISTED ACTIVITY(IES) ON THE PROPERTY

5.1 Provide a description of the property on which the listed activity(ies) is/are to be undertaken and the location of the listed activity(ies) on the property, as well as of all alternative properties and locations (duplicate section below as required).

The proposed development will take place on subdivided Section A of Erf 1148 in Bredasdorp. This property is owned by the applicant and thus no alternatives are proposed. The area is surrounded by several industrial services or activities, this includes but not limited to agroindustry, aluminium glass industry and fuel depot as well other agricultural/commercial shops.

Figure 5.1: location of proposed subdivision area for 14 industrial erven.

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Latitude (S): (deg.; min.; sec) Longitude (E): (deg.; min.; sec.) Coordinates of all the proposed activities on the property or properties (sites): 34° 31΄ 48.04" 20o 3‘ 7.75“

Note: For land where the property has not been defined, the coordinates of the area within which the development is proposed must be provided in an addendum to this report.

5.2 Provide a description of the area where the aquatic or ocean-based activity(ies) is/are to be undertaken and the location of the activity(ies) and alternative sites (if applicable).

N/A

Latitude (S): (deg.; min.; sec) Longitude (E): (deg.; min.; sec) Coordinates of the boundary /perimeter of ° ' " o ' " all proposed aquatic or ocean-based ° ' " o ' " activities (sites) (if applicable): ° ' " o ' " ° ' " o ' "

5.3 For a linear development proposal, please provide a description and coordinates of the corridor in which the proposed development will be undertaken (if applicable).

N/A

For linear activities: Latitude (S): (deg.; min.; sec) Longitude (E): (deg.; min.; sec)  Starting point of the activity o ‘ “ o ‘ “  Middle point of the activity o ‘ “ o ‘ “  End point of the activity o ‘ “ o ‘ “

Note: For linear development proposals longer than 1000m, please provide an addendum with co-ordinates taken every 250m along the route. All important waypoints must be indicated and the GIS shape file provided digitally.

5.4 Provide a location map (see below) as Appendix A to this report that shows the location of the proposed development and associated structures and infrastructure on the property; as well as a detailed site development plan / site map (see below) as Appendix B to this report; and if applicable, all alternative properties and locations. The GIS shape files (.shp) for maps / site development plans must be included in the electronic copy of the report submitted to the competent authority.

The scale of the locality map must be at least 1:50 000. For linear development proposals of more than 25 kilometres, a smaller scale e.g., 1:250 000 can be used. The scale must be indicated on the map. The map must indicate the following:  an accurate indication of the project site position as well as the positions of the alternative sites, if any;  road names or numbers of all the major roads as well as the roads that provide access to the site(s)  a north arrow;  a legend;  a linear scale; Locality  the prevailing wind direction (during November to April and during May to October); and Map:  GPS co-ordinates (to indicate the position of the activity using the latitude and longitude of the centre

point of the site for each alternative site. The co-ordinates should be in degrees and decimal minutes. Appendix A The minutes should have at least three decimals to ensure adequate accuracy. The projection that must be used in all cases is the WGS84 spheroid in a national or local projection).

For an ocean-based or aquatic activity, the coordinates must be provided within which the activity is to be undertaken and a map at an appropriate scale clearly indicating the area within which the activity is to be undertaken.

Coordinates must be provided in degrees, minutes and seconds using the Hartebeesthoek94; WGS84 coordinate system.

Detailed site development plan(s) must be prepared for each alternative site or alternative activity. The site Site Plan: plans must contain or conform to the following:

 The detailed site plan must preferably be at a scale of 1:500 or at an appropriate scale. The scale must Appendix B be indicated on the plan, preferably together with a linear scale.

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 The property boundaries and numbers of all the properties within 50m of the site must be indicated on the site plan.  The current land use (not zoning) as well as the land use zoning of each of the adjoining properties must be indicated on the site plan.  The position of each element of the application as well as any other structures on the site must be indicated on the site plan.  Services, including electricity supply cables (indicate aboveground or underground), water supply pipelines, boreholes, sewage pipelines, storm water infrastructure and access roads that will form part of the development must be indicated on the site plan.  Servitudes and an indication of the purpose of each servitude must be indicated on the site plan.  Sensitive environmental elements within 100m of the site must be included on the site plan, including (but not limited to): o Watercourses / Rivers / Wetlands - including the 32 meter set back line from the edge of the bank of a river/stream/wetland; o Flood lines (i.e., 1:100 year, 1:50 year and 1:10 year where applicable; o Ridges; o Cultural and historical features; o Areas with indigenous vegetation (even if degraded or infested with alien species).  Whenever the slope of the site exceeds 1:10, a contour map of the site must be submitted.  North arrow

A map/site plan must also be provided at an appropriate scale, which superimposes the proposed development and its associated structures and infrastructure on the environmental sensitivities of the preferred and alternative sites indicating any areas that should be avoided, including buffer areas.

The GIS shape file for the site development plan(s) must be submitted digitally.

6. SITE PHOTOGRAPHS

Colour photographs of the site and its surroundings (taken on the site and taken from outside the site) with a description of each photograph. The vantage points from which the photographs were taken must be indicated on the site plan, or locality plan as applicable. If available, please also provide a recent aerial photograph. Photographs must be attached as Appendix C to this report. The aerial photograph(s) should be supplemented with additional photographs of relevant features on the site. Date of photographs must be included. Please note that the above requirements must be duplicated for all alternative sites.

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SECTION B: DESCRIPTION OF THE RECEIVING ENVIRONMENT

Site/Area Description

For linear development proposals (pipelines, etc.) as well as development proposals that cover very large sites, it may be necessary to complete copies of this section for each part of the site that has a significantly different environment. In such cases please complete copies of Section B and indicate the area that is covered by each copy on the Site Plan.

1. GRADIENT OF THE SITE

Indicate the general gradient of the sites (highlight the appropriate box).

Flat Flatter than 1:10 1:10 – 1:4 Steeper than 1:4

2. LOCATION IN LANDSCAPE

(a) Indicate the landform(s) that best describes the site (highlight the appropriate box(es).

Side slope of Closed Open Undulating Ridgeline Plateau Plain Dune Sea-front hill / mountain valley valley plain/low hills

(b) Provide a description of the location in the landscape.

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Climate

Bredasdorp has a Mediterranean climate and receives most of its rain during winter seasons. Cape Agulhas usually receives about 344mm of rain annually. http://www.saexplorer.co.za/south- africa/climate/bredasdorp_climate.asp.

Bredasdorp receives highest rainfalls in August and its lowest rainfalls mostly in December (Figure B.1).

Figure B.1: CAM monthly average rainfall

The monthly distribution of average daily maximum temperatures indicate that the average midday temperatures for Bredasdorp range from 17.5°C in July to 26.2°C in January. (Figure B.2).

Figure B.2: CAM monthly average midday temperatures

Bredasdorp is also known to be coldest during the July month, where temperatures reach an average low of 6.3°C at night (Figure B.3).

Figure B.3: CAM Average night temperatures

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Figure B.4: Topography of the surrounding landscape

3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE

(a) Is the site(s) located on or near any of the following (highlight the appropriate boxes)?

Shallow water table (less than 1.5m deep) YES NO UNSURE Seasonally wet soils (often close to water bodies) YES NO UNSURE Unstable rocky slopes or steep slopes with loose soil YES NO UNSURE Dispersive soils (soils that dissolve in water) YES NO UNSURE Soils with high clay content YES NO UNSURE Any other unstable soil or geological feature YES NO UNSURE An area sensitive to erosion YES NO UNSURE An area adjacent to or above an aquifer. YES NO UNSURE An area within 100m of a source of surface water YES NO UNSURE An area within 500m of a wetland YES NO UNSURE An area within the 1:50 year flood zone YES NO UNSURE A water source subject to tidal influence YES NO UNSURE

(b) If any of the answers to the above is “YES” or “UNSURE”, specialist input may be requested by the Department. (Information in respect of the above will often be available at the planning sections of local authorities. The 1:50 000 scale Regional Geotechnical Maps prepared by Geological Survey may also be used).

Granite Shale Sandstone Quartzite Dolomite Dolorite Other (describe) Provide a description.

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The site falls completely within the Ceres geological type of formation (Figure B.5). This rock type is characterised by shallow marine siliciclastics which are defined by alternating sandstone- and mudrock-dominated formations (SAHRA, 2013).

Figure B.5: Geology of the area (https://sahris.sahra.org.za/fossil-layers/ceres-subgroup )

4. SURFACE WATER

(a) Indicate the surface water present on and or adjacent to the site and alternative sites (highlight the appropriate boxes)?

Perennial River YES NO UNSURE Non-Perennial River YES NO UNSURE Permanent Wetland YES NO UNSURE Seasonal Wetland YES NO UNSURE Artificial Wetland YES NO UNSURE Estuarine / Lagoon YES NO UNSURE

(b) Provide a description.

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As can be seen in the figure 3.6 below, there is a non-perennial stream located on site that flows in a south-easterly direction, but it will not be affected by the subdivision (development footprint).

The site falls within 32m of the water course from the edge of the property on the east. This proximity to the water course coud possibly trigger Activity 12 in Listing Notice 1 of the EIA regulations which states:

The development of- (ii) infrastructure or structures with a physical footprint of 100 square metres or more; where such development occurs- (c) if no development setback exists, within 32 metres of a water course, measured from the edge of a water course; - excluding- (dd) where such development occurs within an urban area;

This activity has been excluded on the list of triggered activities because the proposed development is an extension of an existing industrial area within the urban setting.

Figure B.6: water features occurring within the site

5. THE SEAFRONT / SEA

(a) Is the site(s) located within any of the following areas? (highlight the appropriate boxes). If the site or alternative site is closer than 100m to such an area, please provide the approximate distance in (m).

If “YES”: Distance AREA YES NO UNSURE to nearest area (m) An area within 100m of the high water mark of the sea YES NO UNSURE An area within 100m of the high water mark of an estuary/lagoon YES NO UNSURE An area within the littoral active zone YES NO UNSURE An area in the coastal public property YES NO UNSURE Major anthropogenic structures YES NO UNSURE

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An area within a Coastal Protection Zone YES NO UNSURE An area seaward of the coastal management line YES NO UNSURE An area within the high risk zone (20 years) YES NO UNSURE An area within the medium risk zone (50 years) YES NO UNSURE An area within the low risk zone (100 years) YES NO UNSURE An area below the 5m contour YES NO UNSURE An area within 1km from the high water mark of the sea YES NO UNSURE A rocky beach YES NO UNSURE A sandy beach YES NO UNSURE

(b) If any of the answers to the above is “YES” or “UNSURE”, specialist input may be requested by the Department. (The 1:50 000 scale Regional Geotechnical Maps prepared by Geological Survey may also be used).

6. BIODIVERSITY

Note: The Department may request specialist input/studies depending on the nature of the biodiversity occurring on the site and potential impact(s) of the proposed development. To assist with the identification of the biodiversity occurring on site and the ecosystem status, consult http://bgis.sanbi.org or [email protected] . Information is also available on compact disc (“cd”) from the Biodiversity-GIS Unit, Tel.: (021) 799 8698. This information may be updated from time to time and it is the applicant/ EAP’s responsibility to ensure that the latest version is used. A map of the relevant biodiversity information (including an indication of the habitat conditions as per (b) below) must be provided as an overlay map on the property/site plan as Appendix D to this report.

(a) Highlight the applicable biodiversity planning categories of all areas on preferred and alternative sites and indicate the reason(s) provided in the biodiversity plan for the selection of the specific area as part of the specific category. Also describe the prevailing level of protection of the Critical Biodiversity Area (“CBA”) and Ecological Support Area (“ESA”) (how many hectares / what percentages are formally protected).

No Natural Area Other Natural Systematic Biodiversity Planning Category CBA ESA Remaining Area (“ONA”) (“NNR”) The proposed area does not fall within a CBA but lies within an Ecological Support Areas (ESA) 2. These are areas that are not essential for meeting biodiversity targets, but that play an important role in supporting the functioning of PAs or CBAs and are often vital for delivering ecosystem services. The If CBA or ESA, indicate the reason(s) for its management of these areas should be to “restore and/or selection in biodiversity plan and the conservation management objectives minimize impact on ecological processes and ecological infrastructure functioning, especially soil and water-related services, and to allow for faunal movement”. The ESA 2 area is along the banks of Droë River (non-perennial stream), which forms a natural ecological corridor that links the CBA to the north-west of the site with the CBA to the south-east thereof. Describe the site’s CBA/ESA quantitative values (hectares/percentage) in relation to the prevailing level of protection of The ESA 2 area is 2.4 ha in extent. However, this will not be CBA and ESA (how many hectares / what impacted on by the proposed subdivision. percentages are formally protected locally and in the province)

(b) Highlight and describe the habitat condition on site.

Percentage of habitat Description and additional comments and observations (including Habitat Condition condition class (adding up additional insight into condition, e.g. poor land management to 100%) and area of each practises, presence of quarries, grazing/harvesting regimes, etc.) in square metre (m2)

Natural 0% 0m2 N/A

Near Natural (includes areas with low to moderate 0% 0m2 N/A level of alien invasive plants)

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Degraded The degraded area included areas with riparian (includes areas vegetation and areas with degraded Renosterveld as a 97.6% 110256.7 m2 heavily invaded by result of the site being used as a through-way and for alien plants) illegal dumping activities. Transformed (includes The area that was found to be transformed included cultivation, dams, 2.4% 2724.98 m2 areas with the house structures and parking or bare urban, plantation, ground areas roads, etc.)

(c) Complete the table to indicate: (i) the type of vegetation present on the site, including its ecosystem status; and (ii) whether an aquatic ecosystem is present on/or adjacent to the site.

Description of Ecosystem, Vegetation Type, Original Extent, Terrestrial Ecosystems Threshold (ha, %), Ecosystem Status Central Rûens Shale Renosterveld – only about 13% Critically Ecosystem threat status as per the of its original area remains intact National Environmental Endangered N/A Management: Biodiversity Act, 2004 (Act No. 10 of 2004) Vulnerable N/A

Least N/A Threatened

Aquatic Ecosystems

Wetland (including rivers, depressions, channelled and unchannelled wetlands, flats, Estuary Coastline seeps pans, and artificial wetlands)

YES NO UNSURE YES NO YES NO

(d) Provide a description of the vegetation type and/or aquatic ecosystem present on the site, including any important biodiversity features/information identified on the site (e.g. threatened species and special habitats). Clearly describe the biodiversity targets and management objectives in this regard.

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Vegetation

The site occurs within the Central Ruens Shale Renosterveld vegetation type (Figure B.7)

Figure B.7: National Vegetation Map showing the vegetation type (Central Ruens Shale Renosterveld) that will be affected by the expansion

Central Ruens Shale Renosterveld:

This vegetation type occurs from Greyton and Stormsvlei to Napier and Bredasdorp as well as along the coastal flats southeast of Bredasdorp towards Arniston. It is an open to medium dense cupressoid and small-leaved, low to moderately tall grassy shrubland that is typically dominated by renosterbos. This vegetation type is listed as critically endangered since the conservation target of 27% cannot be attained as 87% has already been transformed by agricultural practices.

Species of Conservation Concern:

Only one species (Ruschia cf lineolata) of conservation concern, which is listed as Schedule 4 species on the PNCO list, was recorded. This species will require permits for their destruction.

7. LAND USE OF THE SITE

Note: The Department may request specialist input/studies depending on the nature of the land use character of the area and potential impact(s) of the proposed development.

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Low density Untransformed area Medium density residential High density residential Informal residential residential Commercial & Retail Light industrial Medium industrial Heavy industrial warehousing Office/consulting Military or police Casino/entertainment Tourism and Power station room base/station/compound complex Hospitality facility Quarry, sand or borrow Open cast mine Underground mine Spoil heap or slimes dam Dam or reservoir pit Hospital/medical School Tertiary education facility Church Old age home centre Sewage treatment Train station or Major road (4 lanes and Railway line Airport plant shunting yard more) Harbour Sport facilities Golf course Polo fields Filling station Landfill or waste Nature Plantation Agriculture River, stream or wetland treatment site conservation area Mountain, koppie Archaeological Museum Historical building Graveyard or ridge site Other land uses

(describe):

(a) Provide a description.

The site is currently vacant land and is considered degraded. The Droe River runs through the site. The site is currently used by pedestrians crossing the site and a number of paths exist. A portion of the area is also used to keep abandoned or stray cows, horses and donkeys which the municipality keeps near/on the site until owners reclaim them. It appears vagrants use the area to sleep. Other areas seem to be used for gatherings, there is evidence of open fires rubbish and alcohol bottles.

8. LAND USE CHARACTER OF THE SURROUNDING AREA

(a) Highlight the current land uses and/or prominent features that occur within +/- 500m radius of the site and neighbouring properties if these are located beyond 500m of the site.

Note: The Department may request specialist input/studies depending on the nature of the land use character of the area and potential impact(s) of the proposed development.

(describe):

(b) Provide a description, including the distance and direction to the nearest residential area, industrial area, agri-industrial area.

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The site is surrounded by light-medium industrial area, residential areas and by a school. The an industrial area borders the property on both sides of and the proposed development project will be expanded from these already existing light industries, effectively connecting them. There is a graveyard that is located +-500m away from the site and there are also some other operating businesses which are near the site.

9. SOCIO-ECONOMIC ASPECTS a) Describe the existing social and economic characteristics of the community in the vicinity of the proposed site, in order to provide baseline information (for example, population characteristics/demographics, level of education, the level of employment and unemployment in the area, available work force, seasonal migration patterns, major economic activities in the local municipality, gender aspects that might be of relevance to this project, etc.).

The site is located in the Cape Agulhas Local Municipality within the Overberg District Municipality in the Western Cape province. The nearest towns from the site include Napier (14km), Arniston (24km) and Struisbaai (28 km). There aren’t any economic activities that take place on the site currently but the project is proposed to be an extension of a nearby already existing industrial area therefore the only existing economic activities include that industrial area as well as some warehouses and other business operations located near the site.

Population Distribution The total population of Cape Agulhas Local Municipality is approximately 33,038 people who live in informal and formal settlement areas in 10,162 households. Table 2 shows the population distribution of people residing in the Cape Agulhas Municipality by their population group. Table 2 also shows that in 2011, the Coloured population group had the highest percentage, followed by Whites, the Black Africans, Indians or Asians and “other” population groups that live in the area.

Age and Gender Structure A majority of the population in Cape Agulhas (67.6%) falls within the economically viable age group of 15-64 years with the dependency ration of 47.9%.

The Gender profile of the Cape Agulhas Local Municipality shows an almost equal percentage of both genders with males being 49.12% and females being 50.87%.

Level of Education Learner enrolment in Cape Agulhas increased at an annual average growth rate of 1.7% between the years 2014 and 2016.

10. HISTORICAL AND CULTURAL ASPECTS

(a) Please be advised that if section 38 of the NHRA is applicable to your proposed development, you are requested to furnish this Department with written comment from Heritage Western Cape as part of your public participation process. Heritage Western Cape must be given an opportunity, together with the rest of the I&APs, to comment on any Pre- application BAR, a Draft BAR, and Revised BAR.

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Section 38 of the NHRA states the following: “38. (1) Subject to the provisions of subsections (7), (8) and (9), any person who intends to undertake a development categorised as- (a) the construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier exceeding 300m in length; (b) the construction of a bridge or similar structure exceeding 50m in length; (c) any development or other activity which will change the character of a site- (i) exceeding 5 000m2 in extent; or (ii) involving three or more existing erven or subdivisions thereof; or (iii) involving three or more erven or divisions thereof which have been consolidated within the past five years; or (iv) the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources authority; (d) the re-zoning of a site exceeding 10 000m2 in extent; or (e) any other category of development provided for in regulations by SAHRA or a provincial heritage resources authority, must at the very earliest stages of initiating such a development, notify the responsible heritage resources authority and furnish it with details regarding the location, nature and extent of the proposed development”.

(b) The impact on any national estate referred to in section 3(2), excluding the national estate contemplated in section 3(2)(i)(vi) and (vii), of the NHRA, must also be investigated, assessed and evaluated. Section 3(2) states the following: “3(2) Without limiting the generality of subsection (1), the national estate may include— (a) places, buildings, structures and equipment of cultural significance; (b) places to which oral traditions are attached or which are associated with living heritage; (c) historical settlements and townscapes; (d) landscapes and natural features of cultural significance; (e) geological sites of scientific or cultural importance; (f) archaeological and palaeontological sites; (g) graves and burial grounds, including— (i) ancestral graves; (ii) royal graves and graves of traditional leaders; (iii) graves of victims of conflict; (iv) graves of individuals designated by the Minister by notice in the Gazette; (v) historical graves and cemeteries; and (vi) other human remains which are not covered in terms of the Human Tissue Act, 1983 (Act No. 65 of 1983); (h) sites of significance relating to the history of slavery in South Africa; (i) movable objects, including— (i) objects recovered from the soil or waters of South Africa, including archaeological and paleontological objects and material, meteorites and rare geological specimens; (ii) objects to which oral traditions are attached or which are associated with living heritage; (iii) ethnographic art and objects; (iv) military objects; (v) objects of decorative or fine art; (vi) objects of scientific or technological interest; and (vii) books, records, documents, photographic positives and negatives, graphic, film or video material or sound recordings, excluding those that are public records as defined in section 1(xiv) of the National Archives of South Africa Act, 1996 (Act No. 43 of 1996)”.

Is Section 38 of the NHRA applicable to the proposed development? YES NO UNCERTAIN In terms of Section 38 of the Heritage Resources Act, 1999, any person who intends to undertake a development categorised as any development or other activity If YES or which will change the character of a site exceeding 5 000m2 in extent must notify UNCERTAIN, explain: the responsible heritage resources authority (Heritage Western Cape) of the location, nature and extent of the development. A notice of intent to develop has been submitted to HWC. Will the development impact on any national estate referred to in Section 3(2) of YES NO UNCERTAIN the NHRA?

If YES or UNCERTAIN, N/A explain:

Will any building or structure older than 60 years be affected in any way? YES NO UNCERTAIN

If YES or UNCERTAIN, N/A explain:

Are there any signs of culturally or historically significant elements, as defined in section 2 of the NHRA, including Archaeological or paleontological sites, on or YES NO UNCERTAIN close (within 20m) to the site?

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If YES or UNCERTAIN, N/A explain:

Note: If uncertain, the Department may request that specialist input be provided and Heritage Western Cape must provide comment on this aspect of the proposal. (Please note that a copy of the comments obtained from the Heritage Resources Authority must be appended to this report as Appendix E1).

11. APPLICABLE LEGISLATION, POLICIES, CIRCULARS AND/OR GUIDELINES

(a) Identify all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks, and instruments that are applicable to the development proposal and associated listed activity(ies) being applied for and that have been considered in the preparation of the BAR.

TYPE Permit/license/authorisation/comment LEGISLATION, POLICIES, PLANS, / relevant consideration (e.g. rezoning GUIDELINES, SPATIAL TOOLS, ADMINISTERING AUTHORITY DATE or consent use, building plan MUNICIPAL DEVELOPMENT and how it is relevant to this (if already approval, Water Use License and/or PLANNING FRAMEWORKS, AND application obtained): General Authorisation, License in terms INSTRUMENTS of the SAHRA and CARA, coastal discharge permit, etc.) The Constitution of South The Constitutional Court Environmental rights and social

Africa (Act 108 of 1996) of South Africa development National Environmental Department of Principles of environmental Management Act (107 of Environmental Affairs management, procedures to 19989) (NEMA) and (DEA) and Department be followed in a Basic Environmental Impact of Environmental Affairs Assessment process and Assessment (EIA) and Development Environmental Authorisation Regulations, 2010 Planning (DEA&DP) National Water Act (36 of Department of Water Water Use License 1998) Affairs and Sanitation A Notice of Intent to Develop was submitted to HWC and response received to confirm National Heritage that the development will not Heritage Western Cape 04 April Resources Act (25 of have impacts on heritage (HWC) 2019 1999) resources and that no further action under Section 38 of the NHRA (Act 25 of 1999) is required License/ permit/ Comment will Environmental be required for the removal of Conservation Ordinance Cape Nature Species of Conservation (No. 19 of 1974) Concern (SCC) Western Cape Nature Department of License/ permit may be Conservation Laws Environmental Affairs required for the removal of

Amendment Act (No. 3 of and Development Species of Conservation 2000) Planning (DEA&DP) Concern (SCC) Comment from DAFF (No Conservation of Department of comments or commitments or Agricultural Resources Act Agriculture, Forestry and comments were received (CARA) Fisheries during the commenting period) Relevant consideration in the Cape Agulhas Integrated Cape Agulhas Local assessment of need and Development Plan (IDP) Municipality desirability

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Relevant consideration in the Cape Agulhas Spatial Cape Agulhas Local assessment of need and Development Plan (SDF) Municipality desirability Overberg District Relevant consideration in the Overberg District Municipality Integrated assessment of need and Municipality Development Plan (IDP) desirability DEA&DP Guideline on Applied in consideration of DEA&DP Alternatives (2010) alternatives DEA&DP Guideline on DEA&DP Applied to the process of PPP Public Participation (2010) Applied to the Need and DEA&DP Guideline on DEA&DP Desirability section. Relevant Need & Desirability (2010 consideration DEA&DP Guideline for Environmental Applied in drafting of DEA&DP Management Plans attached EMPr. (2005)

(b) Describe how the proposed development complies with and responds to the legislation and policy context, plans, guidelines, spatial tools, municipal development planning frameworks and instruments.

LEGISLATION, POLICIES, PLANS, GUIDELINES, SPATIAL TOOLS, MUNICIPAL DEVELOPMENT Describe how the proposed development complies with and responds: PLANNING FRAMEWORKS, AND INSTRUMENTS The proposed extension of the Bredasdorp will promote economic The Constitution of South growth and social development while upholding environmental Africa (Act 108 of 1996) rights. This will happen through the implementation of the environmental management plan.

This Basic Assessment will be submitted to the Department of Environmental Affairs and Development Planning (DEADP) to ensure that the national environmental principles, fair decision making and integrated environmental management approach is applied National Environmental throughout the process. The basic assessment and associated Management Act (107 of environmental management plan aim to prevent pollution and 19989) ecological degradation, promote conservation (through a recommended ecologically sustainable development and use of natural resources, while promoting justifiable economic and social development, as outlined in the Act.

The area to be developed according to distribution of properties will require that more than 1 hectare of area be cleared. This activity will GN No. R. 983 of 2014 or GN trigger listed activities in R983 (GN 327) and is deemed to have a 327 of 2017 potential impact on natural environments and therefore requires a Basic Assessment for approval of development activities.

To ensure that the project adheres to the National Heritage National Heritage Resources Act A Notice of Intent to Develop was submitted to Resources Act (25 of 1999) Heritage Western Cape. To ensure that the project adheres to the Conservation of Agricultural Resources Act to identify necessary measures to protect agricultural Conservation of Agricultural resources the Department of Agriculture was informed of the Resources Act (43 of 1983) proposed expansion of the Bredasdorp industrial area and will be requested to comment on this Basic Assessment. No comments or commitments were received during the commenting period

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An Ecological impact assessment was completed to identify any endangered flora and fauna in the area and to determine if any Environmental nature reserves are in close proximity to the proposed project area, Conservation Ordinance as well as suggest appropriate mitigation measures to protect natural (No. 19 of 1974) flora and fauna. Cape Nature was informed of the proposed development and requested to comment on this Basic Assessment.

The IDP of the Cape Agulhas Municipality was consulted to check Cape Agulhas Municipality that the proposed project was in accordance with the goals set out Integrated Development in the document. The Municipality was informed of the proposed Plan (IDP) development and will be requested to comment on this Basic Assessment. The SDF of the Municipality was consulted to determine that the Cape Agulhas Spatial proposed project was in accordance with the goals set out in the Development Framework document. The Municipality was also informed of the proposed (SDF) extension and will be requested to comment on this Basic Assessment. The Overberg District Municipality IDP was consulted to check that Overberg District the proposed project was in accordance with the goals set out in the Municipality Integrated document. The Overberg District Municipality was informed of the Development Plan (IDP) proposed development and will be requested to comment on this Basic Assessment. DEA&DP Guidelines Application to various components in the Basic Assessment process

Note: Copies of any comments, permit(s) or licences received from any other Organ of State must be attached to this report as Appendix E.

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Section C: PUBLIC PARTICIPATION

The PPP must fulfil the requirements outlined in the NEMA, the EIA Regulations, 2014 (as amended) and if applicable, the NEM: WA and/or the NEM: AQA. This Department’s Circular EADP 0028/2014 (dated 9 December 2014) on the “One Environmental Management System” and the EIA Regulations, any subsequent Circulars, and guidelines must also be taken into account.

1. Please highlight the appropriate box to indicate whether the specific requirement was undertaken or whether there was an exemption applied for.

In terms of Regulation 41 of the EIA Regulations, 2014 (as amended) - (a) fixing a notice board at a place conspicuous to and accessible by the public at the boundary, on the fence or along the corridor of - (i) the site where the activity to which the application relates, is or is to be undertaken; EXEMPTION and YES (ii) any alternative site YES EXEMPTION N/A (b) giving written notice, in any manner provided for in Section 47D of the NEMA, to – (i) the occupiers of the site and, if the applicant is not the owner or person in control of the site on which the activity is to be undertaken, the owner or person in control of EXEMPTION N/A the site where the activity is or is to be undertaken or to any alternative site where YES the activity is to be undertaken; (ii) owners, persons in control of, and occupiers of land adjacent to the site where the activity is or is to be undertaken or to any alternative site where the activity is to be YES EXEMPTION undertaken; (iii) the municipal councillor of the ward in which the site or alternative site is situated EXEMPTION and any organisation of ratepayers that represent the community in the area; YES (iv) the municipality (Local and District Municipality) which has jurisdiction in the area; YES EXEMPTION (v) any organ of state having jurisdiction in respect of any aspect of the activity; and YES EXEMPTION (vi) any other party as required by the Department; YES EXEMPTION N/A (c) placing an advertisement in - (i) one local newspaper; or YES EXEMPTION (ii) any official Gazette that is published specifically for the purpose of providing public EXEMPTION notice of applications or other submissions made in terms of these Regulations; YES N/A (d) placing an advertisement in at least one provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the EXEMPTION boundaries of the metropolitan or district municipality in which it is or will be YES N/A undertaken (e) using reasonable alternative methods, as agreed to by the Department, in those instances where a person is desirous of but unable to participate in the process due to— EXEMPTION N/A (i) illiteracy; YES (ii) disability; or (iii) any other disadvantage. If you have indicated that “EXEMPTION” is applicable to any of the above, proof of the exemption decision must be appended to this report. Please note that for the NEM: WA and NEM: AQA, a notice must be placed in at least two newspapers circulating in the area where the activity applied for is proposed. If applicable, has/will an advertisement be placed in at least two newspapers? YES NO If “NO”, then proof of the exemption decision must be appended to this report. N/A

2. Provide a list of all the State Departments and Organs of State that were consulted:

Date request Date comment Support / not in support State Department / Organ of State was sent: received: Department of Economic Development and Tourism 01-02-2019 N/A N/A Head of Department Western Cape Agriculture 01-02-2019 N/A N/A land use section Cape Agulhas Municipality 01-02-2019 N/A N/A Cape Nature 01-02-2019 N/A N/A Department of Water and 01-02-2019 N/A N/A Sanitation Heritage Western Cape 01-02-2019 N/A N/A SANParks 01-02-2019 N/A N/A

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3. Provide a summary of the issues raised by I&APs and an indication of the manner in which the issues were incorporated, or the reasons for not including them. (The detailed outcomes of this process, including copies of the supporting documents and inputs must be included in a Comments and Response Report to be attached to the BAR (see note below) as Appendix F).

All comments received during pubic review period for the draft BAR and EMPr, are captured and recorded within the Comments and Response Report (CRR) included as Appendix F

Summary of Main Issues Raised Summary of response from CES The BGCMA indicated that they cannot CES has responded to the letter from BGCMA to inform support the application until the them that the Cape Agulhas Municipality, through a Bredasdorp WWTW were upgraded and confirmation letter submitted to CES, intends to had enough capacity to accommodate upgrade the WWTW from 2Ml/day to 4Ml/day during the proposed development. the 2019/20 financial year. The Municipality has been able to provide The DEA&DP requested that a letter to confirmation letters for the following: confirm the availability of services from the service providers be obtained and  Infrastructure Planning; included in the final BAR. A services plan  Waste and Emissions; and was also requested.  Services for proposed Bredasdorp.

A wetland specialist should be appointed to conduct CapeNature states that there is a a site visit during the wet season and verify the temporary wetland across a portion of the presence or absence of a wetland, as a condition of proposed development (erven 6236-6240) approval, and before any construction activities based on satellite imagery. commence.

4. Provide a summary of any conditional aspects identified / highlighted by any Organs of State, which have jurisdiction in respect of any aspect of the relevant activity.

No conditional aspects have been identified or highlighted by any Organs of State at this stage.

See Section C. 2 above.

Note: Even if pre-application public participation is undertaken as allowed for by Regulation 40(3), it must be undertaken in accordance with the requirements set out in Regulations 3(3), 3(4), 3(8), 7(2), 7(5), 19, 40, 41, 42, 43 and 44.

If the “exemption” option is selected above and no proof of the exemption decision is attached to this BAR, the application will be refused.

A list of all the potential I&APs, including the Organs of State, notified and a list of all the registered I&APs must be submitted with the BAR. The list of registered I&APs must be opened, maintained and made available to any person requesting access to the register in writing.

The BAR must be submitted to the Department when being made available to I&APs, including the relevant Organs of State and State Departments which have jurisdiction with regard to any aspect of the activity, for a commenting period of at least 30 days. Unless agreement to the contrary has been reached between the Competent Authority and the EAP, the EAP will be responsible for the consultation with the relevant State Departments in terms of Section 24O and Regulation 7(2) – which consultation must happen simultaneously with the consultation with the I&APs and other Organs of State.

All the comments received from I&APs on the BAR must be recorded, responded to and included in the Comments and Responses Report included as Appendix F of the BAR. If necessary, any amendments made in response to comments received must be effected in the BAR itself. The Comments and Responses Report must also include a description of the PPP followed.

The minutes of any meetings held by the EAP with I&APs and other role players wherein the views of the participants are recorded, must also be submitted as part of the public participation information to be attached to the final BAR as Appendix F.

Proof of all the notices given as indicated, as well as notice to I&APs of the availability of the Pre-Application BAR (if applicable), Draft BAR, and Revised BAR (if applicable) must be submitted as part of the public participation information to be attached to the BAR as Appendix F. In terms of the required “proof” the following must be submitted to the Department:  a site map showing where the site notice was displayed, a dated photographs showing the notice displayed on site and a copy of the text displayed on the notice;  in terms of the written notices given, a copy of the written notice sent, as well as: o if registered mail was sent, a list of the registered mail sent (showing the registered mail number, the name of the person the mail was sent to, the address of the person and the date the registered mail was sent);

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o if normal mail was sent, a list of the mail sent (showing the name of the person the mail was sent to, the address of the person, the date the mail was sent, and the signature of the post office worker or the post office stamp indicating that the letter was sent); o if a facsimile was sent, a copy of the facsimile report; o if an electronic mail was sent, a copy of the electronic mail sent; and o if a “mail drop” was done, a signed register of “mail drops” received (showing the name of the person the notice was handed to, the address of the person, the date, and the signature of the person); and  a copy of the newspaper advertisement (“newspaper clipping”) that was placed, indicating the name of the newspaper and date of publication (of such quality that the wording in the advertisement is legible).

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SECTION D: NEED AND DESIRABILITY

Note: Before completing this section, first consult this Department’s Circular EADP 0028/2014 (dated 9 December 2014) on the “One Environmental Management System” and the EIA Regulations, 2014 (as amended), any subsequent Circulars, and guidelines available on the Department’s website: http://www.westerncape.gov.za/eadp). In this regard, it must be noted that the Guideline on Need and Desirability in terms of the Environmental Impact Assessment (EIA) Regulations, 2010 published by the national Department of Environmental Affairs on 20 October 2014 (GN No. 891 on Government Gazette No. 38108 refers) (available at: http://www.gov.za/sites/www.gov.za/files/38108__891.pdf) also applied to EIAs in terms of the EIA Regulations, 2014 (as amended).

1. Is the development permitted in terms of the property’s existing land use rights? YES NO Please explain The development falls on land with undetermined zoning which is an area where no development is currently allowed without approved rezoning. The Municipality’s intention to expand the industrial area of Bredasdorp is not inconsistent with the existing land use activities of the area as the proposed site for subdivision and potential development is bordered by industries on the East across the banks of the river and by an agricultural warehouse and commercial industrial buildings on the West. 2. Will the development be in line with the following? (a) Provincial Spatial Development Framework (“PSDF”). YES NO Please explain The proposed area for development is intended for expansion of industrial economic activity. The proposed activity is aligned with the Provincial Spatial Policies (PSP) discussed in the PSDF. Policy E3 looks at the need for the revitalisation and strengthening of urban space economies as the engine of growth and Point 5 of this policy identifies the need for existing economic asset such as, but not limited to, vacant and under-utilised strategically located public land parcel to be targeted to lever the regeneration and revitalisation of urban economies. (b) Urban edge / edge of built environment for the area. YES NO Please explain The proposed development area is situated within the edge of built environment and river corridor in an industrial setting. This development/activity area falls within 1000m radius of the Bredasdorp city centre according to Cape Agulhas SDF. (c) Integrated Development Plan and Spatial Development Framework of the Local Municipality (e.g., would the approval of this application compromise the YES NO Please explain integrity of the existing approved and credible municipal IDP and SDF?). Integrated Development Plan

The CAM IDP has nine (9) strategic development objectives (SO) which are aligned to six (6) of the National KPA’s for Local Government. The third KPA recognises the need for economic development and is supported by the IDP strategic objective number four (SO 4).

SO 4 aims to facilitate economic development by creating a conducive environment for business development to unlock opportunities and increase participation amongst all sectors of society in the mainstream economy to ultimately create decent job opportunities.

The Cape Agulhas Municipality proposes an extension of the Bredasdorp industrial area and this proposed expansion is in line with the above mentioned KPA and strategic development objectives. The proposed development recognizes that an environmental assessment should be undertaken to assess the impacts that the proposed activity will have on the environment.

Spatial Development Framework

The Cape Agulhas Municipality’s Spatial Development Framework recognises the need for “an environment, space economy, and settlements in CAM which ensure justice, sustainability, efficiency, livelihood opportunity, and a rich life experience for all residents, citizens, and visitors”

The CAM SDF consist of three types of initiatives or actions; the Protective Actions, Change Actions and the New Development Actions. These initiatives or actions have accompanying strategies focus areas and proposal identified to help achieve the vision and spatial concept in all nine Municipal areas.

The Strategic focus for Bredasdorp Change Actions recognises the need for an area for enhanced economic opportunity, and is in line with SDF element for enhanced commercial or industrial accommodation for user convenience, entrepreneurship development, and work opportunity.

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The CAM municipality proposes to extend the industrial area of Bredasdorp and this is in line with SDF proposal to “enable further industrial development on Erf 1148”. (d) An Environmental Management Framework (“EMF”) adopted by this Department. (e.g., Would the approval of this application compromise the Please explain integrity of the existing environmental management priorities for the area and YES NO if so, can it be justified in terms of sustainability considerations?) The EMF is essential in early identification of biophysical and socio-economic risks of the area where the activity is being proposed. An environmental assessment is required to ensure that any negative effects the development may have on sensitive environment receptors are minimised and/or mitigated. This application is for a basic environmental impact assessment which will identify impacts and ways to minimise and mitigate negative impacts and well as optimise benefits. (e) Any other Plans (e.g., Integrated Waste Management Plan (for waste Please YES NO management activities), etc.)). explain No other plans are known at this stage 3. Is the land use (associated with the project being applied for) considered within the timeframe intended by the existing approved SDF agreed to by the relevant YES NO Please explain environmental authority (in other words, is the proposed development in line with the projects and programmes identified as priorities within the credible IDP)? The proposed extension of the Bredasdorp industrial area is consistent with the land uses in the area. The proposed site for subdivision and potential development is bordered by industries on the East across the banks of the river and by an agricultural warehouse and commercial industrial buildings on the West.

In terms of consistency with the zoning, the site within which the extension is proposed currently has no determined zoning, which means no developments are permitted without approved rezoning.

As mentioned, the proposed extension will not contradict or compromise the CAM municipality’s approved SDF and its proposals that recognise the need to “enable further industrial development on Erf 1148”. The proposed undertaking will not compromise any projects or programmes identified as priorities within the IDP. Please see 2a and 2c above. 4. Should development, or if applicable, expansion of the town/area concerned in Please terms of this land use (associated with the activity being applied for) occur on the YES NO proposed site at this point in time? explain The proposed development is situated within an active industrial region. The expansion will not cause inconsistence with the existing land uses of the area. The area proposed for expansion is also an area whose zoning is not determined and largely remains un-built. With the identified need by the Municipality to expand the Bredasdorp industrial area, the proposed area is ideal to fulfil this need without compromising the surrounding land uses at this stage. 5. Does the community/area need the project and the associated land use concerned (is it a societal priority)? (This refers to the strategic as well as local level YES NO Please explain (e.g., development is a National Priority, but within a specific local context it could be inappropriate.) The municipality and its spatial planners have identified the need for more industrial erven in the exiting industrial area. 6. Are the necessary services available together with adequate unallocated municipal capacity (at the time of application), or must additional capacity be YES NO created to cater for the project? (Confirmation by the relevant municipality in this regard must be attached to the BAR as Appendix E.) The municipality has indicated that te Waste Water treatment Plant currently has a capacity of 2Ml/day with a flow of more 2Ml. it is the intention of the Municipality to upgrade the treatment facilities to 4Ml/day over the 2019/20 financial year. The Municipality has provided confirmation that no issues are foreseen with the handling of the sewer from the proposed development.

Please see Appendix E for the confirmation from Municipality on services for proposed Bredasdorp industrial area. 7. Is this project provided for in the infrastructure planning of the municipality and if not, what will the implication be on the infrastructure planning of the municipality YES NO (priority and placement of services and opportunity costs)? (Comment by the relevant municipality in this regard must be attached to the BAR as Appendix E.) It was confirmed with the municipality that the Waste Water Treatment Plant will undergo an upgrade to 4Ml/day during the 2019/20 financial year to accommodate the growth and

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Please see Appendix E for the written confirmation on infrastructure planning for proposed Bredasdorp Industrial Area. 8. Is this project part of a national programme to address an issue of national concern NO or importance? Economic development has been identified as a national issue and Agriculture, Employment and Food Security, are key sectors for spearheading economic development. The proposed project will therefore contribute to economic development.

The National Development Plan (NDP) aims to eliminate poverty and reduce inequality by 2030. The plan focuses extensively on the notion on capabilities and the development and improvement of such capabilities to improve people’s lives. The NDP proposes the following strategies to address these goals:

1. Creating jobs and improving livelihoods; 2. Expanding infrastructure; 3. Transition to a low-carbon economy; 4. Transforming urban and rural spaces; 5. Improving education and training; 6. Providing quality health care; 7. Fighting corruption and enhancing accountability; and 8. Transforming society and uniting the nation.

The proposed project is therefore aligned with the NDP as it will see the industrial area of Bredasdorp expanded. It is anticipated that the activities that will take place in the subdivided area will lead to temporary and permanent employment opportunities. This will subsequently contribute to the improvement of livelihoods in the surrounding local community.

It is important to note that it is the intention of the Municipality to sell the subdivided area, and as such it is recommended that any developments proposed by the prospective private owner be aligned to the goals envisioned in the NDP and be consistent with the industrial setting and services in the area. 9. Do location factors favour this land use (associated with the development proposal and associated listed activity(ies) applied for) at this place? (This relates NO Please explain to the contextualisation of the proposed land use on the proposed site within its YES broader context.) The proposed undertaking is considered favourable for this location. The project entails the expansion of existing industrial area of Bredasdorp. 10. Will the development proposal or the land use associated with the development proposal applied for, impact on sensitive natural and cultural areas (built and YES NO Please explain rural/natural environment)? An ecological impact assessment was conducted to determine the sensitive natural areas, including aquatic and terrestrial areas with sensitive flora, fauna and ecosystems identified for the project area and its surroundings. A Heritage screener of the site was conducted to determine areas of cultural significance.

See Appendix G for

Ecological Sensitivity Although the site is degraded and the species diversity is lower than expected, “Portion A” of Erf 1148 still functions as an important terrestrial and aquatic ecological corridor through the town of Bredasdorp, linking the natural areas (and CBA2 areas) to the north-west of the town to the areas in the south-east. As such, this site is considered to be of moderate sensitivity. Heritage Sensitivity There were no sensitive cultural or heritage sites such as grave sites, rural areas, areas used for cultural practices or other such cultural environments identified within the project footprint. 11. Will the development impact on people’s health and well-being (e.g., in terms YES NO Please explain of noise, odours, visual character and ‘sense of place’, etc.)?

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The proposed expansion is not anticipated to negatively impact on people’s health or wellbeing. The project will not generate significant noise, odours or waste. The expansion is consistent with the surrounding land use and will not detract from the sense of place of the area. 12. Will the proposed development or the land use associated with the proposed YES NO Please explain development applied for, result in unacceptable opportunity costs? The proposed activity is not expected to result in an unacceptable opportunity cost. The current land use of the property portions under application will continue and the expansion of the industrial area will not compromise these.

The proposed activity entails the expansion of an existing lawful land use. The proposed location for expanding the industrial area is also highly favourable from an economic perspective.

The opportunity cost of expanding the Bredasdorp industrial area as opposed to implementing the no-go option must be considered due to the potential impacts on the aquatic and terrestrial flora, fauna and ecosystem processes in comparison to no impacts. These potential impacts, described in Section G, are weighed against the benefits associated with the proposed development. The negative impacts are expected to be lowered once mitigation measures have been implemented. The opportunity cost is therefore considered to be relatively insignificant. 13. What will the cumulative impacts (positive and negative) of the proposed land use associated with the development proposal and associated listed activity(ies) applied for, be? No cumulative impacts have been noted at this stage of proposed development. Based on the ecological assessment’s findings, the activity does not appear to have any cumulative impacts associated with it. The proposed project is for the expansion of already existing industrial area and the proposed site is not expected to compromise the consistency of surrounding land uses. 14. Is the development the best practicable environmental option for this land/site? YES NO Please explain By not compromising the area’s land uses, the proposed development will increase the sustainability of the industrial operations which are consistent with the current land use on the property and surrounding areas. The majority of the proposed site is already degraded and transformed by existing illegal dumping activities and industrial activities surrounding it. 15. What will the benefits be to society in general and to the local communities? Please explain Job creation and economic development are essential for the survival of local municipalities. The proposed expansion of the industrial area will therefore feed into these two essential areas of survival during the construction and operation phases of development.

Results from growing local economies and access to job opportunities also mean the socio- economic status of the locals within the municipality will be improved and it is expected that this

Therefore, the identified need by municipality and its spatial planners for more industrial erven in the exiting industrial area should be regarded as initiatives that will grow the local municipality and its society in general. 16. Any other need and desirability considerations related to the proposed development? Please explain None at this stage. 17. Describe how the general objectives of Integrated Environmental Management as set out in Section 23 of the NEMA have been taken into account: This report has identified and assessed potential impacts associated with the proposed expansion of the Bredasdorp industrial area, which is in line with S23 requirements. The requirements for Public Participation were considered and have been addressed, which at the time of writing this report will reflect that no comments have been received from various stakeholders and IAPs, including all tiers of government and relevant line function departments. The associated EMPr for the project has taken the assessment findings into consideration and appropriate management and mitigation measures are detailed therein. 18 Describe how the principles of environmental management as set out in Section 2 of the NEMA have been taken into account: The principles of environmental management, as set out in Sections 2, of the NEMA (No. 107 of 1998) are considered throughout this environmental impact assessment process.

Impacts associated with the proposed project are herewith identified, assessed and appropriate mitigation measures proposed in order to achieve maximum sustainability. Construction and operational management and mitigation measures, based on anticipated impacts, are included in the attached EMPr to assist in ensuring sustainable development.

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This process also provides potential I&AP’s, key stakeholders and state departments with adequate opportunity for comment, review and input on the process and available documentation. Details of the Public Participation Process undertaken are described in Section C

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SECTION E: DETAILS OF ALL THE ALTERNATIVES CONSIDERED

The EIA Regulations, 2014 (as amended) defines “alternatives” as “ in relation to a proposed activity, means different means of fulfilling the general purpose and requirements of the activity, which may include alternatives to the— (a) property on which or location where the activity is proposed to be undertaken; (b) type of activity to be undertaken; (c) design or layout of the activity; (d) technology to be used in the activity; or (e) operational aspects of the activity; (f) and includes the option of not implementing the activity;”

The NEMA (section 24(4)(a) and (b) of the NEMA, refers) prescribes that the procedures for the investigation, assessment and communication of the potential consequences or impacts of activities on the environment must, inter alia, with respect to every application for environmental authorisation –  ensure that the general objectives of integrated environmental management laid down in the NEMA and the National Environmental Management Principles set out in the NEMA are taken into account; and  include an investigation of the potential consequences or impacts of the alternatives to the activity on the environment and assessment of the significance of those potential consequences or impacts, including the option of not implementing the activity.

The general objective of integrated environmental management (section 23 of NEMA, refers) is, inter alia, to “identify, predict and evaluate the actual and potential impact on the environment, socio-economic conditions and cultural heritage, the risks and consequences and alternatives and options for mitigation of activities, with a view to minimising negative impacts, maximising benefits, and promoting compliance with the principles of environmental management” set out in the NEMA.

The identification, evaluation, consideration and comparative assessment of alternatives directly relate to the management of impacts. Related to every identified impact, alternatives, modifications or changes to the activity must be identified, evaluated, considered and comparatively considered to:  in terms of negative impacts, firstly avoid a negative impact altogether, or if avoidance is not possible alternatives to better mitigate, manage and remediate a negative impact and to compensate for/offset any impacts that remain after mitigation and remediation; and  in terms of positive impacts, maximise impacts.

1. DETAILS OF THE IDENTIFIED AND CONSIDERED ALTERNATIVES AND INDICATE THOSE ALTERNATIVES THAT WERE FOUND TO BE FEASIBLE AND REASONABLE

Note: A full description of the investigation of alternatives must be provided and motivation if no reasonable or feasible alternatives exists.

(a) Property and location/site alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

The preferred location for the activity has been chosen primarily because the proposed subdivided Portion A is under the Municipality’s ownership and borders the existing industrial area. For these reasons, location alternatives have not been considered in the Basic Assessment and the preferred alternative is the only alternative that was assessed.

(b) Activity alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

This application is for the expansion of the existing Bredasdorp industrial area. As such, the proposed activity is aligned with existing land uses and does not require or warrant the assessment of activity alternatives.

(c) Design or layout alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

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Since the Municipality intends on selling or auctioning the proposed property (Portion A) to a private developer, the design, layout plans as well as detailed service infrastructure plans associated with any specific development (that is consistent with the existing activities) have not been provided by the Municipality, which is still in possession of the proposed land parcel. It is noted that the proposed 14 erven are an extension of the exiting industrial area, with the proposed subdivision layout consistent with the spatial planning approaches adopted for the existing industrial area. Accordingly, the assessment or consideration of layout alternatives will not change the significance of the anticipated impacts.

(d) Technology alternatives (e.g., to reduce resource demand and increase resource use efficiency) to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

No technology alternatives are being considered as part of this proposal.

(e) Operational alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

No operational alternative exsist for this proposed industrial expansion.

(f) The option of not implementing the activity (the ‘No-Go’ Option):

The no-go option is assessed in this Basic Assessment process as the option of not implementing the proposed activity. This implies that the proposed extension of the Bredasdorp industrial area would not go ahead.

According to the ecological study conducted, the 14 erven are located on the western boundary of “Portion A” and the developmental footprint is fairly small (20%). Provided that the development is limited to this area, the impacts associated with fragmentation will be limited and it is unlikely that the current ecological processes provided by the corridor will be heavily impacted by the development itself

It was confirmed during the site visit that the area is also being used for illegal dumping for domestic and garden waste. Therefore, the No-Go option would result in continuous use of the site for illegal dumping activities.

(g) Other alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

No other alternatives considered at this stage.

(h) Provide a summary of all alternatives investigated and the outcome of each investigation:

Only the preferred alternative was investigated for this Basic assessment. Site sensitivities were investigated through specialist studies undertaken for this process (Ecological and Heritage Specialist assessments).

The outcome of the Ecological assessment noted that though the area falls within the Ecological Support Area (ESA) 2 which connects to the CBA’s in the northwest with the CBAs in the southeast, the site is degraded and existing vegetation that occurs on site is transformed as the site used as a walkway from the R319 (Swellendam Road) to the homes situated along the south-western boundary of the site. This area is also used as an illegal dumping site for garden refuse and domestic waste.

Heritage study that was undertaken noted that given the disturbed nature of the area proposed for development, was unlikely that significant fossil resources will be impacted by the development.

(i) Provide a detailed motivation for not further considering the alternatives that were found not feasible and reasonable, including a description and proof of the investigation of those alternatives:

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2. PREFERRED ALTERNATIVE

(a) Provide a concluding statement indicating the preferred alternative(s), including preferred location, site, activity and technology for the development.

As above.

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SECTION F: ENVIRONMENTAL ASPECTS ASSOCIATED WITH THE ALTERNATIVES

Note: The information in this section must be DUPLICATED for all the feasible and reasonable ALTERNATIVES.

1. DESCRIBE THE ENVIRONMENTAL ASPECTS ASSOCIATED WITH THE PROPOSED DEVELOPMENT AND ITS ALTERNATIVES, FOCUSING ON THE FOLLOWING:

(a) Geographical, geological and physical aspects:

The proposed expansion of the Bredasdorp industrial area will promote the industrial activities and footprint on the west side of the overall industrial area.

Within the 100m of the proposed development area, there is an existing stream that run through the edge of the proposed site. The majority of the vegetation within the proposed site is transformed. The riparian vegetation on the banks of the stream are covered to be natural vegetation. The footprint of the proposed area of development covers approximately 20 282 m2 of Central Ruens Shale Renosterveld.

Considering that the proposed development site is situated near the existing R319, it is anticipated and recommended that no new roads will be constructed, only existing roads be used during construction and operation phases.

(b) Ecological aspects:

Will the proposed development and its alternatives have an impact on CBAs or ESAs? If yes, please explain: YES NO Also include a description of how the proposed development will influence the quantitative values (hectares/percentage) of the categories on the CBA/ESA map.

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CBAs are considered to be essential in terms of meeting biodiversity targets, and in terms of maintaining current levels of ecological connectivity across an already fragmented landscape. This site occurs along the banks of the Droë River and forms part of a natural ecological corridor that links the CBA’s in the north-west with the CBAs in the south-east of the study area.

ESAs are “Areas that are not essential for meeting biodiversity targets, but that play a supporting role in the functioning of protected areas or CBAs, and are often vital for delivering ecosystem services”. Portion A of Erf 1148 occurs in an Ecological Support Area (ESA) 2 and the site is considered to be of moderate sensitivity due to the important ecological processes it performs.

Figure 1.1: Critical Biodiversity and Ecological Support Areas Will the proposed development and its alternatives have an impact on terrestrial vegetation, or aquatic ecosystems (wetlands, estuaries or the coastline)? YES NO If yes, please explain:

Will the proposed development and its alternatives have an impact on any populations of threatened plant or animal species, and/or on any habitat that may contain a unique signature of plant or animal species? YES NO If yes, please explain: During the site visit, it was noted that one vegetation types occurring within the project area is considered Critically Endangered (Central Rûens Shale Renosterveld) within which the entire proposed area of development fell.

Only one plant species (Ruschia cf lineolata) of conservation concern, which is listed as Schedule 4 species on the PNCO list, was recorded. This species will require permits for their destruction. Describe the manner in which any other biological aspects will be impacted: N/A Will the proposed development also trigger section 63 of the NEM: ICMA? YES NO

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If yes, describe the following: (i) the extent to which the applicant has in the past complied with similar authorisations; (ii) whether coastal public property, the coastal protection zone or coastal access land will be affected, and if so, the extent to which the proposed development proposal or listed activity is consistent with the purpose for establishing and protecting those areas; (iii) the estuarine management plans, coastal management programmes, coastal management lines and coastal management objectives applicable in the area; (iv) the likely socio-economic impact if the listed activity is authorised or is not authorised; (v) the likely impact of coastal environmental processes on the proposed development; (vi) whether the development proposal or listed activity— (a) is situated within coastal public property and is inconsistent with the objective of conserving and enhancing coastal public property for the benefit of current and future generations; (b) is situated within the coastal protection zone and is inconsistent with the purpose for which a coastal protection zone is established as set out in section 17 of NEM: ICMA; (c) is situated within coastal access land and is inconsistent with the purpose for which coastal access land is designated as set out in section 18 of NEM: ICMA; (d) is likely to cause irreversible or long-lasting adverse effects to any aspect of the coastal environment that cannot satisfactorily be mitigated; (e) is likely to be significantly damaged or prejudiced by dynamic coastal processes; (f) would substantially prejudice the achievement of any coastal management objective; or (g) would be contrary to the interests of the whole community; (vii) whether the very nature of the proposed activity or development requires it to be located within coastal public property, the coastal protection zone or coastal access land; (viii) whether the proposed development will provide important services to the public when using coastal public property, the coastal protection zone, coastal access land or a coastal protected area; and (ix) the objects of NEM: ICMA, where applicable. N/A

What is the expected capital value of the project on completion? Not determined R What is the expected yearly income or contribution to the economy that will be generated by or as a R result of the project? Not determined Will the project contribute to service infrastructure? Not determined YES NO Is the project a public amenity? Not determined YES NO How many new employment opportunities will be created during the development phase? Not determined at this stage What is the expected value of the employment opportunities during the development phase? R What percentage of this will accrue to previously disadvantaged individuals? Not determined % How will this be ensured and monitored (please explain): Not determined How many permanent new employment opportunities will be created during the operational phase of Not the project? determined What is the expected current value of the employment opportunities during the first 10 years? Not R determined What percentage of this will accrue to previously disadvantaged individuals? Not determined % How will this be ensured and monitored (please explain): Not determined Any other information related to the manner in which the socio-economic aspects will be impacted: None at this stage

(d) Heritage and Cultural aspects:

No known significant cultural or historical aspects. Refer to Heritage Screener in Appendix G

2. WASTE AND EMISSIONS

(a) Waste (including effluent) management

Will the development proposal produce waste (including rubble) during the development phase? YES NO If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and m3 estimated quantity per type?

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It is our understanding that the Municipality intends to have the proposed properties sold to private developer(s). Therefore at this stage of the assessment, no waste streams are anticipated to be produced from activities proposed on site. Not Any waste streams that may be generated will depend on the type of industry the determined prospective owner of the property or properties will propose, and the volumes can only be determined at a later stage (development stage of the project).

Will the development proposal produce waste during its operational phase? YES NO If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and m3 estimated quantity per type? Not Same as above (not known at this stage) determined

Will the development proposal require waste to be treated / disposed of on site? YES NO If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and m3 estimated quantity per type per phase of the proposed development to be treated/disposed of? Not Same as above determined If no, where and how will the waste be treated / disposed of? Please explain. Indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated m3 quantity per type per phase of the proposed development to be treated/disposed of? Not Same as above determined Has the municipality or relevant authority confirmed that sufficient capacity exists for treating / disposing of the waste to be generated by the development proposal? YES NO If yes, provide written confirmation from the municipality or relevant authority.

Will the development proposal produce waste that will be treated and/or disposed of at another facility YES NO other than into a municipal waste stream? Not determined

If yes, has this facility confirmed that sufficient capacity exists for treating / disposing of the waste to be generated by the development proposal? YES NO Provide written confirmation from the facility. Confirmation request email sent to client Does the facility have an operating license? (If yes, please attach a copy of the licence.) Not YES NO applicable Facility name: Contact person: Cell: Postal address: Telephone: Postal code: Fax: E-mail:

Describe the measures that will be taken to reduce, reuse or recycle waste: N/A

(b) Emissions into the atmosphere

Will the development proposal produce emissions that will be released into the atmosphere? YES NO If yes, does this require approval in terms of relevant legislation? YES NO If yes, what is the approximate volume(s) of emissions released into the atmosphere? m3 Describe the emissions in terms of type and concentration and how these will be avoided/managed/treated/mitigated: Same as above (not known at this stage)

3. WATER USE

(a) Indicate the source(s) of water for the development proposal by highlighting the appropriate box(es).

River, Stream, The project will Municipal Water board Groundwater Other Dam or Lake not use water Not known at this stage of the process

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Note: Provide proof of assurance of water supply (e.g. Letter of confirmation from the municipality / water user associations, yield of borehole)

(b) If water is to be extracted from a groundwater source, river, stream, dam, lake or any Not m3 other natural feature, please indicate the volume that will be extracted per month: determined

(c) Does the development proposal require a water use permit / license from DWS? YES NO If yes, please submit the necessary application to the DWS and attach proof thereof to this application as an Appendix.

(d) Describe the measures that will be taken to reduce water demand, and measures to reuse or recycle water:

Not known at this stage as this will depend on the specific proposed development on the properties by the prospective private developer

4. POWER SUPPLY

(a) Describe the source of power e.g. municipality / Eskom / renewable energy source.

Municipality

(b) If power supply is not available, where will power be sourced?

N/A

5. ENERGY EFFICIENCY

(a) Describe the design measures, if any, that have been taken to ensure that the development proposal will be energy efficient:

Not known at this stage as this will depend on the specific proposed development on the properties by the prospective private developer.

(b) Describe how alternative energy sources have been taken into account or been built into the design of the project, if any:

Not known at this stage as this will depend on the specific proposed development on the properties by the prospective private developer. At this point of the assessment, no design plans have been made available.

6. TRANSPORT, TRAFFIC AND ACCESS

Describe the impacts in terms of transport, traffic and access.

The property is accessed from the R319 (Swellendam Rd) and the proposed site will be accessed via existing internal roads. It is our understanding that these roads are able to accommodate vehicles associated with the construction phase. It is anticipated that the potential traffic impact would be negligible.

7. NUISANCE FACTOR (NOISE, ODOUR, etc.)

Describe the potential nuisance factor or impacts in terms of noise and odours.

None anticipated.

Note: Include impacts that the surrounding environment will have on the proposed development.

8. OTHER

N/A

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SECTION G: IMPACT ASSESSMENT, IMPACT AVOIDANCE, MANAGEMENT, MITIGATION AND MONITORING MEASURES

a. METHODOLOGY USED IN DETERMINING AND RANKING ENVIRONMENTAL IMPACTS AND RISKS ASSOCIATED WITH THE ALTERNATIVES

(a) Describe the methodology used in determining and ranking the nature, significance consequences, extent, duration and probability of potential environmental impacts and risks associated with the proposed development and alternatives.

The assessment methods used include the desktop analysis of the site, a site visit and identification of impacts. The identified impacts were then assessed using the CES impact assessment methodology as described below. These assessment methods are considered to be adequate for the basic assessment report.

Impact Assessment Methodology

Four factors need to be considered when assessing the significance of impacts, namely: 1. Relationship of the impact to temporal scales - the temporal scale defines the significance of the impact at various time scales, as an indication of the duration of the impact.

2. Relationship of the impact to spatial scales - the spatial scale defines the physical extent of the impact.

3. The severity of the impact - the severity/beneficial scale is used in order to scientifically evaluate how severe negative impacts would be, or how beneficial positive impacts would be on a particular affected system (for ecological impacts) or a particular affected party. The severity of impacts can be evaluated with and without mitigation in order to demonstrate how serious the impact is when nothing is done about it. The word ‘mitigation’ means not just ‘compensation’, but includes concepts of containment and remedy. For beneficial impacts, optimization means anything that can enhance the benefits. However, mitigation or optimization must be practical, technically feasible and economically viable.

4. The likelihood of the impact occurring - the likelihood of impacts taking place as a result of project actions differs between potential impacts. There is no doubt that some impacts could occur (e.g. loss of vegetation), but other impacts are not as likely to occur (e.g. vehicle accident), and may or may not result from the proposed development. Although some impacts may have a severe effect, the likelihood of them occurring may affect their overall significance.

Each criterion (Table G1) is ranked with scores to determine the overall significance of an activity. The criterion is then considered in two categories, viz. effect of the activity and the likelihood of the impact. The total scores recorded for the effect and likelihood are then read off the matrix presented in Table 2, to determine the overall significance of the impact (Table G3). The overall significance is either negative or positive.

The environmental significance scale is an attempt to evaluate the importance of a particular impact. This evaluation needs to be undertaken in the relevant context, as an impact can either be ecological or social, or both. The evaluation of the significance of an impact relies heavily on the values of the person making the judgment. For this reason, impacts of especially a social nature need to reflect the values of the affected society.

Prioritising The evaluation of the impacts, as described above is used to prioritise which impacts require mitigation measures.

Negative impacts that are ranked as being of “VERY HIGH” and “HIGH” significance will be investigated further to determine how the impact can be minimised or what alternative activities or

BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) – October 2017 Page 48 of 124 mitigation measures can be implemented. These impacts may also assist decision makers i.e. numerous HIGH negative impacts may bring about a negative decision.

For impacts identified as having a negative impact of “MODERATE” significance, it is standard practice to investigate alternate activities and/or mitigation measures. The most effective and practical mitigations measures will then be proposed.

For impacts ranked as “LOW” significance, no investigations or alternatives will be considered. Possible management measures will be investigated to ensure that the impacts remain of low significance.

Table G1: Ranking of Evaluation Criteria Temporal Scale Short term Less than 5 years Medium term Between 5-20 years Between 20 and 40 years (a generation) and from a human Long term perspective also permanent Over 40 years and resulting in a permanent and lasting change that will Permanent always be there Spatial Scale Localised At localised scale and a few hectares in extent Study Area The proposed site and its immediate environs Regional District and Provincial level National Country International Internationally Severity Severity Benefit Slight impacts on the affected Slightly beneficial to the affected Slight system(s) or party(ies) system(s) and party(ies) Moderate impacts on the affected Moderately beneficial to the Moderate system(s) or party(ies) affected system(s) and party(ies) Severe/ Severe impacts on the affected A substantial benefit to the Beneficial system(s) or party(ies) affected system(s) and party(ies) Very Severe/ Very severe change to the A very substantial benefit to the

EFFECT Beneficial affected system(s) or party(ies) affected system(s) and party(ies)

Likelihood Unlikely The likelihood of these impacts occurring is slight May Occur The likelihood of these impacts occurring is possible Probable The likelihood of these impacts occurring is probable

LIKELIHOOD Definite The likelihood is that this impact will definitely occur

* In certain cases it may not be possible to determine the severity of an impact thus it may be determined: Don’t know/Can’t know

Table G2: Matrix used to determine the overall significance of the impact based on the likelihood and effect of the impact Effect 3 4 5 6 7 8 9 10 11 12 13 14 15 16 1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 2 5 6 7 8 9 10 11 12 13 14 15 16 17 18 3 6 7 8 9 10 11 12 13 14 15 16 17 18 19 4 7 8 9 10 11 12 13 14 15 16 17 18 19 20

Likelihood

Table G3: Description of Environmental Significance Ratings and associated range of scores Significance Description Score Rate Low An acceptable impact for which mitigation is desirable but not 4-8 essential. The impact by itself is insufficient even in combination with other low impacts to prevent the development being approved.

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These impacts will result in either positive or negative medium to short term effects on the social and/or natural environment. Moderate An important impact which requires mitigation. The impact is 9-12 insufficient by itself to prevent the implementation of the project but which in conjunction with other impacts may prevent its implementation. These impacts will usually result in either a positive or negative medium to long-term effect on the social and/or natural environment. High A serious impact, if not mitigated, may prevent the implementation of 13-16 the project (if it is a negative impact). These impacts would be considered by society as constituting a major and usually a long-term change to the (natural &/or social) environment and result in severe effects or beneficial effects. Very High A very serious impact which, if negative, may be sufficient by itself to 17-20 prevent implementation of the project. The impact may result in permanent change. Very often these impacts cannot be mitigated and usually result in very severe effects, or very beneficial effects.

(b) Please describe any gaps in knowledge.

There are no known gaps of knowledge in this report. All required information has been provided by the applicant, engineers and specialists.

The following assumptions are applicable to the studies undertaken within this Basic Assessment Process:

 This basic assessment report and supporting documentation was compiled under the impression that all information provided by the Applicant to CES Coastal and Environmental Services was correct, accurate and valid at the time it was provided.

 It is our Assumption that in an event of a positive outcome of this Basic Assessment and anticipated land purchase by prospective private owner, any construction, operation and decommissioning activities will be conducted in an environmentally responsible manner.

It is assumed that Stakeholders and Interested and Affected Parties notified during the public participation process will submit all relevant comments within the designated 30days review and comment period, so that these can included in the Final BAR and can be timeously submitted to DEAD&DP.

(d) Please describe the uncertainties.

None. This report has been compiled with a high degree of certainty and is based on the applicant’s, EAPs’ and specialists’ expertise.

(e) Describe adequacy of the assessment methods used.

The assessment methods used adhere to the strict guidelines stipulated by the DEA&DP and include the following:

 Site visits in order to determine the nature and sensitivity of the site and the surrounding environment.  Consultation with the Applicant to gain an understanding of the need and desirability for the proposed activity.  Obtaining botanical input from a botanical/Ecological specialist.  Obtaining cultural input from Heritage Western Cape through Heritage Specialist  Consulting with the DEA&DP.

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 Consideration of the applicable Legislation, Guidelines and Policies.

The assessment methods proved adequate to determine the nature and extent of all potential impacts on the environment that would be associated with the proposed development.

b. IDENTIFICATION, ASSESSMENT AND RANKING OF IMPACTS TO REACH THE PROPOSED ALTERNATIVES INCLUDING THE PREFERRED ALTERNATIVE WITHIN THE SITE

Note: In this section the focus is on the identified issues, impacts and risks that influenced the identification of the alternatives. This includes how aspects of the receiving environment have influenced the selection.

(a) List the identified impacts and risks for each alternative.

for example, choose from: geology / geohydrological / ecological / socio-economic / heritage and Alternative 1: cultural-historical / noise / visual / etc. Alternative 1 (current/preferred site):

Property alternative –

The proposed property was the only alternative assessed in the EIA as the applicant owns this property and an alternative property is therefore not practically or financially viable. As such this is the only property that is available for the applicant to utilise.

Site alternative –

The Municipality’s expansions are proposed to occur only on this site and therefore, no alternative site Preferred Site has been proposed or considered on this assessment.

Activity alternative (land use) –

The proposed activity for the site was the only alternative assessed in terms of different land use options. The proposed development is for the expansion of an existing industrial area in Bredasdorp. The Applicant (Municipality) requires the proposed expansion of the Industrial area to increase economic activities and productive use of existing Municipal land. Therefore, no feasible or reasonable activity alternatives exist.

Please refer to SECTION G (b) for an assessment of identified impacts and risks for the preferred site or Alternative 1 for example, choose from: geology / geohydrological / ecological / socio-economic / heritage and Alternative 2: cultural-historical / noise / visual / etc. for example, choose from: geology / geohydrological / ecological / socio-economic / heritage and Alternative x: cultural-historical / noise / visual / etc. No-go Alternative:

(b) Describe the impacts and risks identified for each alternative, including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts can be reversed; may cause irreplaceable loss of resources; and can be avoided, managed or mitigated.

The following table serves as a guide for summarising each alternative. The table should be repeated for each alternative to ensure a comparative assessment. (The EAP has to select the relevant impacts identified in blue in the table below for each alternative and repeat the table for each impact and risk).

Geology / geohydrological / ecological / socio-economic / Alternative 1 : heritage and cultural-historical / noise / visual / etc. PLANNING, DESIGN AND CONSTRUCTION PHASE Potential impact and risk: 1. Loss of Vegetation Communities a. Loss of Degraded Renosterveld

Nature of impact: Approximately 2.4 ha of degraded renosterveld will be lost as a result of clearing for the construction of the road and buildings anticipated for the 14 erven. No loss of the riparian vegetation is anticipated. Extent and duration of impact: Localised and Permanent Approximately 2.4 ha of degraded renosterveld will be lost as a Consequence of impact or risk: result of clearing for the construction of the road and buildings anticipated for the 14 erven. Probability of occurrence: Definite Degree to which the impact may cause Moderate irreplaceable loss of resources:

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Degree to which the impact can be reversed: Irreversible Indirect impacts: N/A Cumulative impact prior to mitigation: No cumulative impacts identified Significance rating of impact prior to mitigation (e.g. Low, Medium, Medium-High, High, or Very- Moderate (-) High) Degree to which the impact can be avoided: Low Degree to which the impact can be managed: Medium Degree to which the impact can be mitigated: Medium  Clearing must be kept to a minimum.  Top soil (20 cm, where possible) must be collected and used elsewhere on the property and for the rehabilitation of lay down areas and other impacted areas no longer required during the operational phase. Proposed mitigation:  Lay down areas must not be located in the riparian vegetation.  Employees must be prohibited from making fires.  An alien management plan must be designed and implemented to prevent the spread of alien species. Residual impacts: N/A Cumulative impact post mitigation: No cumulative impacts identified Significance rating of impact after mitigation (e.g. Low, Medium, Medium-High, High, or Very- Moderate (-) High)

Potential impact and risk: 2. Loss of Biodiversity a. Loss of biodiversity

Clearing for the construction of the project infrastructure will result in the loss of general biodiversity. However, given that a large portion Nature of impact: of the individuals present at the site are alien species, and the species diversity is relatively low, the severity of the impact will be moderate with an overall significance of moderate negative

Extent and duration of impact: Study Area, Localised and Permanent Clearing for the construction of the project infrastructure will result in Consequence of impact or risk: the loss of general biodiversity Probability of occurrence: Definite without mitigation, Probable with mitigation Degree to which the impact may cause Moderate irreplaceable loss of resources: Degree to which the impact can be reversed: Low Indirect impacts: N/A Cumulative impact prior to mitigation: Not assessed Significance rating of impact prior to mitigation (e.g. Low, Medium, Medium-High, High, or Very- Moderate (-) High) Degree to which the impact can be avoided: Low Degree to which the impact can be managed: Moderate Degree to which the impact can be mitigated: Moderate  Alien invasive species should be removed from the areas where development will not occur. The area should be actively managed to prevent the return of alien invasive species.  Prohibit all employees from harvesting plants; Proposed mitigation:  Prohibit open fires;  An ECO must be employed to demarcate areas for use during construction, and to ensure that the construction activities remain within the designated area and that no unauthorised activities occur outside of the construction footprint. Residual impacts: N/A Cumulative impact post mitigation: Not assessed Significance rating of impact after mitigation (e.g. Low, Medium, Medium-High, High, or Very- Low (-) High)

Potential impact and risk: 3. Loss of Species of Conservation Concern

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a. Loss of Species of Conservation Concern

One species listed as a Schedule 4 species on the Western Cape PNCO was recorded at the site. However, this species is listed as Least Concern by the South African Red Data List.

Nature of impact: There may be a few geophytes that went undetected due to the time of year the assessment was done. Clearing for the construction of the project infrastructure could result in the loss of some of these species but this is unlikely to affect the population’s survival given the small area that will be affected. The overall significance of the impact is therefore low. Extent and duration of impact: Localised and Permanent Clearing for the construction of the project infrastructure could result Consequence of impact or risk: in the loss of some of the species of conservation concern Probability of occurrence: Probable Degree to which the impact may cause Low irreplaceable loss of resources: Degree to which the impact can be reversed: Moderate Indirect impacts: N/A Cumulative impact prior to mitigation: Not assessed Significance rating of impact prior to mitigation (e.g. Low, Medium, Medium-High, High, or Very- Low (-) High) Degree to which the impact can be avoided: Low Degree to which the impact can be managed: Moderate Degree to which the impact can be mitigated: Low  Alien invasive species should be removed from the areas where development will not occur. The area should be actively managed to prevent the return of alien invasive species.  Prohibit all employees from harvesting plants;  Prohibit open fires;  An ECO must be employed to demarcate areas for use during construction, and to ensure that the construction activities remain within the designated area and that no Proposed mitigation: unauthorised activities occur outside of the construction footprint.  Destruction or removal of the SCC such as Ruschia cf lineolate recorded on the proposed site requires that a plant removal permit be obtained from competent authorities. CapeNature is the responsible commenting and competent authority with which the removal application must be logged and processed before removal of this species. Residual impacts: N/A Cumulative impact post mitigation: Not assessed Significance rating of impact after mitigation (e.g. Low, Medium, Medium-High, High, or Very- Low (-) High)

Potential impact and risk: 4. Habitat Fragmentation a. Habitat Fragmentation

Fragmentation is one of the most important impacts on vegetation as it creates breaks in previously continuous vegetation, causing a reduction in the gene pool and a decrease in species richness and diversity. This impact occurs when more and more areas are cleared for agriculture and development resulting in the isolation of functional ecosystems, which results in reduced biodiversity and Nature of impact: reduced movement due to the absence of ecological corridors.

Edge effects may occur along the boundary of development and roads which may further compound the impacts associated with fragmentation and further reduce population numbers to below sustainable thresholds, potentially causing local extinctions.

The proposed development will occur in an important, existing corridor that links natural habitat to the south and north of

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Bredasdorp. Development in this area will result in further habitat fragmentation in an already fragmented area. However, if the development is restricted to the 14 proposed erven, located on the edge of Section A of erf 1148, the corridor can continue to support existing ecological processes since only a small portion (2.4ha) will be permanently lost. Extent and duration of impact: Regional without mitigation and Study Area with mitigation Consequence of impact or risk: Loss of approximately 2.4 hectares through habitat fragmentation Probability of occurrence: Definite Degree to which the impact may cause Moderate irreplaceable loss of resources: Degree to which the impact can be reversed: Moderate Indirect impacts: N/A Cumulative impact prior to mitigation: Not assessed Significance rating of impact prior to mitigation (e.g. Low, Medium, Medium-High, High, or Very- Moderate (-) High) Degree to which the impact can be avoided: Moderate Degree to which the impact can be managed: High Degree to which the impact can be mitigated: High  The project infrastructure must be located along the boundary near existing infrastructure  An ecological corridor between the north and south of the site must be delineated in consultation with the landowner Proposed mitigation: and designated as a permanent ecological corridor within which there is a commitment that no further development will occur. It is recommended that this corridor incorporates the river and 32m either side of the river where feasible. Residual impacts: N/A Cumulative impact post mitigation: Not assessed Significance rating of impact after mitigation (e.g. Low, Medium, Medium-High, High, or Very- Low (-) High)

Potential impact and risk: 5. Invasion of Invasive Alien Plant Species a. Invasion of Invasive Alien Plant Species

The site is already infested with invasive alien species and other weedy species. Further disruption of the site could exacerbate the Nature of impact: infestation of alien species unless these are controlled for. Areas that are disturbed during the construction phase are vulnerable to infestations unless rehabilitated to prevent invasive alien plant species from establishing themselves.

Study Area without mitigation, Localised with mitigation and Extent and duration of impact: Permanent Areas that are disturbed during the construction phase are Consequence of impact or risk: vulnerable to infestations and could exacerbate the infestation of alien species. Probability of occurrence: Definite Degree to which the impact may cause Low irreplaceable loss of resources: Degree to which the impact can be reversed: Moderate Indirect impacts: N/A Cumulative impact prior to mitigation: Not assessed Significance rating of impact prior to mitigation (e.g. Low, Medium, Medium-High, High, or Very- Moderate (-) High) Degree to which the impact can be avoided: Moderate Degree to which the impact can be managed: Moderate Degree to which the impact can be mitigated: Moderate  An invasive alien plant management plan must be designed and implemented to remove the alien species Proposed mitigation: within the subdivided “Portion A”. This plan must designate management units and prescribe the most effective method of removing the species Residual impacts: N/A Cumulative impact post mitigation: Not assessed

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Significance rating of impact after mitigation (e.g. Low, Medium, Medium-High, High, or Very- Low (-) High)

OPERATIONAL PHASE Potential impact and risk: 6. Degradation of the site due to poor management a. Degradation of the site due to poor management

The site may be further degraded if the site is not managed effectively during the operational phase. For example, the invasive Nature of impact: alien plant species not being actively removed, increased erosion is occurring as a result of poor storm water management and illegal harvesting of plant material is occurring within the site.

Extent and duration of impact: Study Area and Permanent Consequence of impact or risk: Site degradation resulting from poor or mismanagement of the site Probability of occurrence: Definite Degree to which the impact may cause High irreplaceable loss of resources: Degree to which the impact can be reversed: Moderate Indirect impacts: Cumulative impact prior to mitigation: Not Assessed Significance rating of impact prior to mitigation (e.g. Low, Medium, Medium-High, High, or Very- High (-) High) Degree to which the impact can be avoided: High Degree to which the impact can be managed: Moderate Degree to which the impact can be mitigated: High  An invasive alien management plan must be put in place if Proposed mitigation: one doesn’t already exist.  A stormwater management plan must be implemented Residual impacts: N/A Cumulative impact post mitigation: Not assessed Significance rating of impact after mitigation (e.g. Low, Medium, Medium-High, High, or Very- Low (-) High)

DECOMMISSIONING AND CLOSURE PHASE- Potential impact and risk: Nature of impact: Not Assessed Extent and duration of impact: Not Assessed Consequence of impact or risk: Not Assessed Probability of occurrence: Not Assessed Degree to which the impact may cause Not Assessed irreplaceable loss of resources: Degree to which the impact can be reversed: Not Assessed Indirect impacts: Not Assessed Cumulative impact prior to mitigation: Not Assessed Significance rating of impact prior to mitigation Not Assessed (e.g. Low, Medium, Medium-High, High, or Very- High) Degree to which the impact can be avoided: Not Assessed Degree to which the impact can be managed: Not Assessed Degree to which the impact can be mitigated: Not Assessed Proposed mitigation: Not Assessed Residual impacts: Not Assessed Cumulative impact post mitigation: Not Assessed Significance rating of impact after mitigation Not Assessed (e.g. Low, Medium, Medium-High, High, or Very- High)

Note: The EAP may decide to include this section as Appendix J to the BAR.

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N/A – No Site Alternatives were comparatively assessed in the BAR.

(d) Outcome of the site selection matrix.

N/A – No Site Alternatives were comparatively assessed in the BAR.

B. SPECIALIST INPUTS/STUDIES, FINDINGS AND RECOMMENDATIONS

Note: Specialist inputs/studies must be attached to this report as Appendix G and must comply with the content requirements set out in Appendix 6 of the EIA Regulations, 2014 (as amended). Also take into account the Department’s Circular EADP 0028/2014 (dated 9 December 2014) on the “One Environmental Management System” and the EIA Regulations, 2014, any subsequent Circulars, and guidelines available on the Department’s website (http://www.westerncape.gov.za/eadp).

Provide a summary of the findings and impact management measures identified in any specialist report and an indication of how these findings and recommendations have been included in the BAR.

Ecological Impact Assessment

A site visit was conducted on the 22 November 2018 to assess the site-specific ecological state, current land-use, identify potential sensitive ecosystems and identify plant species associated with the proposed project activities. The site visit also served to identify potential impacts of the proposed development on the surrounding ecological environment.

According to Mucina and Rutherford, 2006, only one vegetation type will be impacted on by subdivision and expansion of the industrial area, Central Ruens Shale Renosterveld. This was confirmed during the site, where field survey recorded two vegetation types on site; Degraded Renosterveld and Riparian Vegetation (found on the river banks and dominated by Typha capensis).

The indigenous species recorded at the site were compared to the South African Red Data List, the Threatened and Protected Species list and the Provincial Nature Conservation Ordinance Act (PNCO) (No. 19 of 1974). Only one species (Ruschia cf lineolata) of conservation concern, which is listed as Schedule 4 species on the PNCO list, was recorded. This species will require permits for their destruction.

The site falls within QDS 3420CA and approximately 19 of reptile species have been recorded in this QDS. These species are listed as least concerned and unlikely to be found on site (SARCA, 2014). Approximately 9 species of amphibians have been recorded in QDS 3420CA (ADU, 2018). No SCC amphibians are likely to occur on site. Approximately 46 mammal species have been recorded in QDS 3420CA (ADU, 2018) the majority of these are likely located at the Heuningberg Nature Reserve.

Approximately 359 bird species occur within the Bredasdorp region (QDS 3420CA), Western Cape Province (Lepage, 2018). 12 birds were seen on site during the field visit including the Southern Red Bishop, Cape Canary, Helmeted Guinea fowl, Hadeda Ibis, Yellow billed kite, Speckled Pidgeon, Cape Sparrow, Common starling, Red winged starling, Cape Weaver, Cape white eye and pearl breasted swallow.

The study site falls within 16 species of conservation concern and five endemic distribution ranges (Lepage, 2018). The study area QDS includes an ocean portion approximately 25km away, given that marine and shoreline species are restricted to their habitat and are highly unlikely to occur in the study area.

Recommendations

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The proposed infrastructure is located within an ESA that currently functions as an ecological corridor through the town of Bredasdorp. Although the site is degraded with some invasive alien species present, this site is considered to be of high sensitivity due to the important ecological processes it performs.

It is recommended that if this development proceeds, an ecological corridor along the Droë River is delineated and preserved in perpetuity to ensure that the current ecological processes, such as seed dispersal and movement of fauna, can continue unhindered. Refer to Subsection 2 above for detailed recommendations

Heritage Impact Assessment

The proposed development is an extension of an existing industrial area and is located well away from the significant historic core of Bredasdorp and will not impact on any of the known significant structures within Bredasdorp, nor on their largely victorian context.

The Heritage study noted that very few Heritage Impact Assessments have been conducted within 15km of the proposed development area. Van Pletzen-Vos and Rust (2011, SAHRIS ID 502780) conducted an HIA on erf 1148 for the extension of the Bredasdorp Cemetery. They noted that previous assessments by Orton (2008) and Kaplan (2006) had identified low density scatters of Early Stone Age artefacts in this general vicinity, however their assessment concluded that, due to the highly disturbed nature of the area proposed for development, no archaeological resources were identified.

It is therefore unlikely that, due to the previously disturbed nature of the development area and its location alongside the existing industrial area of Bredasdorp the proposed development will impact on significant archaeological heritage resources.

Recommendations

The heritage resources in the area proposed for development are sufficiently recorded. Due to the location and nature of the proposed development, it is unlikely that significant heritage resources will be impacted by the development and as such, it is recommended that no further heritage studies are required, however the HWC Fossil Finds Procedure must be implemented throughout the construction phase

C. ENVIRONMENTAL IMPACT STATEMENT

Provide an environmental impact statement of the following:

(i) A summary of the key findings of the EIA.

SUMMARY OF THE PROPOSED DEVELOPMENT The Cape Agulhas Municipality proposes to expand the Industrial Area of Bredasdorp on the subdivided Portion A of Erf. 1148 in the Western Cape. The reason for the proposed expansion is to increase the economic activity of the town and productive use of the unused and undetermined land parcel under the Municipality’s assets. The proposed industrial area will be accommodated on the 14 industrial erven on the subdivision area (Portion A). At this stage, it is our understanding that following the conclusion of this Basic Assessment and favourable final decision from the authorities, the Municipality intends to have the land sold to private developer(s). As a result, no specific development has been proposed, however, it is anticipated that any development that will be proposed by the prospective developer(s) will be consistent with the existing land uses and industrial culture and setting of this industrial area.

CONSIDERATION OF ALTERNATIVES

The following alternatives were assessed as part of the Basic Assessment:

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Property alternative – the proposed property was the only alternative assessed in the EIA as the applicant owns this property and an alternative property is therefore not practically or financially viable. As such this is the only property that is available for the applicant to utilise.

Site alternative – The Municipality’s expansions are proposed to occur only on this site and therefore, no alternative site is proposed or considered on this assessment.

Activity alternative (land use) – the proposed activity for the site was the only alternative assessed in terms of different land use options. The proposed development is for the expansion of an existing industrial area in Bredasdorp. The Applicant (Municipality) requires the proposed expansion of the Industrial area to increase economic activities and productive use of existing Municipal land. Therefore, no feasible or reasonable activity alternatives exist.

Design/Layout alternative – None.

Technology alternative – None.

The No-Go option was also assessed.

SUMMARY OF SIGNIFICANT IMPACTS (ALL IMPACTS AND BENEFITS THAT ARE HIGH PRE-MITIGATION)

PLANNING, DESIGN AND CONSTRUCTION PHASES Significance Significance Type of Theme Impacts pre- post- Impact mitigation mitigation Loss of Degraded 2.4 ha of degraded Renosterveld renosterveld will be lost as a result of clearing for the Moderate Moderate Ecological construction of the road and Negative Negative buildings anticipated for the 14 erven. Loss of Biodiversity During construction, clearing for the construction of the Moderate Low project infrastructure will result Ecological Negative Negative in the loss of general biodiversity. Loss of Species of One species listed as a Conservation Schedule 4 species on the Concern Western Cape PNCO was recorded at the site. However, this species is listed as Least Concern by the South African Red Data List.

There may be a few geophytes that went Low Low Ecological undetected due to the time Negative Negative of year the assessment was done. Clearing for the construction of the project infrastructure could result in the loss of some of these species but this is unlikely to affect the population’s survival given the small area that will be affected. Habitat The proposed development Moderate Low Fragmentation will occur in an important, Ecological Negative Negative existing corridor that links

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natural habitat to the south and north of Bredasdorp. Development in this area will result in further habitat fragmentation in an already fragmented area. However, if the development is restricted to the 14 proposed erven, located on the edge of Section A of erf 1148, the corridor can continue to support existing ecological processes since only a small portion (2.4 ha) will be permanently lost. Invasion of Invasive Though the site is already Alien Plant Species infested, further disruption of the site could exacerbate the infestation of alien species unless these are controlled for. Areas that are disturbed Moderate Low Ecological during the construction phase Negative Negative are vulnerable to infestations unless rehabilitated to prevent invasive alien plant species from establishing themselves. OPERATIONAL PHASE Significance Significance Type of Theme Impacts pre- post- Impact mitigation mitigation Degradation of the The site may be further site due to poor degraded if the site is not management managed effectively during the operational phase. For example, the invasive alien plant species not being High Low Ecological actively removed, increased Negative Negative erosion is occurring as a result of poor storm water management and illegal harvesting of plant material is occurring within the site.

(ii) Has a map of appropriate scale been provided, which superimposes the proposed development and its associated structures and infrastructure on the environmental YES NO sensitivities of the preferred site, indicating any areas that should be avoided, including buffers? (iii) A summary of the positive and negative impacts that the proposed development and alternatives will cause in the environment and community.

Significance Significance rating Impacts rating of impacts of impacts after Before mitigation mitigation (Low, (Low, Medium, Medium, Medium- Medium-High, High, High, Very High, Very High): High): Planning, design and construction phases 1. Loss of Degraded Renosterveld Moderate - Moderate - 2. Loss of Biodiversity Moderate - Low - 3. Loss of Species of Conservation Concern Low - Low - 4. Habitat Fragmentation Moderate - Low -

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5. Invasion of Invasive Alien Plant Species Moderate - Low - Operational phase 6. Degradation of the site due to poor management High - Low -

D. IMPACT MANAGEMENT, MITIGATION AND MONITORING MEASURES

(a) Based on the assessment, describe the impact management, mitigation and monitoring measures as well as the impact management objectives and impact management outcomes included in the EMPr. The EMPr must be attached to this report as Appendix H.

Impact management and mitigation are all covered in the EMPr along with monitoring of the site in order to adhere to mitigation measure. One of these monitoring methods is having an Environmental Control Officer on site during the construction phase of the project. Monthly site visits will be conducted, and reports submitted to the Department of Environmental Affairs and Development Planning on a monthly basis.

(b) Describe any provisions for the adherence to requirements that are prescribed in a Specific Environmental Management Act relevant to the listed activity or specified activity in question.

No provisions are required.

The applicant is committed to ensuring that the development meets all the relevant legal requirements and provides an environmentally sustainable facility. The applicant is aware and has agreed to implement all management, mitigation and monitoring measures required for the development and operation of the proposed industrial expansion. All mitigation measures would be implemented and monitored in terms of construction monitoring and in line with the auditing requirements of the amended NEMA 2014 EIA Regulations).

The included EMPr is intended to provide the guidelines needed to ensure all measures put in place are adhered to.

(d) Provide the details of any financial provisions for the management of negative environmental impacts, rehabilitation and closure of the proposed development.

Financial provisions must be made for the appointment of an Environmental Control Officer during the construction phase, and for the required environmental auditing in terms of the NEMA 2014 Regulations, as amended.

(e) Provide the details of any financial provisions for the management of negative environmental impacts, rehabilitation and closure of the proposed development.

Same as above (d)

(f) Describe any assumptions, uncertainties, and gaps in knowledge which relate to the impact management, mitigation and monitoring measures proposed.

This report has been compiled with a high degree of certainty and is based on the applicant’s, EAPs’ and specialists’ expertise. Refer also to Section G (1) (c) and (d) of this report.

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SECTION H: RECOMMENDATIONS OF THE EAP AND SPECIALISTS

(a) In my view as the appointed EAP, the information contained in this BAR and the documentation YES NO attached hereto is sufficient to make a decision in respect of the listed activity(ies) applied for.

(b) If the documentation attached hereto is sufficient to make a decision, please indicate below whether, in your opinion, the listed activity(ies) should or should not be authorised: Listed activity(ies) should be authorised: YES NO Provide reasons for your opinion This Basic Assessment Report has investigated and assessed the significance of the predicted positive and negative impacts associated with the proposed expansion of the Bredasdorp industrial area.

It is the opinion of the EAP that:

• There are no fatal flaws associated with the proposed development and that all impacts can be adequately mitigated to reduce the risk or significance to an acceptable level; • The significance of the benefits associated with the proposed development outweigh the significance of the negative aspects; • The Basic Assessment Report contains sufficient information to allow DEA&DP to make an informed decision. • Therefore, provided that the specified mitigation measures stated herein are effectively implemented, it is recommended that the project receive Environmental Authorisation in terms of the EIA Regulations promulgated under the National Environmental Management Act (Act 107 of 1998, as amended).

In order to ensure the effective implementation of the mitigation and management actions, an EMPr has been compiled and is included in Appendix H of this Report. The mitigation measures necessary to ensure that the project is planned, constructed, operated and decommissioned in an environmentally responsible manner are listed in this EMPr. The EMPr is a dynamic document that should be updated regularly and provides clear and implementable measures for the proposed industrial expansion.

Furthermore, this Basic Assessment is only for the Listed Activities triggered. It is therefore important to note that if new or any other Activities are triggered by the new property owners under Listing Notices 1, 2 and/or 3, they are required to obtain their own Environmental Authorisation from the relevant and competent authorities (c) Provide a description of any aspects that were conditional to the findings of the assessment by the EAP and Specialists which are to be included as conditions of authorisation. None, apart from the recommended mitigation measures (d) If you are of the opinion that the activity should be authorised, please provide any conditions, including mitigation measures that should in your view be considered for inclusion in an environmental authorisation. All mitigation measures which have been outlined in this report as well as in the Environmental Management Programme (EMPr) must be fully adhered to. In addition, the following recommendations have been made:

Pre-Construction: • Notice must be given to surrounding land owners and businesses informing them of the intended date of commencement of construction;

Construction Phase: • An ECO must be employed to ensure that the construction activities remain within the designated area and that no unauthorised activities occur; • The ECO should submit monthly site audits detailing the applicant’s compliance with the EMPr; • An efficient stormwater management system must be implemented during construction; • Workers must be educated on environmental management aspects;

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• It is highly recommended that ALL invasive alien plant species upstream of the dam are removed. These species utilise more water than the surrounding fynbos and with their removal, the amount of water reaching downstream users will be increased. Once species upstream of the dam have been removed, individuals downstream of the dam should start to be removed. An invasive alien plant management plan must be drafted and implemented as a condition of the EMPr for this site. • A water monitoring programme should be implemented. In an event that the monitoring results indicate a strong decline in water quality and aquatic ecosystem quality, immediate corrective action will have to be taken in order to reduce the impacts on the stream and aquatic environment. • In the highly unlikely event that heritage resources such as archaeological material, paleontological material, graves or human remains are encountered during construction, works must cease and findings immediately report to Heritage Western Cape.

(e) Please indicate the recommended periods in terms of the following periods that should be specified in the environmental authorisation: i. the period within which commencement must occur; 7 years ii. the period for which the environmental authorisation is granted and the date on which the development proposal will have been

concluded, where the environmental 7 years authorisation does not include operational aspects; iii. the period for which the portion of the environmental authorisation that deals with 7 years non-operational aspects is granted; and iv. the period for which the portion of the environmental authorisation that deals with 7 years operational aspects is granted.

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SECTION I: APPENDICES

The following appendices must be attached to this report:

Confirm that APPENDIX Appendix is attached Appendix A: Locality map Yes

Site development plan(s) Yes

Appendix B: A map of appropriate scale, which superimposes the proposed development and its associated structures and infrastructure on Yes the environmental sensitivities of the preferred site, indicating any areas that should be avoided, including buffer areas;

Appendix C: Photographs Yes

Appendix D: Biodiversity overlay map Yes

Permit(s) / license(s) from any other Organ of State, including Yes service letters from the municipality. Appendix E: Appendix E1: Copy of comment from HWC. Yes

Public participation information: including a copy of the register of I&APs, the comments and responses report, proof of notices, Appendix F: Yes advertisements and any other public participation information as is required in Section C above.

Appendix G: Specialist Report(s) Yes

Appendix H : EMPr Yes

Additional information related to listed waste management Appendix I: N/A activities (if applicable) If applicable, description of the impact assessment process Appendix J: followed to reach the proposed preferred alternative within the N/A site.

Appendix K: Any Other (if applicable). N/A

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SECTION J: DECLARATIONS

THE APPLICANT

Note: Duplicate this section where there is more than one applicant.

I …………………………………………..……….., in my personal capacity or duly authorised thereto, hereby declare/affirm all the information submitted as part of this Report is true and correct, and that I –

 am aware of and understand the content of this report;  am fully aware of my responsibilities in terms of the NEMA, the EIA Regulations in terms of the NEMA (Government Notice No. R. 982, refers) (as amended) and any relevant specific environmental management Act and that failure to fulfil these requirements may constitute an offence in terms of relevant environmental legislation;  have provided the EAP and Specialist, Review EAP (if applicable), and Review Specialist (if applicable), and the Competent Authority with access to all information at my disposal that is relevant to the application;  will be responsible for complying with conditions that may be attached to any decision(s) issued by the Competent Authority;  will be responsible for the costs incurred in complying with the conditions that may be attached to any decision(s) issued by the Competent Authority;

Note: If acting in a representative capacity, a certified copy of the resolution or power of attorney must be attached.

Signature of the Applicant:

Name of Organisation:

Date:

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THE ENVIRONMENTAL ASSESSMENT PRACTITIONER

I ………………………………………………………., as the appointed EAP hereby declare/affirm:

 the correctness of the information provided as part of this Report;  that all the comments and inputs from stakeholders and I&APs have been included in this Report;  that all the inputs and recommendations from the specialist reports, if specialist reports were produced, have been included in this Report;  any information provided by me to I&APs and any responses by me to the comments or inputs made by I&APs;  that I have maintained my independence throughout this EIA process, or if not independent, that the review EAP has reviewed my work (Note: a declaration by the review EAP must be submitted);  that I have throughout this EIA process met all of the general requirements of EAPs as set out in Regulation 13;  I have throughout this EIA process disclosed to the applicant, the specialist (if any), the Department and I&APs, all material information that has or may have the potential to influence the decision of the Department or the objectivity of any report, plan or document prepared as part of the application;  have ensured that information containing all relevant facts in respect of the application was distributed or was made available to I&APs and that participation by I&APs was facilitated in such a manner that all I&APs were provided with a reasonable opportunity to participate and to provide comments;  have ensured that the comments of all I&APs were considered, recorded and submitted to the Department in respect of the application;  have ensured the inclusion of inputs and recommendations from the specialist reports in respect of the application, if specialist inputs and recommendations were produced;  have kept a register of all I&APs that participated during the PPP; and  am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations, 2014 (as amended).

Signature of the EAP:

Name of Company:

Date:

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THE REVIEW ENVIRONMENTAL ASSESSMENT PRACTITIONER

I ………………………………………………………., as the appointed Review EAP hereby declare/affirm:

 that I have reviewed all the work produced by the EAP;  the correctness of the information provided as part of this Report;  that I have, throughout this EIA process met all of the general requirements of EAPs as set out in Regulation 13;  I have, throughout this EIA process disclosed to the applicant, the EAP, the specialist (if any), the review specialist (if any), the Department and I&APs, all material information that has or may have the potential to influence the decision of the Department or the objectivity of any report, plan or document prepared as part of the application; and  am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations, 2014 (as amended).

Signature of the Review EAP:

Name of Company:

Date:

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THE SPECIALIST

Note: Duplicate this section where there is more than one specialist.

I ……………………………………, as the appointed Specialist hereby declare/affirm the correctness of the information provided or to be provided as part of the application, and that I :

 in terms of the general requirement to be independent: o other than fair remuneration for work performed in terms of this application, have no business, financial, personal or other interest in the development proposal or application and that there are no circumstances that may compromise my objectivity; or o am not independent, but another specialist (the “Review Specialist”) that meets the general requirements set out in Regulation 13 has been appointed to review my work (Note: a declaration by the review specialist must be submitted);  in terms of the remainder of the general requirements for a specialist, have throughout this EIA process met all of the requirements;  have disclosed to the applicant, the EAP, the Review EAP (if applicable), the Department and I&APs all material information that has or may have the potential to influence the decision of the Department or the objectivity of any report, plan or document prepared or to be prepared as part of the application; and  am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations, 2014 (as amended).

Signature of the Specialist:

Name of Company:

Date:

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THE REVIEW SPECIALIST

I ………………………………………………………., as the appointed Review Specialist hereby declare/affirm:

 that I have reviewed all the work produced by the Specialist(s);  the correctness of the specialist information provided as part of this Report;  that I have, throughout this EIA process met all of the general requirements of specialists as set out in Regulation 13;  I have, throughout this EIA process disclosed to the applicant, the EAP, the review EAP (if applicable), the Specialist(s), the Department and I&APs, all material information that has or may have the potential to influence the decision of the Department or the objectivity of any report, plan or document prepared as part of the application; and  I am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations, 2014 (as amended).

Signature of Review Specialist:

Name of Company:

Date:

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APPENDICES

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Appendix A: Locality map

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Appendix B: The proposed development plan

Appendix C: Photographs

Recent aerial image of the proposed site

Photo of the access road (R319)/ Swellendam Rd bordering the Site on the North

Photo fuel industry operating in the industrial area, located on the South East side of the proposed site across the stream

Photo taken from the West of the site on the end of Sealy Street.

Photo of an existing livestock Deeping found on site

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Photo taken of building structures and animal kraal present on site.

Photo taken from the river crossing, showing the Droë River running on the East side of the proposed site

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Photo showing a 180 degree view of the proposed site in relation to its surroundings.

Coordinate: S 34°31'35.70"; 20° 2'57.01" E Date: 22-11-2018

Appendix D: Biodiversity Overlay map

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Appendix E: Permit(s) / license(s) from any other Organ of State, including service letters from the municipality.

Proof of comment and confirmation on electrical demand from Cape Agulhas Municipality:

Proof of comment and confirmation on infrastructure planning from the Cape Agulhas Municipality:

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Proof of comment and confirmation on services for proposed industrial area from the Cape Agulhas Municipality:

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Proof of comment and confirmation on waste and emissions from the Cape Agulhas Municipality:

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E 1: Copy of comment from HWC

Proof of NID Submission to HWC:

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Copy of comment from HWC:

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Appendix F: Public participation information as is required in Section C

SITE NOTICES:

Site Notice Placed on Ou Meule St. Coordinates: 34°31'54.09"S; 20° 3'20.37"E

Site Notice Placed on R319 (Swellendam Rd). Coordinates: 34°31'35.81"S; 20° 2'56.62"E

LIST OF INTERESTED AND AFFECT PARTIES NOTIFIED:

Name Affiliation

CES Amber Jackson CES Zweli Nkosi CES Applicant Bertus Hayward Cape Agulhas Municipality Doreen Oncke Cape Agulhas Municipality Elsabe Zieff PA to M Manager Dean O'Neil Municipal Manager Land Owners Same as Applicant Neighbours Overberg Agri - Tiaan Augustyn Erven 2969 Overberg Agri Erven 6216 Richard Roberts Erven 2969 Lifestyle Center RE/1285 Gareth van der Walt Erven 2970 Droerivier Industrieele Sentrum Erven 2970 Municipality Stores Erven 1404, Erasmus Vervoer Trust Erven 1404 Pierre Erasmus Erven 2133 PL Willemse Erven 2133 Leslie Andrews Erven 1875 Ikamva fuel Erven 1876 Elaine Willemse Erven 1876 Joseph Eugene Dunn Erven 1877 Alexander Robert Rohland Erven 1878 Johan Snyders cc Erven 4665 CA Municipality Erven 3274 Johannes Andries de Wet Erven 3317 Zaccheus Jaars Erven 3316 Willem Andries Coert Erven 3315 Pieter Gabriels Erven 2657 Lilly Diedericks Erven 2658 Sarah Abrahams Erven 2659 Willem Kamfer Erven 2660 Marthinus Gert Abrahams Erven 2661 Patricia Lin Des Jantjies Erven 2662 Jan Jackson Erven 2663 Gert Windvogel Erven 2664 Freek September Erven 2665 Christiana Signeur Erven 2666 Jacoba Frilina Katrina Davids Erven 2667 Joshua Michael de Jager Erven 2668 Ann Cucille Hess Erven 2669 Barend Slammat Erven 2670 Hester Olivier Erven 2671 Elizabeth Emily Arendse Erven 2672 Jacobus Ettienne Adriaans Erven 2673 Frederick Charles Hickley Erven 2674 Charlie Chelwin Gabriels Erven 2675 Magdelena Newman Erven 2676 Annette Florinda Leonard Erven 2677 Golliat Freek Moses Erven 2678 Provincial Govt - WC Erven 2178 Provincial Govt - WC Erven 1136 Provincial Govt - WC Erven 1135 Provincial Govt - WC Erven 1295 Provincial Govt - WC Erven 2136 Gideon Albertyn Trust Erven 3575 Erven 1295 Erven 2136 Emilius Tomlinson Erven 104 Erven 103

Name Affiliation

Van der Stelskraal Trust Erven 3332 Neethling Property Trust Erven 100 Jo Ann Jacobs Erven 99 Jehovah's Witnesses Temple Erven 98 Wilhelmina Rosemary Dittmer Erven 97 Petrus Jacobus Robbertze Erven 96 Alida Roddertze Erven 96 Stephanus Johannes Matthee Erven 82 Loire Trust Erven 81 Patrick Koos Pietersen Erven 80 Johannes Andries de Wet Erven 4168 Gabriel Jacobus Swart Erven 3632 Organs of State Mr Fabion Smith Department of Water& Sanitation Cor Van der walt (details provided by Brandon) Western Cape Agriculture land use section Phyllis Pienaar (Confirmed by Mponna) Western Cape Department of Agriculture Department of Economic Development and Tourism Head of Mr Solly Fourie () Department Overberg District Municipality Head: Environmental Francios Kotze Management Rulien Volschenk Overberg District Municipality -Environmental Officer Dean O'Neil Cape Agulhas Local Municipality - Municipal Manager Evelyn Sauls Ward 1 Councilor Marjorie October Ward 2 Councilor Raymond Baker Ward 3 Councilor Danny Europa Ward 6 Councilor John Daniels Cape Agulhas Local Municipality - Technical department Cape Agulhas Local Municipality - Corporate Services ( Town Bertus Hayward and Building Control) Cape Agulhas Local Municipality - Water Distribution ( Water Deon Wasserman and Sanitation) Cape Agulhas Local Municipality - Corporate Services ( Town Francois du Toit and Building Control) Andrew September HeritageWestern Cape - Heritage Officer Key Stakeholders Henk Aggenbach Bredasdorp Mega Park Non-Profit Company - Chaiperson Cornie Swart Agulhas Biodiversity Initiative - Chaiperson Colin Fordham Cape Nature - Land Use Advice Chanel Rampartab Cape Nature - Land Use Advice (Cape Agulhas) Gerald Cloete Department of Agriculture, Bredasdorp Bredasdorp Librarian Bredasdorp Library Oscar January Cape Agulhas Communication & Client Services - Manager Derick Strydom (not confirmed) SANParks (Agulhas National Park) - Tourism manager Christy Bragg Freshwater research centre (NGO) Research Registered IAPs Modeleen Basson JD Implemente Peter Volkeis JD Implemente Bertus Lambrecht Moov fuel Depot Manager Kent Georgala Omega Consulting Africa (Pty) Ltd (OCA) Mr Ben Burger Individual

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NOTIFICATION LETTERS:

Mailchimp list of I&AP’s who received Inception letters

Mailchimp list of I&AP’s who received notifications of the reease of Draft BAR/EMPr:

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Inception Letter sent to I&AP’s using mail-chimp tool:

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Notification Letter for Release of Draft BAR/EMPr sent to I&AP’s using mail-chimp tool:

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26 April 2019 Dear Interested and Affected Party

NOTIFICATION OF RELEASE OF DRAFT BASIC ASSESSMENT REPORT FOR THE PROPOSED EXPANSION OF THE INDUSTRIAL AREA IN BREDASDORP, CAPE AGULHAS MUNICIPALITY, WESTERN CAPE DEA&DP BA ref: 16/3/3/1/E1/5/1022/19

In accordance with the requirements of regulation 41 of the Environmental Impact Assessment Regulations (2014) as amended in 2017 and made in terms of section 24 of the National Environmental Management Act (Act No 107 of 1998) as amended, we are required to notify all Interested and Affected Parties. In accordance with this requirement, please find here-with a letter of notification for the submission of a draft Basic Assessment Report carried out by Coastal and Environmental Services (CES) in respect of the above-mentioned project.

The Cape Agulhas Municipality (here-in referred to as the Municipality) proposes to expand the industrial area of Bredasdorp town in the Western Cape Province. The Municipality intends to subdivide the erf 1148 for the purpose of establishing Section A of the erf and Remainder. It is the intention of the Municipality to then Rezone Section A of erf 1148 into Sub-divisional Area. The “Rezoned Section A” into Sub-divisional Area will then be further subdivided into fourteen (14) Industry Zoned Erven and one (1) Street Zoned erf.

CES, Environmental and Social Advisory Services, would like to notify you of the release of the draft Basic Assessment Report for public review and comment. The review period is from 26 April 2019 until 28 May 2019. PLEASE ENSURE THAT YOUR COMMENTS REACH US ON OR BEFORE 28 May 2019.

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Copies of the draft Basic Assessment Report will be available for review at the following locations: o Bredasdorp Public Library o The CES website (http://www.cesnet.co.za/cape-agulhas-municipality-eia)

CES will be pleased if you could confirm your receipt of notification via email, phone, fax or post. For more information, please feel free to contact Mr Zweli Nkosi on 021 045 09000 at the CES Cape Town office or on [email protected]

Yours sincerely,

Zweli Nkosi Environmental Consultant Email: [email protected]

This email was sent to [email protected] why did I get this? unsubscribe from this list update subscription preferences CES · 76 Regent Road · Sea Point, Cape Town 8005 · South Africa

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Tear sheet of an advert placed and published in the Theewaterskloof Gazette (Afrikaans and English) on the 30th of April 2019:

Background Information Document Sent to I&AP’s:

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Proof of bulk SMS services sent out to I&AP’s (Inception SMS):

Message History Detail: Batch 900555158

Time submitted 2019-02-04 08:25:41.0

Total messages 57

Total credits 57.00

Delivery Delivered to mobile 78.95% summary Delivery failed 5.26%

Delivered upstream 15.79%

Recipient Status Credits Completed time Body

+27616247836 Delivered 1.00 2019-02-04 08:25:00 Concatenated SMS (part 1 of 3): to mobile You have been identified as an Interested & Affected Party by EOH Coastal & Environmental Services and are hereby notified of the proposed expansion of the industrial area of Bredasdorp by the Cape Agulhas Municipality. You will be notified of this projects progress when your valued comment is required. F or further info please contact Zweli Nkosi on [email protected] or (021) 045 0900.

+27711055774 Delivered 1.00 2019-02-04 08:25:00 Concatenated SMS (part 1 of 3): to mobile You have been identified as an Interested & Affected Party by EOH Coastal & Environmental Services and are hereby notified of the proposed expansion of the industrial area of Bredasdorp by the Cape Agulhas Municipality. You will be notified of this projects progress when your valued comment is required. F or further info please contact Zweli Nkosi on [email protected] or (021) 045 0900.

+27727659027 Delivered 1.00 2019-02-04 08:25:00 Concatenated SMS (part 1 of 3): to mobile You have been identified as an Interested & Affected Party by EOH Coastal & Environmental Services and are hereby notified of the proposed expansion of the industrial area of Bredasdorp by the Cape Agulhas Municipality. You will be notified of this projects progress when your valued comment is required. F or further info please contact Zweli Nkosi on [email protected] or (021) 045 0900.

+27733661595 Delivered 1.00 Concatenated SMS (part 1 of 3): upstream You have been identified as an Interested & Affected Party by EOH Coastal & Environmental Services and are hereby notified of the proposed expansion of the industrial area of Bredasdorp by the Cape Agulhas Municipality. You will be notified of this projects progress when your valued comment is required. F or further info please contact Zweli Nkosi on [email protected] or (021) 045 0900. Records: 57

Proof of bulk SMS services sent out to I&AP’s (Notification of release of Draft BAR/EMPr SMS):

Message History Detail: Batch 940398637

Time 2019-04-26 10:20:21.0 submitted

Total 76 messages

Total credits 76.00

Delivery summary Delivered to mobile 56.58% Delivery failed 5.26%

Delivered upstream 38.16%

BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) – October 2017 Page 1 of 124

Recipient Status Credits Completed time Body

+27616247836 Delivered 1.00 2019-04-26 10:20:00 Concatenated SMS (part 1 of 4): to mobile Dear Interested and Affected party, you are hereby notifie d that the Draft Basic Assess ment for the proposed expansi on of the industrial area of Bredasdorp by the Cape Agulha s Municipality is available f or public review and comment (from 26/04/2019 to 28/05/201 9). A copy of the report is a vailable at the Bredasdorp pu blic library or can be downlo aded from our website: http:/ /www.cesnet.co.za/public-docu ments.html. For further info please contact Zweli Nkosi on [email protected] or (021) 045 0900.

+27616247836 Delivered 1.00 Concatenated SMS (part 2 of 4): upstream Dear Interested and Affected party, you are hereby notifie d that the Draft Basic Assess ment for the proposed expansi on of the industrial area of Bredasdorp by the Cape Agulha s Municipality is available f or public review and comment (from 26/04/2019 to 28/05/201 9). A copy of the report is a vailable at the Bredasdorp pu blic library or can be downlo aded from our website: http:/ /www.cesnet.co.za/public-docu ments.html. For further info please contact Zweli Nkosi on [email protected] or (021) 045 0900.

+27616247836 Delivered 1.00 2019-04-26 10:20:00 Concatenated SMS (part 3 of 4): to mobile Dear Interested and Affected party, you are hereby notifie d that the Draft Basic Assess ment for the proposed expansi on of the industrial area of Bredasdorp by the Cape Agulha s Municipality is available f or public review and comment (from 26/04/2019 to 28/05/201 9). A copy of the report is a vailable at the Bredasdorp pu

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blic library or can be downlo aded from our website: http:/ /www.cesnet.co.za/public-docu ments.html. For further info please contact Zweli Nkosi on [email protected] or (021) 045 0900.

Records: 76

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PROOF OF POSTAL SERVICES USED TO NOTIFY I&AP’s

COMMENTS AND RESPONSE REPORT/ TRAIL

During the public participation process, a phased approach was adopted to ensure that all I&AP’s are informed of the process being undertaken for the proposed project and the stages, to achieve this the following was done:

 Identifying Interested and Affected Parties (I&AP’s);  Creating an I&AP Database;  Disseminating project information such as the BID and ensuring the involvement of the I&AP’s;  Collecting and recording contributions by the I&AP’s; and  Preparation of comments and response trail which incorporates all the comments, issues, concerns, suggestions, questions and responses provided by CES

All raised and received comments, concerns or questions, suggestions, critiques, requests for clarification or further information provided by participants were recorded and included into this report. All concerns raised and comments forwarded by the I&APs were, where possible and reasonable, responded to.

The Comments and Response Report/Trail (CRR) below was developed to capture all the comments raised by the I&APs. All comments were thus summarised and included in the CRR table below

Affiliation/ Date Person Comment CES Response Organisation

Dear Sir, Dear Kent

Your Notice of Environmental Impact Thank you for registering Omega Consulting Assessment refers. Africa (Pty) Ltd (OCA) with us on this project.

Omega Please register Omega Consulting Africa (Pty) Please note that your details have been 1/16/2019 Kent Georgala Consulting Ltd (OCA) on your database in order to added on our database. Africa receive all project related information for the Good day. proposed expansion of the Bredasdorp Industrial Area. Kind Regards

Thanks and regards. Zweli

Dear Zweli, Dear Colin, 4/29/2019 Colin Fordham CapeNature Hope you are well! Thank you for your response below. Please note that Miss Chanel Rampartab was

Affiliation/ Date Person Comment CES Response Organisation

As per our requirements for development added on the stakeholder database and applications letter, please note that Miss relevant documentation has been sent for Chanel Rampartab is the official responsible her attention. for providing comment on applications within Good day. the Cape Agulhas Municipality. So please forward all relevant documentation to her. Best, Regards, Zweli

Thanks I did receive the info. Hi Francois, Cape Regards. Thank you for acknowledging receipt. Your 7/5/2019 Francois du Toit Agulhas Francois du Toit receipt in noted. Municipality Best, Zweli

Cape Notification received, thank you. Hi Lesley, Lesley 5/8/2019 Agulhas Richardson Thank you for confirming receipt of the Biodiversity below notification.

Good day, Dear Loretta

Please find attached letter for your perusal. Thank you for the email. The letter and comments made there-in have been It is recommended to please also look at page noted. Comments will be incorporated in 3 of the EMP, bullet g-l, if you can rather put the Comments and Response Report in the those aspects into a table format to be Final BAR. 5/28/2019 Lorretta Osborne DEA&DP included in the final EMP. Good day. Thank you Best, Lorretta Osborne Zweli

Please note responses to the letter from the DEA&DP below:

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Affiliation/ Date Person Comment CES Response Organisation

2.1 Noted. 2.2 CapeNature was confirmed to be the Competent Authority responsible for issuing Flora permit. No comment was received from CapeNature during the commenting period. Comment was requested from CapeNature after the public comment period and no comment has been received from CapeNature. For the purpose of flora removal permit, it is recommended that a Botanist be appointed to conduct a site visit to quantify the number of individuals present within the impacted area and collect specific coordinates of the species identified as being of conservation concern. 2.3 Noted.

2.4 Noted. 2.5 The Municipality has provided confirmation letters for the availability of electricity services and necessary servces. Moreover, the Municipality indicated its intentions to upgrade the current 2Ml/day WWTP to 4Ml/day to accommodate the proposed industrial expansions. 2.6 Noted. 2.7 The EMPr has been updated to include the information about the process of obtaining (where required) permits for

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Affiliation/ Date Person Comment CES Response Organisation

removing Species of Conservation Concern 2.8 Noted. 2.9 Noted.

See Appendix K for the full letter with comments from DEA&DP

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Affiliation/ Date Person Comment CES Response Organisation

Dear V. Ligudu

The letter that is dated 30 May 2019, with reference no: 4/10/1/G50E/Industrial Area, Bredasdorp refers.

Please note this communication serves to acknowledge receipt of the letter with comments from the Breede-Gouritz Catchment Management by CES on the 19th of June 2019.

The copy of the letter is attached and comments there-in noted. 30/5/2019 V Ligudu BGCMA

Please note that, with regards to comments #1 and #2 in the letter you submitted, the Municipality acknowledged and indicated that “the waste water treatment plant will be upgraded to 4Ml per day during the 2019/20 financial year to accommodate the growth and expansion of the consumer base” See Appendix K for the full letter with comments from BGCMA I hope you find all of the above in order.

Best, Zweli Chanel Dear Zweli Please note responses to the letter from Rampartab 09/07/2019 CapeNature CapeNature: (Scientific Please see attached.

Services)

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Affiliation/ Date Person Comment CES Response Organisation

Kind regards CapeNature’s comments were only Chanel received on the 9th of July 2019, the commenting period ran from the 26 April Dear Mr Nkosi 2019 to 28 May 2019, weeks after the Draft BAR for the expansion of the industrial commenting period had ended. area on Erf 1148, Bredasdorp Comments were again requested from CapeNature would like to thank you for the CapeNature by CES on 28 June 2019. opportunity to comment on the Draft BAR for the proposed expansion of industrial area on CapeNature states that there is a Erf 1148, Bredasdorp. Please note that these temporary wetland across a portion of the comments only pertain to the biodiversity- proposed development (erven 6236-6240) related impacts and not to the overall based on satellite imagery. desirability of the application. CES and the Ecological specialist were on Erf 1148, within the urban edge of Bredasdorp, site in November 2018 and did not observe has already been subdivided into Portion A any evidence of the wetland referred to by and a remainder. Portion A has been further CapeNature, no wetland plant species subdivided into 14 industrial zone erven and were recorded on site other than within the one street zone erf (total footprint 25 500 m2). river and its banks and none of the site was water logged or inundated. However, this A. Biodiversity features may have been due to the severe drought Critically endangered Central Ruens Shale experienced during 2018. Renosterveld is mapped for the site. According to the Western Cape Biodiversity A brief desktop assessment suggests that Spatial Plan (CapeNature 2017), the site is an this area may be a drainage line caused by Ecological Support Area with restoration storm water runoff from surrounding potential (ESA2). A non-perennial stream runs property’s and road hard surfaces, this is along the northeastern border of the site, the supported by the gradient of the site and closest edge of which is approximately 30 m that only Kikuyu grass is present. from the edge of the riparian habitat. According to satellite imagery, a temporary

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Affiliation/ Date Person Comment CES Response Organisation

wetland is visible across erven 6236-6240. The Based on CapeNatures comments CES site also falls within the National Strategic recommends that as a condition of Water Source Area for groundwater in the approval, and before any construction Overberg region, and serves as watercourse activities commence, a wetland specialist protection for the Southern Coastal Belt. be appointed to conduct a site visit during CapeNature therefore recommends that a the wet season and verify the presence or freshwater specialist be consulted to absence of a wetland. undertake a site scan and recommend appropriate buffer areas and mitigation If a wetland is present it must be delineated measures. and given a PES rating according to the approved DWS methodology. DWS then B. Specialist studies and EMP needs to comment if the proposed CapeNature generally supports the infrastructure layout needs to be relocated. recommendations made in the specialist studies and the EMP. It should be noted, however, that the faunal statistics provided are of low resolution (QDS) and therefore impractical to assess the impacts of a development of this nature.

According to the impact table, the post- mitigation impact of the construction phase on the loss of degraded renosterveld will be of moderate significance. In accordance with the Draft National Biodiversity Offsets Policy, the applicability of biodiversity offsets is largely based on the significance of the post- mitigation residual impacts. If the impact is high or moderate, offsets are applicable; if the impact is low or very high, offsets are not applicable.

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Affiliation/ Date Person Comment CES Response Organisation

C. Conclusion CapeNature wishes to comment on all developments proposed in the subject area to ensure that appropriate mitigation measures are proposed. A freshwater specialist must undertake a site scan. Alien clearing must form part of the construction and operation phase of the project, to prevent further dispersal along the stream.

CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received.

Yours sincerely Chanel Rampartab For: Manager (Scientific Services)

See Appendix K for the full letter with comments from CapeNature

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Appendix G: Specialist Report(s)

 Ecological Impact Assessment Report  Heritage Impact Assessment: Screener and NID

Specialist Report Attached separately

Appendix H: EMPr

Attached separately

Appendix I: Additional information related to listed waste management activities (if applicable)

Not Applicable

Appendix J: If applicable, description of the impact assessment process followed to reach the proposed preferred alternative within the site.

Not Applicable

Appendix K: Any Other (if applicable).

Letter of Comment from the Department of Environmental Affairs and Development Planning:

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Letter of Comment from the Breede Gouritz Catchment Management Agency:

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Letter of Comment from Cape Nature:

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