DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT:

The Proposed Gas to Power Powership Project at the Port of Saldanha Bay, Saldanha Local Municipality,

DEFF REF NO: 14/12/16/3/3/2/2006

A Project of Karpowership SA (PTY) Ltd

REPORT

26 February 2021

DRAFT ENVIRONMENTAL IMPACT ASSESSSMENT ASSESSSMENT IMPACT ENVIRONMENTAL DRAFT DOCUMENT DESCRIPTION

Applicant: Karpowership SA (Pty) Ltd

Report name: Draft Environmental Impact Assessment Report for the Proposed Powership at Port of Saldanha, Saldanha Local Municipality, Western Cape

Report type: Draft Environmental Impact Assessment Report

Project name: Proposed Gas to Power Powership Project at the Port of Saldanha at Saldanha Bay Local Municipality, Western Cape,

Project number: E-BL01.200445

Version: Original

Compiled and Authorised by: Compiled By: Date Signature Nerita Sewnath February 2021 Environmental Consultant Zayd Hoosen February 2021 Environmental Consultant

Reviewed By: Date Signature Shanice Singh February 2021 EAPASA Sustainability Consultant Melissa Gopaul (nee Padayachee) February 2021 (Pri.Sci.Nat | EAPASA) Senior Sustainability Consultant Janice Tooley February 2021 Environmental Legal Advisor Authorised By: Date Signature Hantie Plomp (Pri.Sci.Nat | EAPASA) February 2021 Director

COMPILED FOR: COMPILED BY: Karpowership SA (Pty) Ltd Triplo4 Sustainable Solutions (Pty) Ltd Suite 5, The Circle, Douglas Crowe Drive, Ballito, 4420  +27 (0)3 946 3213  +27 (0)32 946 0826  [email protected] www.triplo4.com © Copyright 2021 Triplo4 Sustainable Solutions

EXECUTIVE SUMMARY

The proposed Gas to Power Powership Project at the Port of Saldanha has been formulated in response to the Request for Proposals (RFP) for New Generation Capacity under the Risk Mitigation IPP Procurement Programme issued by the Department of Mineral Resources and Energy to alleviate the immediate and future capacity deficit as well as the limited, unreliable and poorly diversified provision of power generating technology with its adverse environmental and economic impacts. The “Emergency/Risk Mitigation Power Purchase Procurement Programme (2000MW): National” has also been designated the status of a Strategic Integrated Project (SIP) under the Infrastructure Development Act, 2014 by the Presidential Infrastructure Coordinating Commission. SIPs are considered to be projects of significant economic or social importance to South Africa as a whole or regionally that give effect to the national infrastructure plan and for this reason, can be expeditiously implemented through the provisions of the enabling Act. At the time of this report, the preferred bidder status had not been confirmed.

The Project entails the generation of electricity from a floating mobile Powership moored in the Port of Saldanha Bay. The Port activities falls under the jurisdiction of the Transnet National Port Authority (TNPA) and the associated land-based activities are located on land owned by Transnet, Eskom and other private industry landowners. The proposed combined design capacity for the Powership is 415MW, comprising 21 reciprocating engines and 2 steam turbines. A Floating Storage Regasification Unit (FSRU) will act as the storage and regasification facility. A Liquefied Natural Gas Carrier will supply the Liquefied Natural Gas (LNG) to the FSRU over a 1 – to - 2 day period approximately every 20 days. The associated evacuation route is dependent on the position of the Powership within the Port of Saldanha. The power from the Powership will either be evacuated by means of a double circuit twin Chicadee conductor 132kV line. This line will interconnect the Powership to the National Grid utilising the existing Aurora- Saldanha Steel network via a new 132kV on shore switching station. Alternatively, the power that is generated is then converted by the on-board High Voltage substation (capacity of 110 – 170kV) and the electricity evacuated via a 132kV transmission line over a distance of approximately 7.5 km to the Eskom Blouwater Substation which feeds into the national grid.

Alternatives being considered for this Project include two ship positions, two alternative routes for the gas pipeline, and two alternative evacuation routes.

The Project triggers a number of activities listed under the National Environmental Management Act 107 of 1998 (NEMA) which require environmental authorisation prior to commencement. Because these listed activities include activities described in the EIA Regulations Listing Notice 2 of 2014, the process that is required to be applied to the application for environmental authorisation is Scoping and Environmental Impact Reporting (S&EIR). The procedural requirements for S&EIR are set out in the Environmental Impact Assessment Regulations, 2014 (as amended) (the EIA Regulations, 2014).

Scoping has already been concluded with the acceptance of the Scoping Report, including the plan of study for the EIA by the competent authority, namely the Department of Environment, Forestry and Fisheries (DEFF) on 6 January 2021. This draft EIA Report is part of the EIR phase and has been distributed for comment as part of the public participation process. i

The objectives of the EIA process is, through a consultative process with Interested and Affected Parties (I&APs), including relevant organs of state, to:

 determine the policy and legislative context within which the activity is located and document how the proposed activity complies with and responds to the policy and legislative context;  describe the need and desirability of the proposed activity, including the need and desirability of the activity in the context of the development footprint on the approved site as contemplated in the accepted scoping report;  identify the location of the development footprint within the approved site as contemplated in the accepted scoping report based on an impact and risk assessment process inclusive of cumulative impacts and a ranking process of all the identified development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects of the environment;  determine the- o nature, significance, consequence, extent, duration and probability of the impacts occurring to inform identified preferred alternatives; and o degree to which these impacts can be reversed; may cause irreplaceable loss of resources, and can be avoided, managed or mitigated;  identify the most ideal location for the activity within the development footprint of the approved site as contemplated in the accepted scoping report based on the lowest level of environmental sensitivity identified during the assessment;  identify, assess, and rank the impacts the activity will impose on the development footprint on the approved site as contemplated in the accepted scoping report through the life of the activity;  identify suitable measures to avoid, manage or mitigate identified impacts; and  identify residual risks that need to be managed and monitored.

The process and findings of the EIA are reported on in the draft EIA Report. Once the public participation process has been concluded, the draft report will be revised taking into consideration I&APs’ comments. The Final EIA Report will then be submitted to DEFF for consideration, and a decision either to grant or refuse environmental authorisation will be made. All registered I&APs will be notified of this decision and their opportunity to appeal.

The following issues and potential impacts have been identified and assessed in respect of the various alternatives in the EIA:

. Liquefied Natural Gas (LNG) Carrier, Powership and FSRU o Disturbance to marine habitat; o Disturbance to the sediment from mooring infrastructure; o Reduction in ambient air quality from increased atmospheric emissions; o Gas supply; o Safety risk from potential leakage of LNG; o Safety risk of storage of NG within the Port; o Increase in noise pollution; o Change in water temperature o Provision of additional electricity; o Contributions to climate change; ii

o Marine traffic congestion and accidents; o Visual Impact. . Gas Pipeline o Disturbance to marine habitat; o Potential leakage of LNG; o Increase in noise pollution; o Disturbance to coastal dunes. . Transmission Lines and Lattice Towers / Monopoles o Clearance of indigenous vegetation o Disturbance to the terrestrial ecosystem; o Loss of biodiversity; o Altered hydrology; o Increase in noise pollution; o Change in hydropedological processes; o Destruction of wetlands, watercourses, estuarine areas; o Destruction of cultural heritage and palaeontological resources; o Disturbance to properties and existing services; o Provision of additional electricity; o Visual Impact

The assessment was conducted with specialist input, and includes the identification of mitigation measures and an evaluation of their effectiveness. These assessment findings are used to determine the preferred alternative development footprint and provides the basis for the EAP’s opinion as to whether the proposed activity should be authorised or not, and if so, the conditions that should be made in respect of such authorisation. Should authorisation be granted, the applicant will need to comply with the Environmental Management Programme (EMPr) when implementing the project, which contains inter alia the proposed impact assessment outcomes and actions (mitigation measures) and monitoring and auditing requirements.

For ease of reference:  The EIA process, methodology and findings are contained in Chapter 8.  The specialist reports are contained in Appendix I: o Terrestrial Ecological Assessment – Appendix I1 o Heritage and Paleontology Impact Assessment – Appendix I2 o Wetland Delineation and Functional Assessment – Appendix I3 o Geohydrological Assessment – Appendix I4 o Hydrological and 1:100 Year – Appendix I5 o Aquatic Assessment – Appendix I6 o Hydropedology Assessment – Appendix I7 o Avifaunal Assessment – Appendix I8 o Estuarine and Coastal Assessment – Appendix I9 o Marine Ecological Assessment – Appendix I10 o Air Quality Impact Assessment – Appendix I11 o Climate Change Impact Assessment – Appendix I12 o Landscape and Visual Impact Assessment – Appendix I13 o Major Hazardous Risk Assessment – Appendix I14 iii

o Socio-Economic Assessment – Appendix I15 o Noise Impact Assessment – Appendix I16

 The EAP’s opinion is provided in Chapter 9.2.  The Environmental Management Programme is contained in Appendix G;

The proposed gas pipeline subsea as well as land-based to the Powership alternative in Big Bay or Small Bay are supported by all the Specialists and the EAP. As the alternatives are not limited by environmental and/or socio- economic impacts, it is recommended that both alternatives be approved to allow for Transnet National Port Authority and Eskom’s ultimate requirements. These entities are instrumental in determining the technical feasibility of each option in line with their requirements and future plans. Preliminary discussions were undertaken as part of the EIA process however extensive engagements with TNPA, Eskom and Karpowership SA will be required once preferred bidder status is confirmed.

The same EIA process meets the requirements for an application for an atmospheric emission licence (AEL) required for a Listed Activity under GN 893 of 22 November 2013 (as amended) in terms of Section 21 of the National Environmental Management: Air Quality Act 39 of 2004: Sub-category 1.5: Reciprocating Engines. The Powership will have a combined sum of 21 reciprocating engines that have a heat input capacity of more than 10 MW each. The findings in the EIA Report will be used by the licensing authority, also DEFF, to decide on the application for the AEL. Again, registered I&APs will be notified of DEFF’s decision on the AEL and their opportunity to appeal.

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TABLE OF CONTENTS

EXECUTIVE SUMMARY I

1 INTRODUCTION 1

PROJECT TITLE 1

BACKGROUND 1

SUMMARY OF “ENVIRONMENTAL LICENSING” REQUIREMENTS 2

PURPOSE OF THIS REPORT 2

INDEPENDENT ENVIRONMENTAL ASSESSMENT PRACTITIONER 3

SPECIALIST STUDIES 4

EIA REPORTING REQUIREMENTS AS PER EIA REGULATIONS 2014 (AS AMENDED) 5

REPORT STRUCTURE 10

2 DESCRIPTION OF THE PROPOSED ACTIVITY 11

DESCRIPTION OF THE ACTIVITIES TO BE UNDERTAKEN INCLUDING ASSOCIATED STRUCTURE AND INFRASTRUCTURE 11 POWERSHIP, FSRU AND LNG CARRIER 11 BERTHING & MOORING OF THE POWERSHIP AND FSRU 13 GAS LINES 13 TRANSMISSION LINE 16 SWITCHING STATION 17

ALL LISTED AND SPECIFIED ACTIVITIES TRIGGERED IN TERMS OF NEMA AND NEM: AQA 21

PROJECT LOCALITY 31 SITE ACCESS, CONSTRUCTION ROUTES AND PROPOSED LAYDOWN AREAS 34

3 ALTERNATIVES ASSESSED IN THE EIA PROCESS 36

APPROVED SITE 36

DEVELOPMENT FOOTPRINT (LAYOUT) ALTERNATIVES ASSESSED IN EIA 36 ALTERNATIVES IN SCOPING REPORT (PLAN OF STUDY FOR EIA) 36 LAYOUT DEVIATIONS FROM THE SCOPING REPORT 36 ALTERNATIVES ASSESSED IN THE EIA 37 NO-GO OPTION 42

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4 SITE DESCRIPTION OF SURROUNDING LAND USE 43

BIOPHYSICAL ENVIRONMENT 43 REGIONAL SETTING AND TOPOGRAPHY 43 CLIMATIC CONDITIONS 43 GEOLOGY AND SOILS 44 GEOHYDROLOGY 46 WETLAND ENVIRONMENT 47 VEGETATION AND FLORA 49 AVIFAUNA 50 MARINE BASELINE 51 COASTAL AND CLIMATE CHANGE 65 AIR QUALITY, NOISE AND VISUAL 66

HERITAGE AND ARCHAELOGY 71 HERITAGE 71 PALAEONTOLOGY 71

SOCIAL AND ECONOMIC CONDITIONS 72 SOCIO-ECONOMIC 72

5 POLICY AND LEGISLATIVE FRAMEWORK 73

NATIONAL REGULATORY FRAMEWORK 73 NATIONAL LEGISLATION 73 NATIONAL ENVIRONMENTAL MANAGEMENT: INTEGRATED COASTAL MANAGEMENT ACT 24 OF 2008 76 PROVINCIAL LEGISLATION AND PLANNING 84 LOCAL LEGISLATION AND PLANNING 85

INTERNATIONAL AGREEMENTS 85

6 MOTIVATION, NEED AND DESIRABILITY 87

PROPOSED DEVELOPMENT 87

THE ACTIVITY IN THE CONTEXT OF THE PREFERRED DEVELOPMENT FOOTPRINT WITHIN THE APPROVED SITE 99

7 PUBLIC PARTICIPATION PROCESS 100

PRE-APPLICATION CONSULTATION 100

REGISTERED INTERESTED AND AFFECTED PARTIES 100

LANDOWNER NOTIFICATION 100

NOTIFICATION OF INTERESTED AND AFFECTED PARTIES – SCOPING PHASE 101 SITE NOTIFICATION 101 ADVERTISEMENTS 102 BACKGROUND INFORMATION DOCUMENT: 103 vi

PUBLIC MEETING: 103 PUBLIC REVIEW OF THE DRAFT SCOPING REPORT: 104 COMMENTS RECEIVED ON THE DRAFT SCOPING REPORT: 104

PUBLIC PARTICIPATION DURING EIA PHASE 105 MAINTENANCE OF I&AP DATABASE 105 REQUIREMENTS OF THE APPROVED PP PLAN 105 PUBLIC MEETING 106 PUBLIC REVIEW OF DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT 106 COMMENTS AND RESPONSES TRAIL REPORT 106 SUMMARY OF ISSUES RAISED BY I&APS 107

NOTIFICATION OF ENVIRONMENTAL AUTHORISATION 109

8 ENVIRONMENTAL IMPACT ASSESSMENT 110

OVERVIEW OF EIA PROCESS 110

IMPACT ASSESSMENT METHODOLOGY 111 TERRESTRIAL ECOLOGY 113 AVIFAUNA 114 WETLAND 115 HYDROPEDOLOGY 116 RIVER AND RIPARIAN (AQUATIC) 117 SURFACE WATER (HYDROLOGY) 118 GROUNDWATER (GEOHYDROLOGY) 118 CLIMATE CHANGE 118 ESTUARY 120 MARINE ECOLOGY 120 AIR QUALITY 122 HERITAGE, ARCHAEOLOGY AND PALAEONTOLOGY 125 RISK ASSESSMENT 125 SOCIO-ECONOMIC 126 LANDSCAPE AND VISUAL IMPACT ASSESSMENT 128 NOISE 129

IMPACT ASSESSMENT FINDINGS 132 TERRESTRIAL ECOLOGICAL IMPACTS 132 AVIFAUNAL IMPACTS 139 WETLAND IMPACTS 141 HYDROPEDOLOGICAL IMPACTS 141 RIVER AND RIPARIAN (AQUATIC) IMPACTS 144

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SURFACE WATER (HYDROLOGY) IMPACTS 144 GROUNDWATER IMPACTS 145 CLIMATE CHANGE IMPACTS 148 ESTUARINE IMPACTS 153 MARINE IMPACTS 163 AIR QUALITY IMPACTS 163 HERITAGE, ARCHAEOLOGY AND PALAEONTOLOGICAL IMPACTS 164 MAJOR HAZARDS IMPACTS 167 SOCIO-ECONOMIC IMPACTS 169 VISUAL IMPACTS 176 NOISE IMPACTS 177 CUMULATIVE IMPACTS 181 DECOMMISSIONING PHASE IMPACTS 190

ENVIRONMENTAL IMPACT STATEMENT 191 SUMMARY OF FINDINGS OF ENVIRONMENTAL IMPACT ASSESSMENT 191

PROPOSED IMPACT MANAGEMENT OUTCOMES 193

SCOPING REPORT AND PLAN OF STUDY DEVIATIONS 195

ASSUMPTIONS, UNCERTANITIES AND GAPS IN KNOWLEDGE 198

RECOMMENDED ALTERNATIVES 207

EAP’S OPINION AND RECOMMENDED CONDITIONS OF AUTHORISATION 211

10 REFERENCES 212

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Table of Figures

FIGURE 2-1: TYPICAL STRINGING YARD 15

FIGURE 2-2 TYPICAL LAUNCHWAY ACROSS BEACH 15

FIGURE 2-3 REPRESENTATION OF THE GLOBAL LNG SUPPLY 20

FIGURE 2-4: MAP SHOWING THE PROPOSED GAS TO POWER POWERSHIP PROJECT – PORT OF SALDANHA. 32

FIGURE 2-5 GOOGLE IMAGE SHOWING PROJECT DETAILS. 33

FIGURE 2-6 GOOGLE MAP SHOWING EXISTING ACCESS ROAD SYSTEM TO THE PORT OF SALDANHA 34

FIGURE 2-7 GOOGLE IMAGE SHOWING LAYDOWN AREA 1. 35

FIGURE 2-8 GOOGLE IMAGE SHOWING LAYDOWN AREA 2. 35

FIGURE 3-1: ALTERNATIVE 1 AND 2: POSITION OF POWERSHIP WITHIN SMALL BAY AND FSRU WITHIN BIG BAY. 38

FIGURE 3-2 GOOGLE IMAGE SHOWING THE GAS PIPELINE ALTERNATIVES 39

FIGURE 3-3 TRANSMISSION LINE TO AURORA-SALDANHA STEEL NETWORK 40

FIGURE 3-4 PROPOSED SWITCHING STATION ASSOCIATED WITH ALTERNATIVE 1 ONLY 40

FIGURE 3-5 GOOGLE IMAGE SHOWING ALTERNATIVE 2 TO THE EXISTING BLOUWATER SUBSTATION 41

FIGURE 4-1: AVERAGE TEMPERATURE AND RAINFALL – SALDANHA BAY (METEOBLUE, 2020) 44

FIGURE 4-2 LAND MORPHOLOGY CONCEPT (ALMOND, 2016) 45

FIGURE 4-3 ESTIMATED SOIL DISTRIBUTION (ARC, 2006) 46

FIGURE 4-4: GROUNDWATER USERS IDENTIFIED IN THE STUDY AREA 47

FIGURE 4-5: MAP OF THE WMA, SUB-WMA AND QUATERNARY CATCHMENT THAT FALL WITHIN THE PROPOSED DEVELOPMENT. 48

FIGURE 4-6 LOCATION OF THE LANGABAAN LAGOON RELATIVE TO THE PORT OF SALDANHA INCLUDING THE EFZ IN BLUE 49

FIGURE 4-7 IMPORTANT BIRD AREAS 51

FIGURE 4-8 LOCATION AND DEPTH RANGES OF SITES IN SMALL BAY AND BIG BAY ANCHOR (2020) 54

FIGURE 4-9 GRACILARIA GRACILIS WASHED UP ON BEACHES IN SMALL BAY, SALDANHA BAY 57

FIGURE 4-10 ANNUAL TRENDS IN THE ABUNDANCE AND BIOMASS OF BENTHIC MACROFAUNA IN SMALL BAY AND BIG BAY 58

FIGURE 4-11 VARIATION IN THE SPECIES DIVERSITY OF BENTHIC MACROFAUNA IN SMALL BAY AND BIG BAY (ANCHOR, 2020) 59

FIGURE 4-12 CURRENT LAYOUT OF PORT OF SALDANHA 65

FIGURE 4-13 NOISE SENSITIVE AREAS 68

FIGURE 4-14 LANDCOVER MAP OF SALDANHA BAY 70

FIGURE 4-15: SURFACE GEOLOGY 71

FIGURE 6-1: UNITED NATIONS SUSTAINABLE DEVELOPMENT GOALS (SOURCE: UN GENERAL ASSEMBLY, 21 OCTOBER 2015) 88 ix

FIGURE 6-2: EXTRACT FROM THE CSIR REPORT 90

FIGURE 6-3 PORT OF SALDANHA BAY SHORT-TERM LAYOUT 97

FIGURE 8-1 NATIONAL BIRD SENSITIVITY IN SALDANHA BAY 114

FIGURE 8-2 WETLAND DELINEATION 116

FIGURE 8-3 SALDANHA BAY GHG EFFICIENCY AT VARYING OPERATIONAL LEVELS 119

FIGURE 8-4 PREDICTED NOISE LEVELS DURING THE OPERATIONAL PHASE OF THE PROJECT 129

FIGURE 8-5 NOISE LEVEL AT RECEIVERS DURING OPERATIONAL PHASE 130

FIGURE 8-6 PROPOSED GAS TO POWERSHIP PROJECT ALTERNATIVES 208

List of Tables

TABLE 1-1: INDEPENDENT EAP DETAILS 3

TABLE 1-2: DETAILS OF SPECIALIST AND TECHNICAL TEAM 4

TABLE 1-3 PRESCRIBED CONTENTS OF THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT 5

TABLE 2-1: IMAGES OF VARIOUS POWERSHIP 12

TABLE 2-2 APPLICABLE LISTED ACTIVITIES 21

TABLE 2-3: APPLICABLE LISTED ACTIVITIES DETAILS OF THE LISTED ACTIVITY 30

TABLE 2-4: MINIMUM EMISSION STANDARDS IN MG/NM3 FOR SUBCATEGORY 1.5 30

TABLE 2-5: LOCATION OF THE PROPOSED ACTIVITY 31

TABLE 2-6: PROPERTY DESCRIPTION & 21 DIGIT SG CODE – AS PER OPTIONS PRESENTED IN SECTION 3 31

TABLE 3-1: DETAILS OF PROPOSED ROUTE GAS PIPELINE ROUTE ALTERNATIVES 39

TABLE 3-2 TABLE OF ALTERNATIVE 1 ROUTE TO AURORA -SALDANHA STEEL NETWORK SWITCHING STATION 41

TABLE 3-3 DETAILS OF TRANSMISSION LINE FROM POWERSHIP IN BIG BAY TO TOWER 1 OR 2 41

TABLE 3-4 DETAILS OF TRANSMISSION LINE FROM POWERSHIP IN SMALL BAY TO TOWER 1 42

TABLE 4-1 TRACE METAL CONCENTRATIONS (MG/KG) IN SURFACE SEDIMENT FROM SITES IN SMALL BAY AND BIG BAY 55

TABLE 4-2 LOCATION OF NOISE SENSITIVE AREAS 67

TABLE 4-3: TYPICAL RATING LEVEL FOR NOISE IN VARIOUS DISTRICT TYPES 69

TABLE 5-1: CATEGORIES OF ENVIRONMENTAL COMMUNITY / GROUP RESPONSE (SANS 10103:2008). 81

TABLE 5-2: APPLICABLE PROVINCIAL PLANS, STRATEGIES AND PROGRAMMES 84

TABLE 5-3: APPLICABLE LEGISLATION – REGIONAL AND LOCAL PLANNING FRAMEWORKS 85

TABLE 8-1 MINIMUM EMISSION STANDARDS IN MG/NM3 FOR RECIPROCATING ENGINES 123

TABLE 8-2 ANNUAL EMISSIONS FROM THE POWERSHIP PROJECT 123

TABLE 8-3 MAXIMUM PREDICTED AMBIENT ANNUAL SO2, NO2 AND PM10 CONCENTRATIONS IN ΜG/M3 AND THE PREDICTED 99TH

PERCENTILE CONCENTRATIONS FOR 24-HOUR AND 1-HOUR AVERAGING PERIODS, WITH THE SOUTH AFRICAN NAAQS 124 x

TABLE 8-4 AIR QUALITY IMPACT SCORES 125

TABLE 8-5 IMPACT OF THE NO-GO ALTERNATIVE 179

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Appendices Appendix A - Site Plan Appendix G - EMPR Appendix A1 - DEFF Layout Plan Appendix H - Addition Information Appendix A2 - Sensitivity Map Appendix H1 - Regulations Appendix A3 - DEFF Cumulative Map Appendix A4 - Locality Map Appendix I - Specialist Studies Appendix A5 - Proposed Mooring positions Appendix I1 - Terrestrial Ecological Assessment Appendix A6 - Proposed Gas Pipeline Alternatives Appendix I2 - Heritage and Paleontology Impact Assessment Appendix A7 - Laydown Areas Appendix I3 - Wetland Delineation and Functional Assessment Appendix A8 - Proposed Transmission Routes Appendix I4 - Geohydrological Assessment Appendix A9 - Proposed Switching Station Appendix I5 - Hydrological Assessment Appendix B - Facility Illustration Appendix I6 - Aquatic Assessment Appendix B1 - Khan Class Illustrations Appendix I7 - Hydropedology Assessment Appendix B2 - 132 KV Twin Conductor Tower Illustration Appendix I8 - Avifaunal Assessment Appendix B3 - 132 KV Switching Station Appendix I9 - Estuarine and Coastal Assessment Appendix B4 - 132 KV Steel Pole Intermediate Double Appendix I10 - Marine Ecological Assessment Circuit Structure for Twin Tern Conductor Appendix B5 - 132 KV Steel Pole Angle Strain Structure Appendix I11 - Air Quality Impact Assessment Appendix C - Impact Matrix Appendix I12 - Climate Change Impact Assessment Appendix D - Public Participation Appendix I13 - Landscape and Visual Impact Assessment Appendix D1: Ppp Summary Appendix I14 - Major Hazardous Risk Assessment Appendix D2: Approved Pp Plan Appendix I15 - Socio-Economic Assessment Appendix D3: Notifications, Notices And Flyers Appendix I16 - Noise Impact Assessment Appendix D4: Proof Of Notifications, Notices And Flyers Appendix J - Technical Reports Appendix D5: Advertisements Appendix J1- Marine Vessel Traffic Assessment Appendix D6: Proof Of Advertisement Appendix J2 - Alternative Powership Location Appendix D7: Iap Database Appendix J2 - Cooling Water Dispersion Modelling for 100% Load Case Appendix D8: Bid &Comment Form Appendix J3 - Pipeline Design Basis Appendix D9 - Comments and Responses Report for Appendix J4 - Gas Pipeline Design Scoping Appendix D10 - IAP Correspondence Appendix J5 - Mooring Design Appendix D11 - Other Media Sources Appendix J6 - Khan Class Powership Steam turbine Appendix D12 – Minutes- Attendees List and Appendix J7 - Khan Class Powership Firefighting and Presentation from Public Meeting Detection plan Appendix E - Undertaking under Oath and Details of Appendix J8 - Water Balance EAP Appendix F - DEFF Correspondence and Approval of Appendix J9 - Geotechnical Assessment FSR

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List Of Abbreviations

BID Background Information Document BOG Boil of Gas CBAs Critical Biodiversity Areas CWDP Coastal Waters Discharge Permit dB Decibel DAFF Department of Agriculture, Forestry and Fisheries DEDEAT Department of Economic Development, Environmental Affairs and Tourism DEFF Department of Environment, Forestry and Fisheries DFP Development Framework Plan DWA Department of Water Affairs DWS Department of Water and Sanitation DOT Department of Transnet DWAF Department of Water Affairs and Forestry EA Environmental Authorisation EAP Environmental Assessment Practitioner ECA Environment Conservation Act EIA Environmental Impact Assessment EIR Environmental Impact Report EMP Environmental Management Plan EMPr Environmental Management Programme EMS Environmental Management Systems G2P Gas to Power GG Government Gazette GN Government Notice I&APs Interested and Affected Parties IDP Integrated Development Plan IDZ Industrial Development Zone IEP Integrated Energy Planning IUCN International Union for Conservation of Nature IRT Issues and Response Trail MPA Marine Protected Area MBM Multi-Buoy Mooring NEMA National Environmental Management Act NEM:BA National Environmental Management: Biodiversity Act NEM:ICMA National Environmental Management: Integrated Coastal Management Act NERSA National Energy Regulator South Africa NGO Non-Governmental Organisations NFEPA National Freshwater Ecosystems Priority Areas NIRP National Integrated Resource Planning NWA National Water Act PoS Plan of Study PPP Public Participation Process SANBI South African National Biodiversity Institute xiii

SANS South African National Standards SCC Species of Conservation Concern SDF Spatial Development Framework SEA Strategic Environmental Assessment SEZ Special Economic Zone TOR Terms of Reference TNPA Transnet National Ports Authority

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

THIS REPORT WAS COMPILED BY TRIPLO4 SUSTAINABLE SOLUTIONS (PTY) LTD IN TERMS OF APPENDIX 3 TO GNR 982 (AS AMENDED)

1 INTRODUCTION

Project Title The Draft Environmental Impact Assessment Report for the Proposed Gas to Power Powership Project at the Port of Saldanha, Saldanha Local Municipality, Western Cape.

Background Triplo4 Sustainable Solutions (Pty) Ltd has been appointed by Karpowership SA (Pty) Ltd (Karpowership) to undertake the environmental impact assessment (EIA) and manage the application for Environmental Authorisation for the proposed Gas to Power Powership at Port of Saldanha, located within ward 5 of the Saldanha Bay Local Municipality. The Competent Authority responsible for evaluating and deciding on the application for environmental authorisation is the Department of Environment, Forestry & Fisheries (DEFF). The same EIA will inform Karpowership’s application for an atmospheric emission licence (AEL). The licensing authority for the AEL is also DEFF, although a different branch within the Department)

The applicant is Karpowership SA Pty Ltd, a South African company with 51% owned by Karpowership, a member of Karadeniz Energy Group, Istanbul, Turkey which owns, operates and builds Powership (floating power plants). Since 2010, 25 Powership have been completed with total installed capacity exceeding 4,100 MW globally with an additional 4,400 MW of Powership either under construction or in the pipeline.

The proposed Project has been formulated in response to the Request for Proposals (RFP) for New Generation Capacity under the Risk Mitigation IPP Procurement Programme issued by the Department of Mineral Resources and Energy to alleviate the immediate and future capacity deficit as well as the limited, unreliable and poorly diversified provision of power generating technology with its adverse environmental and economic impacts. The RFP stipulates stringent environmental, social and economic criteria, for example, the shift from coal and LPG to NG as a cleaner and more cost effective resource, BBBEE criteria and skills development. The Emergency/Risk Mitigation Power Purchase Procurement Program (2000 MW) (ERMPPPP) has been declared a Strategic Integrated Project (SIP) in terms of the Infrastructure Development Act 23 of 2014 by the Presidential Infrastructure Coordinating Commission Council on 24 July 2020 under SIP 20. At the time of publication of this report, the preferred bidder status had not been confirmed.

The project consists of three key parts: Liquefied Natural Gas, electricity generation and dispatch of electricity into the national power grid. Powership are fully integrated floating power plants. Powership can be installed at a coastal site where there is an available substation for electrical connection and suitable marine conditions for berthing or mooring. Mooring will be followed by interconnection of the Powership to the national power grid. Finally, fuel connection takes place via pipeline.

Karpowership proposes to moor a Powership and Floating Storage Regasification Unit (FSRU), connected by a part sub-sea, part land-based gas pipeline in the Port of Saldanha to generate electricity which will be evacuated by means of a double circuit twin Chicadee conductor 132kV line. This line will interconnect the Powership to the

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

National Grid utilising the existing Aurora- Saldanha Steel network via a new 132kV on shore switching station. In addition, a Liquefied Natural Gas Carrier (LNGC) will supply the FSRU over a 1 to 2 day period approximately every 20 days. The proposed design capacity for the Saldanha Powership is 415MW, which comprises a total of 21 reciprocating engines and 2 steam turbines.

The proposed technology for the production of electricity through natural gas-fired reciprocating engines and steam engines is designed to improve efficiency of energy generation. Construction is limited to transmission and gas supply lines as the ships are built internationally and arrive fully equipped in the Port ready for operation.

The proposed Port based activities (Powership, FSRU, gas pipeline, temporary LNG carrier) are situated within the Port of Saldanha areas managed by Transnet Port National Authority (TNPA) and the proposed transmission line from the port to the Aurora- Saldanha Steel network traverses various properties owned by Transnet and other private industry landowners.

Summary of “Environmental Licensing” Requirements Prior to the commencement of the proposed Gas to Power Project at Port of Saldanha Project, the following key “environmental licences”are required from the following competent authorities namely:

. Environmental authorisation from the Department of Environment, Forestry & Fisheries (DEFF) in terms of the National Environmental Management Act 107 of 1998 (NEMA), the EIA Regulations, 2014 (as amended) and the EIA Regulations Listing Notices 1, 2 and 3 (as amended). . An atmospheric emission licence (AEL) in terms of the National Environmental Management: Air Quality Act 39 of 2004) (NEM:AQA) and the Listed Activities and Associated Minimum Emission Standards identified in terms of Section 21 of NEMAQA, 2013 (as amended). The licensing authority is also DEFF, but a separate Branch within the same Department.

Purpose of this Report 2014 NEMA EIA Regulations (as amended), Appendix 3. 1 the objective of the environmental impact assessment process is to, “through a consultative process: a) determine the policy and legislative context within which the activity is located and document how the proposed activity complies with and responds to the policy and legislative context; b) describe the need and desirability of the proposed activity, including the need and desirability of the activity in the context of the development footprint on the approved site as contemplated in the accepted scoping report; c) identify the location of the development footprint within the approved site as contemplated in the accepted scoping report based on an impact and risk assessment process inclusive of cumulative impacts and a ranking process of all the identified development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects of the environment; d) determine the – i. nature, significance, consequence, extent, duration and probability of the impacts occurring to inform identified preferred alternatives; and ii. degree to which these impacts— aa) can be reversed;

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

bb) may cause irreplaceable loss, of resources, and cc) can be avoided, managed or mitigated; e) identify the most ideal location for the activity within the development footprint of the approved site as contemplated in the accepted scoping report based on the lowest level of environmental sensitivity identified during the assessment; f) identify assess, and rank the impacts the activity will impose on the development footprint on the approved site as contemplated in the accepted scoping report through the life of the activity; g) identify suitable measures to avoid, manage or mitigate identified impacts; and h) identify residual risks that need to be managed and monitored.

The draft EIA Report documents the findings of the EIA as per the reporting requirements of the EIA Regulations, 2014 (as amended).

Independent Environmental Assessment Practitioner 2014 NEMA EIA Regulations (as amended), Appendix 3. 3. (1) (a) An environmental impact assessment report must contain the information that is necessary for the competent authority to consider and come to a decision on the application, and must include— (a) details of—(i) the EAP who prepared the report; and (ii) the expertise of the EAP, including a curriculum vitae;

Please see Appendix E for EAP Declaration and full Curriculum Vitae.

Table 1-1: Independent EAP Details

EAP Triplo4 Sustainable Solutions EAP Hantie Plomp Educational qualifications Masters in Environmental Management Professional Registrations EAPASA; SACNASP; AP with GBCSA Voluntary Memberships IAIAsa; IWMSA; IODSA, WISA Experience at environmental > 20 Years assessments (yrs.) Postal Address P.O. Box 6595 Zimbali, 4418 Telephone Number 032 946 3213 Cell Number 083 308 8003 Fax Number 032 946 0826 Email Address [email protected]

Assisted by: Ms. Melissa Gopaul Educational qualifications Honours in Environmental Management Professional Registrations SACNASP (Pri.Sci.Nat) | EAPASA Voluntary Memberships IAIAsa; IWMSA; WISA Experience at environmental >7 years assessments (yrs.)

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

EAP Triplo4 Sustainable Solutions Assisted By: Ms. Shanice Singh Educational qualifications Honours in Environmental Management Professional Registrations EAPASA Voluntary Memberships IAIAsa Experience at environmental >5 years assessments (yrs.)

Assisted By: Zayd Hoosen Educational qualifications MSc Environmental Sciences Professional Registrations SACNASP (Pri.Sci.Nat) Voluntary Memberships IAIAsa Experience at environmental >6 years assessments (yrs.)

Assisted By: Nerita Sewnath Educational qualifications BSc Environmental Sciences Voluntary Memberships IAIAsa Experience at environmental >4 years assessments (yrs.)

Specialist Studies Specialist studies have been undertaken to inform the EIA process. The specialist studies involved the gathering of baseline data (desktop and site visit, where applicable) relevant to identifying and assessing environmental, socio- economic and heritage impacts that may occur as a result of the proposed project. Specialist studies have also recommended mitigation measures to minimise potential impacts or optimisation measures to enhance potential benefits as well as monitoring requirements, where necessary. These findings and recommendations have been incorporated into the assessment (Chapter 8) and the EMPr. The methodologies applied to each specialist study are described in the specialist reports attached as appendices to this EIA and EMPr. The Specialists and technical experts who provided input to the EIA process are listed in the Table 1-2.

Table 1-2: Details of Specialist and Technical Team Specialist Field Company & Specialist Wetland Delineation and Functionality Triplo4 - Mr. Suheil M Hoosen Terrestrial Ecological (Transmission Lines) Ms Leigh Anne de Wet Heritage & Palaeontology Impact ACRM - Mr. Jonathan Kaplan Estuarine Impacts GroundTruth - Ms Catherine Meyer & Coastwise Consulting -Ms Tandi Breetzke Climate Change Impact Themis - Mr. Luke Moore Geohydrological, Hydrology & Hydropedology GCS Water and Environmental Consultants - Mr. Henri Botha & Mr. Gareth Preen

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Hydrological & 1:100 Year Floodline GCS Water and Environmental Consultants - Mr. Henri Botha & Mr. Gareth Preen Aquatic Aspects GCS Water and Environmental Consultants - Ms Karin Lukes & Mr. Gareth Preen Major Hazardous Installation Occutech cc - Mr. Harold Gaze Marine Ecology Lwandle - Dr Robin Carter & Ms Laura Weston Air Quality Impact uMoya-Nilu - Dr Mark Zunckel Socio-Economic Impact Urban-Econ - Mr. Eugene de Beer Noise Safetech - Dr Brett Williams Avifauna Birds & Bats Unlimited - Dr Rob Simmons Landscape and Visual Impact Assessment Environmental Planning and Design – Mr Jon Marshall Technical expertise Company & Expert Thermal Plume & Marine Traffic PRDW – Mr Warwick Donaldson & Mr Derek Paul Power Evacuation Routes SIRIS – Dr. Kishoor Pitamber Greenhouse Gas Emissions Southern Cross Capacitating Corporation (Pty) Ltd Geotechnical Geosure – Mr A. Ramroop Water Balance GCS Water and Environmental Consultants - Mr. Henri Botha & Mr. Gareth Preen

EIA Reporting Requirements as per EIA Regulations 2014 (as amended) Table 1-2 outlines the requirements of the Environmental Impact Assessment Report as per the NEMA EIA Regulations, 2014 (as amended). According to Appendix 3 (1) “An environmental impact assessment report must contain the information that is necessary for the competent authority to consider and come to a decision on the application, and must include…” the information outlined in Table 1-2 below. This includes the information elicited through the Public Participation Process (PPP) prescribed by Regulations 39 to 44 of the EIA Regulations, 2014 (as amended) and described in Chapter 7 of the EIA Report.

Table 1-3 Prescribed contents of the Environmental Impact Assessment Report (Appendix 3 of the EIA Regulations, 2014) Relevant section in Requirement description Relevant section in GNR. 982 this report (a) Details of- (i) The EAP who prepared the report; and Section 1.5 (ii) The expertise of the EAP, including a curriculum vitae; Appendix E (b) The location of the (i) The 21 digit Surveyor General code of each cadastral land Section 2.3 development footprint of parcel; the activity on the (ii) Where available, the physical address and farm name; approved site as (iii) Where the required information in items (i) and (ii) is not contemplated in the available, the coordinates of the boundary of the property or accepted scoping properties; report, including - c) A plan which locates (i) A linear activity, a description and coordinates of the

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Relevant section in Requirement description Relevant section in GNR. 982 this report the proposed activity or corridor in which the proposed activity or activities is to be Section 2.3 & activities applied for as undertaken; or Appendix A and B well as the associated (ii) On land where the property has not been defined, the structures and coordinates within which the activity is to be undertaken; infrastructure at an appropriate scale (d) A description of the (i) All listed and specified activities triggered and being Section 2.2 scope of the proposed applied for; activity, including (ii) A description of the activities to be undertaken, including Section 2.1 associated structures and infrastructure; (e) A description of the policy and legislative context within Section 5 which the development is located and an explanation of how the proposed development complies with and responds to the legislation and policy context; (f) A motivation for the need and desirability for the proposed Section 6 development, including the need and desirability of the activity in the context of the preferred development footprint within the approved site as contemplated in the accepted scoping report (g) motivation for the preferred development footprint within the approved site as contemplated in the accepted scoping report; (h) a full description of (i) details of the development footprint alternatives Section 3 the process followed to considered; reach the proposed (ii) details of the public participation process undertaken in Section 7 and development footprint terms of regulation 41 of the Regulations, including copies of Appendix D within the approved site the supporting documents and inputs; as contemplated in the (iii) a summary of the issues raised by interested and Section 7 and accepted scoping affected parties, and an indication of the manner in which the Appendix D report, including: issues were incorporated, or the reasons for not including them; (iv) the environmental attributes associated with the Section 4 development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects; (v) the impacts and risks identified including the nature, Section 8.4 significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts— (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Relevant section in Requirement description Relevant section in GNR. 982 this report (cc) can be avoided, managed or mitigated; (vi) the methodology used in determining and ranking Section 8 2 the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks; (vii) positive and negative impacts that the proposed Section 8.4 activity and alternatives will have on the environment and on the community that may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects; (viii) the possible mitigation measures that could be Section 8.4 and applied and level of residual risk; Appendix G (ix) if no alternative development footprints for the Not Applicable activity were investigated, the motivation for not considering such; and (x) a concluding statement indicating the location of the Section 9 preferred alternative development footprint within the approved site as contemplated in the accepted scoping report (i) a full description of (i) a description of all environmental issues and risks Section 8 and the process undertaken that were identified during the environmental impact Appendix I to identify, assess and assessment process; and rank the impacts the (ii) an assessment of the significance of each issue and activity and associated risk and an indication of the extent to which the issue and structures and risk could be avoided or addressed by the adoption of infrastructure will mitigation measures impose on the preferred development footprint on the approved site as contemplated in the accepted scoping report through the life of the activity, including (j) an assessment of (i)cumulative impacts; Section 8.4 and each identified (ii) the nature, significance and consequences of the impact Appendix I potentially significant and risk; impact and risk, (iii) the extent and duration of the impact and risk; including— (iv) the probability of the impact and risk occurring; (v) the degree to which the impact and risk can be reversed; (vi) the degree to which the impact and risk may cause irreplaceable loss of resources; and vii) the degree to which the impact and risk can be mitigated;

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Relevant section in Requirement description Relevant section in GNR. 982 this report (k) where applicable, a summary of the findings and Section 8 and recommendations of any specialist report complying with Appendix I Appendix 6 to these Regulations and an indication as to how these findings and recommendations have been included in the final assessment report (l) an environmental (i) a summary of the key findings of the environmental impact Section 8 and 9 impact statement which assessment contains (ii) a map at an appropriate scale which superimposes the Appendix A – Site proposed activity and its associated structures and Plans infrastructure on the environmental sensitivities of the preferred development footprint on the approved site as contemplated in the accepted scoping report indicating any areas that should be avoided, including buffers; and (iii) a summary of the positive and negative impacts and risks Section 8.4 of the proposed activity and identified alternatives; (m) based on the assessment, and where applicable, Section 8.6 recommendations from specialist reports, the recording of proposed impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation (n) the final proposed alternatives which respond to the impact Section 9 management measures, avoidance, and mitigation measures identified through the assessment; (o) any aspects which were conditional to the findings of the Section 9 assessment either by the EAP or specialist which are to be included as conditions of authorisation; (p) a description of any assumptions, uncertainties and gaps in Section 8.8 knowledge which relate to the assessment and mitigation measures proposed; (q) a reasoned opinion as to whether the proposed activity Section 9 should or should not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation; (r) where the proposed activity does not include operational Not Applicable aspects, the period for which the environmental authorisation is required and the date on which the activity will be concluded and the post construction monitoring requirements finalised; (s) An undertaking (i) The correctness of the information provided in the report; Appendix E - under oath or (ii) The inclusion of comments and inputs from stakeholders Declaration and interested and affected parties; and

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Relevant section in Requirement description Relevant section in GNR. 982 this report affirmation by the EAP (iii) Any information provided by the EAP to interested and in relation to - affected parties and any responses by the EAP to comments or inputs made by interested or affected parties; (t) where applicable, details of any financial provision for the Not applicable rehabilitation, closure, and ongoing post decommissioning management of negative environmental impacts (u) an indication of any (i) any deviation from the methodology used in determining Section 8.7 deviation from the the significance of potential environmental impacts and risks; approved scoping and report, including the (ii) a motivation for the deviation plan of study, including (v) any specific information that may be required by the Appendix F - DEFF competent authority; and Correspondence (w) any other matters required in terms of section 24(4)(a) and Not applicable (b) of the Act. (2) Where a government notice gazetted by the Minister Appendix I – provides for any protocol or minimum information Specialists considered requirement to be applied to an environmental impact relevant assessment report the requirements as indicated in such Environmental notice will apply. Themes.

Appendix G – Transmission Line EMPr.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Report Structure The EIA Report has been structured as follows – . Executive Summary . Chapter 1 – Introduction . Chapter 2 – Project Description: Provides a description of the proposed development, the properties on which the development is to be undertaken and the location of the development on the property. The technical details of the project are also provided in this Chapter. . Chapter 3 – Alternatives: . Chapter 4 – Description of Environment: Provides a brief overview of the biophysical and socio-economic characteristics of the site and its environs that may be affected by the proposed development, compiled largely from published information, but supplemented by information from a site visit. . Chapter 5 – Policy and Legislative Framework: Identifies all the legislation and guidelines that have been considered in the preparation of the EIA Report and project compliance. . Chapter 6 – Motivation, Need and Desirability. . Chapter 7 – Public Participation Process . Chapter 8 – EIA . Chapter 9 – Description of the process undertaken to identify impacts. . Chapter 10 – Concluding Statement and Recommendations . Chapter 11 - References: Cites any texts referred to during preparation of this report. . Appendices: Containing all supporting information, environmental management programme, including specialist studies, public participation record.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

2 DESCRIPTION OF THE PROPOSED ACTIVITY

2014 EIA Regulations (as amended), Appendix 3 - (d) (ii) a description of the activities to be undertaken, including associated structures and infrastructure.

Description of the Activities to be Undertaken Including Associated Structure and Infrastructure

The Karpowership project generates electricity from a floating mobile Powership moored in the Port of Saldanha Bay. Two ships will be berthed during the proposed project lifespan of 20 years – a Floating Storage Regasification Unit (FSRU), and the Powership. In addition, a Liquefied Natural Gas Carrier (LNGC) will dock on a short term basis (1 to 2 days) to supply Liquid Natural Gas (LNG) to the FSRU approximately every 20 days. The natural gas once degasified is pumped from the FSRU to the Powership via a gas pipeline. The proposed design capacity for the Powership is 415MW, comprising 21 reciprocating engines having an approximate heat input of more than 10MW each. The 2 steam turbines have a heat input of 15.45 MW each. The power that is generated is then converted by the on-board High Voltage substation (capacity of 110 – 170kV) and the electricity evacuated by means of a double circuit twin Chicadee conductor 132kV line. This line will interconnect the Powership to the National Grid utilising the existing Aurora- Saldanha Steel network via a new 132kV on shore switching station. Alternatively, the power that is generated is then converted by the on-board High Voltage substation (capacity of 110 – 170kV) and the electricity evacuated via a 132kV transmission line over a distance of approximately 7.5 km to the Eskom Blouwater Substation which feeds into the national grid.

The project is anticipated to make a notable contribution towards the national and local economy. There will be a significant number of local employees for both the construction and operation period which will exceed the Economic Development criteria that must be reached under the terms of the RMIPPPP. Please refer to Section 8.3.1.5 of this report for further details on the findings from the Socio-Economic study.

The Powership and the Floating Storage Regasification Unit (FSRU) are to be moored within the Port of Saldanha within the Port Limits (NPP, 2019). The FSRU proposed will be adjacent to the existing LPG MBM facility in Big Bay. The position of the Powership will be adjacent to the existing Sunrise LPG MBM facility and approximately 3,8km away from the beach.

The proposed Powership, FSRU, temporary LNGC and gas line, will be located in the Port of Saldanha under the jurisdiction of the Transnet National Port Authority (TNPA) while the transmission line is across Transnet properties as well as private properties currently used for industrial activities.

Powership, FSRU and LNG carrier The Powership is assembled off-site and will be delivered fully equipped and functional to the Port of Saldanha. Powership with their modular generation capability, allow for greater technical flexibility for load cycling and shedding. The Powership is approximately 289m in length with an approximate breadth of 45m. Because the Powership is equipped with reciprocating engines for power generation, this allows for a reliable supply of electricity with minimal impacts from load profile and number of starts and stops. The Powership is essentially a

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. ship which has been fitted with the necessary equipment, including reciprocating engines, steam turbines, and a high voltage substation to generate and transmit electricity using natural gas as a fuel.

The fuel is supplied by a separate, vessel, a Floating Storage Regasification Unit (FSRU) which stores the liquefied natural gas (LNG) and converts it to a gaseous state for delivery to the Powership through a gas pipeline. The FSRU with an overall length of approximately 272m with a breadth of 47,2m is made up of a series of pressurised containers.

A LNG carrier shall supply LNG to the FSRU and will temporarily moor over a 1 to 2 day period approximately every 20 days while offloading the LNG cargo. The ship-to-ship transfer of LNG will be managed in accordance to STS operation, the applied standard is Ship to Ship Transfer Guide (Liquefied Gases) - 2nd edition (OCIMF/SIGTTO) via trained personnel to ensure compliance and within quality, health and safety requirements. The fuel lines between the FSRU and the Powership will be via double walled with annular space being inerted and continuously purged with Nitrogen “N2” gas.

Refer to table of figures below, showing examples of Powership, an FSRU and the project concept.

Table 2-1: Images of Various Powership

Image 1: Powership – Khan Class Image 1: Powership – Khan Class

Image 3: Floating Storage & Regasification Unit (FSRU) Image 4: Project Concept

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

FSRU regasifies the required amount of LNG and sends this to the Powership in gaseous form (NG) continuously through a connecting pipeline. The FSRU is specifically designed, constructed and equipped to supply the fuel gas required for the power generator engines installed on the Powership.

Natural gas boil off of LNG on board the FSRU is not flared or vented. The natural boil off is used as fuel for the operation of the FSRU and if in excess, is prioritised for export to the Powership for use in the generation of electrical power. In the event that Boil Off Gas (BOG) is in excess of the base load demand, then arrangements are provided on-board the FSRU for this excess BOG to be burnt in a specialised internal process. Under normal operations it is anticipated that the demand for gas will be significantly in excess of the natural boil off resulting in liquid LNG being re-gasified for export to the Powership. The NG is supplied to the engines. The engines in operation drive the generator shaft to generate electricity, and the heat generated by the engines may be captured and used by additional steam turbines for increased efficiency. The electricity generated is transmitted through the overhead transmission line to the substation to the national grid.

Berthing & Mooring of the Powership and FSRU Berthing and mooring will be conducted by the Port authorities as per the Port’s approved maintenance plans, procedures and requirements, and ships will be located where adequate depths exist.

The operational requirements at the Port cannot accommodate the use of existing berthing infrastructure, and therefore the vessels will be positioned in unused areas of the port and will utilise their own mooring system comprising catenary mooring chains and anchors. No marine structures are planned, and the mooring system for the vessels will be heavy chain lying on the seabed attached to anchors (anchor piles or vertical load anchors) which will become buried in a very short time. The vertical load anchors are by design buried during the installation and the intention is to install the anchor piles such they are flush or below the surrounding sea bed.

No dredging will be required as the mooring locations are positioned in sufficient water depth to safely accommodate the moored vessels. In the process of identification of the potential sites, the existing cargo facilities and the Port’s future short term developments were avoided.

The key criteria for the mooring site are sufficient space for turning the LNG Carrier (LNGC) as well as the approach channel shared with the container terminal to allow the safe passing of other traffic including container vessels, cargo vessels and tugs, and maintain the safety exclusion zone required for the ship-to-ship transfer of the LNG to the FSRU.

The design of the infrastructure has taken into consideration changes in marine conditions as a result of potential climate change impacts (increases) on wind speeds, water levels and wave heights over the lifespan of the project.

Gas Lines A gas line is required between the FSRU and Powership to ensure gas supply for power generation. The pipelines used for natural gas transmission will be made of steel engineered to meet the standards for natural gas pipelines with a diameter of approximately 60cm.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

There are two alternative routes for the onshore section of pipeline being considered which are described in Section 3, and which are dependent on the position of the Powership within the Port of Saldanha.

The subsea section of the gas pipeline connecting the FSRU to the Powership will be routed perpendicular to the coastline and adjacent the existing Liquid Petroleum Gas pipelines and will connect to the FSRU via a flexible marine hose riser. The onshore section of the gas pipeline will follow the existing pipeline servitude along the edge of the Saldanha Iron Ore terminal and across existing port causeway to the Powership mooring location.

It is anticipated that the sea-based section of the pipeline will have a servitude of approximately 10m to allow for mounting and protection. The land-based section will require an anticipated servitude of 3m. The gas pipeline will likely be mounted on small footings requiring minor civil works to construct and install.

The recommended routes subsequent to the EIA process will also need to be approved by Transnet National Port Authority (TNPA).

Site Access The submarine pipeline is to be brought onto site in sections, typically 18m long. The pipeline will be delivered to the site by road truck and welded together in a pipe stringing yard near the launch site. The trucks used to deliver the pipeline sections will therefore require road access to the stringing yard.

Pipeline Assembly Sufficient space near the launch site will therefore be required to undertake the assembly of the pipeline. The proposed location of the stringing yard and launchway is proposed to be adjacent to the old aquaculture basin behind the current iron ore stockyard and is shown on the drawings. A suitable area of hardstanding will be prepared in front of the sand dunes above the beach in the same position approved for the LPG pipeline project in 2017. At this stage it is estimated that an area of 100 m x 150 m will be required. The pipe stringing and fabrication yard will be set up to assemble 29.5 strings which will make up the 3,726m pipeline length. A launchway will be constructed with rollers to transfer the pipeline from the stringing yard to the sea. The launchway will be constructed on the west side of the stringing yard continuing down onto the beach. The launchway typically will consist of concrete pedestals supporting rollers at approximately 10 to 20m centres, over which the pipeline will move, allowing the completed pipeline to be pulled into the sea. This area will be fully rehabilitated after the completion of the installation of the pipeline.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 2-1: Typical Stringing Yard

Figure 2-2 Typical Launchway across beach

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Pipeline Installation The pipeline is to be installed by pulling it from the shore into position using a winch mounted on a barge moored temporarily offshore. As the pipeline is pulled, additional pipe sections are welded on in the stringing yard. The pipeline is placed on the seabed with minimal disturbance to the seabed and weighted with concrete elements to ensure the on-bottom stability of the pipeline during operation. Where necessary the pipeline will be covered with crushed rock to protect the pipeline. Although no dredging is required prior to installation of the pipeline, some seabed preparation in the form of levelling of high spots or placing of crushed stone founding material in low spots may be necessary prior to installing the pipeline. This procedure is comparative to the methodology approved for the installation of the existing LPG pipeline within the Port of Saldanha.

Once the pipeline installation is complete, the laydown site will be rehabilitated to reinstate it to the topographical and environmental condition as was prior to the disturbance during the construction phase of this project.

The above methodology for the preferred proposal for the gas pipeline further detailed in Appendix J3 Pipeline Design Basis. The methodology will also need to be approved by TNPA once preferred bidder status is confirmed.

Transmission Line There are two potential options being considered for connection from the Powership to the National Grid that will ultimately be dependent on Eskom’s requirements:  The power generated on the ship will be converted by the on-board High Voltage substation and transmitted along a double circuit twin Chicadee conductor 132kV line. This new transmission line of approximately 5,7km will interconnect the Powership to the National Grid utilising the existing Aurora- Saldanha Steel network via a new 132kV on shore switching station. Approximately 25 towers are proposed along a 50 metre corridor which includes the working servitude. The servitude, stretching approximately 5,7km from the port to existing Aurora- Saldanha Steel network via a new 132kV on shore switching station the, will have a width of 30m as per Eskom safety specifications.  Alternatively, the power generated on the ship will be converted by the on-board High Voltage substation and transmitted along a 132kV transmission line. A transmission line approximately 7,5km will be installed as part of the project from the Saldanha Port to the Blouwater substation.

Both options traverse properties owned by Transnet and other private industrial landowners. Each tower will cover a maximum footprint of 15m by 15m which will necessitate the clearing of vegetation to allow for the steel lattice towers to be erected.

Access will be via the existing servitude, therefore no additional access roads will be required to be constructed.

Routes options for the transmission lines are presented in the layout alternatives, section 3.1.3 of this report.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Switching Station As per Eskom requirements, an on shore switching station will be required. The switching station will facilitate the control of the incoming lines from the Powership and the outgoing lines to the Aurora-Saldanha Steel network. The switching station will measure approximately 13 000 m2 in size.

Operational Processes and Associated Measures i. Water use and Heat Generation The Powership uses seawater and potable water for cooling the reciprocating engines, condensers and other auxiliaries. The Powership operate a once through cooling system, which abstracts seawater directly for cooling and then discharges it into the sea. Part of the cooling water is processed into potable water through the vaporization process for steam generation (onboard water treatment unit) and non-process water consumption. Seawater is primarily used for steam generation, make up water and for domestic use.

Water supply for domestic use is produced using the onboard water treatment unit. Potable water will, where required, be provided by local suppliers. No bulk water supply is anticipated from the Saldanha Bay Municipality. The Powership also has a sewage treatment unit and oily bilge separator to be utilized while sailing.

The following volume of water required daily is anticipated:  400 litres of drinking water will be required for onboard utilisation;  1010 litres technical water for continuous Steam Turbine Generator (STG) operation; and  25-30 litres of water per engine is required and 200 litres for STG consumption.

No biocides and no other additives are necessary to control bio-fouling in seawater pumping and temperature exchange systems. Part of the cooling seawater is processed into steam through an evaporation process for non- process water consumption.

The Powership will use seawater for cooling the gen-sets and optionally, the steam turbine generators and fresh water generators. The total intake/outlet flow rates range from 2.4 m3/s to 11.4 m3/s and the increase in temperature (ΔT) range from 4°C to 15°C. No chemicals such as chlorine are discharged with the cooling water.

ii. Risks and Possible Explosions Safety performance is focused on risk and on the safe operation of the vessel as well as the containment of the LNG within the containment systems, including the pipeline. The fuel lines between the FSRU and the Powership is equipped with a gas detector in circuit which will identify a leak, so that the fuel gas can be immediately isolated and shut off, the leak identified, and the necessary repairs or replacements made. However, should there be a minor leakage of LNG, it will disperse quickly and rise into the atmosphere very quickly.

In the event of a lightning strike, the high conductivity of the large quantities of metal, with hundreds of square yards of hull in direct contact with the water, causes rapid dissipation of the electrical charge. The Powership, FSRU and LNG carriers are designed to meet stringent lightning protection standards required by the Ship Classification Society. FSRU operations are safeguarded through 100% containment with no LNG interface with the atmosphere. Lightning strikes are easily dissipated by the steel structures without affecting the normal

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. operational aspects of the FSRU, however, in such situations, it is normal practice to cease STS operations and make safe the transfer hoses through inerting and also maintaining the cargo containment without oxygen.

Fire can be extinguished in Powership by means of various methods which include permanently installed systems in the Powership that are able to fill the affected area with CO2 or Hot foam and portable extinguishing systems. Each chamber in the Powership is also equipped with fire detection and alarm equipment (fire detectors, manual call points, alarms, sounders, and bells) in order to detect & locate the origin of the fire.

In addition to using the fixed firefighting systems, portable firefighting equipment and personnel protection equipment are to be used throughout Powership to ensure maximum protection from fire related accidents. Approved drawings on firefighting plans are located throughout the Powership in fireboxes and hung in different locations. In the event of fire drills or actual fire these plans are to be carried out.

iii. Security Measures Powership are equipped with advanced CCTV systems monitoring all areas, inside and out, in addition to surrounding fencing and razor wires to protect against unauthorized entry to the project site from land. Dedicated professional security team personnel are responsible for monitoring and constantly patrolling the vessels to prevent any un-authorized entry or attacks. In addition, prior to deployment of the Powership to the operating location, an independent security risk assessor visits the location, meets local authorities (including port authorities and armed security forces) and provides detailed advice on any additional security measures that should be implemented before or during the operation over and above the proposed Security Plan specific to the project site.

The same independent security advisors visit the vessels shortly after their arrival, immediately after mooring arrangements are completed, to follow up and assess actual operation of the security systems and team. Regular follow up visits and assessments continue, and adaptation of systems and protocols would be made if the project site security risk status is deemed by security advisors to have changed in the area over time.

In addition, a Floating Storage Vessel can be moved relatively quickly in the event that South Africa becomes exposed to terrorist activities. Access to these facilities are also more easily controlled than land based facilities.

In terms of Emergency Plans, the Major Hazard Installation (MHI) Risk Assessor had recommended that an Emergency Plan be developed and sent to the City’s Disaster Management for them to comment and formulate action plans during the MHI application. The MHI application will be made to the District Municipality, and be assessed based on their disaster management capacity. This MHI application can only be made upon completion of the EIA process, once the EA has been granted (refer to the Major Hazard Installation Risk Assessment, Appendix I).

iv. Air Emissions Natural Gas (NG) will be the fuel used for the generation of electricity in the proposed Karpowership project. The pollutants that are usually emitted using this type of fuel include oxides of nitrogen (NOx), low sulphur dioxide

(SO2) and low particulate matter (PM10).

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

v. Storage of Hazardous Goods The Liquid Natural Gas stored on the FSRU at any given time will not exceed 175 000m³. The FSRU is made up of a series of pressurised containers. The storage of NG on the Powership is of small quantities and can be assumed as zero. The reason for this is because as the gas is produced it is used to produce electricity. Health and Safety protocols and requirements are ensured for the storage of hazardous goods such as small quantities of lubricating oil stored for equipment maintenance purposes.

vi. Refuelling The FSRU is refuelled through vessels specially fitted for the purpose of carrying LNG and fuelling the Powership. Refuelling would be required approximately every 20 days, depending on the power generation capacity and output of the Powership. The location of the LNGC, when re-fuelling, will be immediately adjacent to the FSRU. The LNGC will stay in this location within the Port only during the re-fuelling which takes one to two days, and thereafter will leave the Port. The FSRU can hold enough LNG to allow the Powership to operate for approximately 40 days; expected arrival dates of the LNG Carriers transporting the LNG from the overseas market will be aligned (taking account of the prevailing weather conditions) with the expected usage profile, whilst ensuring that sufficient reserves are maintained in the FSRU in case of any short notice delays. This is to avoid interrupting the supply of LNG to the Powership and thus, power generation.

vii. LNG Fuel Source The Powership is designed to use Natural Gas, a cleaner burning fuel for the cost effective generation of power, as opposed to coal-fired power stations. In addition, coal-fired power technology is associated with significant air pollution as a result of the coal-fired combustion. Natural gas emits between 45 and 55% fewer greenhouse gas emissions and less than one-tenth of the air pollutants than coal when used to generate electricity (Shell SA, Media Release, 2020).

According to Shell SA, “Natural gas is the cleanest-burning hydrocarbon, producing around half the carbon dioxide (CO2) and just one tenth of the air pollutants of coal when burnt to generate electricity.

If consumption remained at today’s levels, there would be enough recoverable gas resources to last around 230 years. It is versatile. A gas-fired power station takes much less time to start and stop than a coal-fired plant. This flexibility makes natural gas a good partner to renewable energy sources like solar and wind power, which are only available when the sun shines and the wind blows.” (https://www.shell.co.za/energy-and-innovation/natural- gas.html).

The benefits of running the engine on NG include emission reductions of NOx, SOx, CO2, particulates, no smoke, reduced waste streams to meet the requirements of local or international legislations.

Global LNG Market

The market for Liquified Natural Gas has existed since 1958 when the first tanker shipment of LNG took place from Lake Charles, USA bound for Canvey Island in the UK aboard the Methane Pioneer.

Today, more than 40 countries import LNG from 21 exporting nations around the world. Imports are dominated by the Asia Pacific region, with Japan, China and South Korea dominating demand, as shown in the diagram below. Page 19

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

On the supply side, Qatar has been the world’s largest supplier of LNG for a number of years. However, both Australia and the USA are expected to surpass Qatar as the world’s largest LNG suppliers since both nations have rapidly expanded their liquefaction capacity in recent years.

Figure 2-3 Representation of the Global LNG Supply

LNG Supply Sources Given the complexity of different sources of LNG and different customers for LNG and the fact that demand for LNG in a country can change from year to year as well as within the market, this market is suited to very large companies who can manage the complexity of changing import demand combined with the requirement to serve the customers' demands.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

LNG Supply is a mature market with approximately 30 larger companies, capable of supplying LNG to the project. Well–established companies will have to supply LNG from within their total global portfolio. Therefore, the LNG will not be sourced from a dedicated source(s).

The market for the supply of LNG will continue to grow for the next 40 years, and therefore there is no risk associated with the physical supply of this fuel for the term of the project.

LNG Procurement for the Project Fuel Company started the process for procurement of LNG during September 2020 by running an Expression of Interest (“EOI”) for LNG supply to the proposed Project. The EOI was sent to thirty (30) well established LNG suppliers. A robust LNG supply chain was secured.

Upon receiving the Preferred Bidder status, Karpowership will enter into an agreement for 6 years extendable up to a 20-year term with the preferred supplier(s).

viii. Waste generation and Management Due to daily activities and the Powership and FSRU will require regular maintenance and repairs which will produce waste. Approximately 75m3 of sewage (black water) as well as grey water (washing and kitchen) will be generated. All effluent and solid (general and hazardous) waste will be removed by authorised service providers in terms of the legislation and TNPA and MARPOL requirements.

All Listed and Specified Activities Triggered in terms of NEMA and NEM: AQA

2014 EIA Regulations (as amended), Appendix 3 - (d) (i) all listed and specified activities triggered

The table below indicates activities that are deemed applicable to the proposed project, based on Triplo4’s assessment:

NEMA Table 2-2 Applicable Listed Activities LISTED NOTICES LISTING NOTICE 1 Activity No. Activity Description Applicability Activity 11 The development of facilities or infrastructure for the The power generated on the transmission and distribution of electricity— Powership will be converted by the (i) outside urban areas or industrial complexes with a on-board High Voltage substation capacity of more than 33 but less than 275 kilovolts; (110 – 170 kV) and transmitted or along a double circuit twin (ii) inside urban areas or industrial complexes with a Chicadee conductor 132kV line. capacity of 275 kilovolts or more; This line will interconnect the excluding the development of bypass infrastructure Powership to the National Grid for the transmission and distribution of electricity utilising the existing Aurora- where such bypass infrastructure is —

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

LISTED NOTICES LISTING NOTICE 1 Activity No. Activity Description Applicability (a) temporarily required to allow for maintenance of Saldanha Steel network via a new existing infrastructure; 132kV on shore switching station. (b) 2 kilometres or shorter in length; (c) within an existing transmission line servitude; and The proposed transmission line (d) will be removed within 18 months of the with a capacity of 132 kV occurs commencement of development. within the Port and adjacent to existing infrastructure (transmission lines, railway lines and roads), associated with the adjacent industries.

DEFF to confirm that this listed activity can be removed. Activity 12 The development of— Based on the proposed route of the (ii) infrastructure or structures with a physical footprint transmission line, location of the of 100 square metres or more; proposed switching station and where such development occurs— temporary laydown area for the (a) within a watercourse land-based portion of the gas (c) if no development setback exists, within 32 metres pipeline installation, none of these of a watercourse, measured from the edge of a infrastructure or structures will be watercourse within 32m of a watercourse. Excluding: (dd) where such development occurs within an urban However, if these project area. components fall within an area considered to be “urban” by the competent authority, they will not trigger this activity.

DEFF to confirm that this listed activity can be removed. Activity 15 The development of structures in the coastal public Structures in the coastal public property where the development footprint is bigger property exceeding 50 square than 50 square metres, excluding— meters include: gas pipeline, transmission line and the laydown (i) the development of structures within existing area for the gas pipeline ports or harbours that will not increase the installation. development footprint of the port or harbour;

(ii) the development of a port or harbour, in The development of these which case activity 26 in Listing Notice 2 of structures and infrastructure within 2014 applies; the coastal public property will

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

LISTED NOTICES LISTING NOTICE 1 Activity No. Activity Description Applicability (iii) the development of temporary structures occur within the Port of Richards within the beach zone where such structures Bay. will be removed within 6 weeks of the commencement of development and where Activity 14 in Listing Notice 2 coral or indigenous vegetation will not be (2014), is applied for in terms of the cleared; or gas pipeline and mooring (iv) activities listed in activity 14 in Listing structures. Notice 2 of 2014, in which case that activity applies. DEFF to confirm the applicability of this listed activity given the potential exclusions of (i) and (iv).

Activity 17 Development— The development footprint of the (ii) in an estuary; proposed towers for the (v)if no development setback exists, within a distance transmission line, the switching of 100 metres inland of the high-water mark of the sea station and the temporary laydown or an estuary, whichever is the greater; area for the gas pipeline installation will exceed 50 square meters. in respect of— As these project components fall (e) infrastructure or structures with a development within an established Port, DEFF’s footprint of 50 square metres or more — guidance is sought on whether the activities are included or excluded but excluding— in terms of (aa). (aa) the development of infrastructure and structures within existing ports or harbours that will not increase In addition, these structures and the development footprint of the port or harbour; infrastructure are proposed within (dd) where such development occurs within an urban the existing Port of Saldanha Bay area. and Transnet property, which could be interpreted as urban, in which case the exclusion (dd) would apply and the activity not triggered.

DEFF to confirm the applicability of this listed activity given the possible exclusion of (aa) and/ or (dd). Activity 18 The planting of vegetation or placing of any material Sections of the gas pipeline and on dunes or exposed sand surfaces of more than 10 transmission line, where it comes

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

LISTED NOTICES LISTING NOTICE 1 Activity No. Activity Description Applicability square metres, within the littoral active zone, for the on shore, need to be stabilised to purpose of preventing the free movement of sand, prevent erosion on the substrate erosion or accretion. where the pipeline and transmission line is established.

Furthermore, rehabilitation for the land-based portion will be required. Although the area has already been transformed due to port activity, it will require the planting of vegetation on exposed sand surfaces of more than 10 square meters to ensure environmental management. Activity 19 The infilling or depositing of any material of more than The proposed transmission and 10 cubic metres into, or the dredging, excavation, onshore gas pipeline routes do not removal or moving of soil, sand, shells, shell grit, occur within a watercourse as pebbles or rock of more than 10 cubic metres from a confirmed by the Wetland watercourse Specialist.

But excluding where such infilling, depositing, DEFF to confirm that this listed dredging, excavation, removal or moving – activity can be removed. (d) occurs within existing ports or harbours that will not increase the development footprint of the port or harbour. Activity 19A The infilling or depositing of any material of more than The erection of the pylons for the 5 cubic metres into, or the dredging, excavation, transmission lines and gas pipeline removal or moving of soil, sand, shells, shell grit, installation will require the removal pebbles or rock of more than 5 cubic metres from— of more than 5 cubic metres of (i) the seashore; sand, within 100 metres inland of (ii) the littoral active zone, an estuary or a distance of the high-water mark. 100 metres inland of the high-water mark of the sea or an estuary, whichever distance is the greater; or Installation of the subsea as well as (iii) the sea; — land based portions of the gas but excluding where such infilling, depositing , pipeline and laydown areas will dredging, excavation, removal or moving— require excavation, levelling infilling (e) will occur behind a development setback; and compaction. (f) is for maintenance purposes undertaken in accordance with a maintenance management plan; It is uncertain whether the infilling, depositing, dredging, excavation,

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

LISTED NOTICES LISTING NOTICE 1 Activity No. Activity Description Applicability (g) falls within the ambit of activity 21 in this Notice, in removal or moving are deemed to which case that activity applies; increase the development footprint (h) occurs within existing ports or harbours that will not of the port. increase the development footprint of the port or harbour; or DEFF to confirm the applicability where such development is related to the of this listed activity given the development of a port or harbour, in which case potential exclusion of (h). activity 26 in Listing Notice 2 of 2014 applies. Activity 27 The clearance of an area of 1 hectare or more, but The transmission line, its servitude less than 20 hectares of indigenous vegetation, and the associated switching except where such clearance of indigenous station (1.3 Ha) will require clearance of more than 1 hectares vegetation is required for— of indigenous vegetation. (i) the undertaking of a linear activity; or

maintenance purposes undertaken in accordance DEFF IQ desk has confirmed that with a maintenance management plan. the transmission line comprising of towers / pylons and 132kV lines is not triggered by the project. The switching station was not specifically addressed in the enquiry to DEFF IQ. It must be noted that without the transmission line, no switching station will be established.

DEFF) to confirm that the switching station is included with in linear activity and to confirm applicability and confirm that this listed activity can indeed be removed for the transmission line and associated switching station.

Activity No. Activity Description Applicability LISTING NOTICE 2 Activity 2 The development and related operation of facilities or The Powership and FSRU are infrastructure for the generation of electricity from a assembled off-site and will be non-renewable resource where the electricity output delivered fully equipped and ready is 20 megawatts or more.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Activity No. Activity Description Applicability LISTING NOTICE 2 to operate to the Port of Saldanha Bay where they will be moored.

The proposed design capacity for the Saldanha Bay Powership is approximately 415MW, which comprises of 21 gas reciprocating engines having a heat input of approximately 18.32 MW each. The 2 steam turbines have a heat input of approximately 15.45 MW each.

The gas pipeline from the FSRU to the Powership and the transmission line linking the Powership to the national grid trigger separately listed activities as does the need for an AEL which if issued, will regulate the atmospheric emissions during commissioning and operation of the project. Activity 4 The development and related operation of facilities or Storage of LNG on the FSRU will infrastructure, for the storage, or storage and handling exceed 500 cubic meters of a dangerous good, where such storage occurs in (maximum estimated storage is containers with a 175000 cubic meters at any given combined capacity of more than 500 cubic metres time). Activity 6 The development of facilities or infrastructure for any The engines used for electricity process or activity which requires a permit or licence generation are a Listed Activity or an amended permit or licence in terms of national under GN 893 of 22 November or provincial legislation governing the generation or 2013 (as amended) in terms of release of emissions, pollution or effluent, excluding─ Section 21 of the NEM: AQA Sub- (i) activities which are identified and included in Category 1.5: Reciprocating Listing Notice 1 of 2014; Engines. In the case of the (ii) activities which are included in the list of proposed project, the Powership waste management activities published in terms of will have a combined sum of 21 section 19 of the National Environmental engines that all have a heat input Management: Waste Act, 2008 (Act No. 59 of 2008) capacity of more than 10 MW each. in which case the National Environmental Management: Waste Act, 2008 applies; The two steam turbines have a heat input capacity of less than 50 MW,

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Activity No. Activity Description Applicability LISTING NOTICE 2 but more than 10 MW. These units are therefore declared Controlled Emitters and will likely be regulated in terms of GN 831 of 1 November 2013 for Small Boilers.

Activity 7 The development and related operation of facilities or A subsea gas pipeline for infrastructure for the bulk transportation of dangerous transportation of gas in gas form is goods─ proposed, exceeding 1000 meters, (i) in gas form, outside an industrial complex, using however the proposed location is pipelines, exceeding 1 000 metres in length, with a within industrial complex (harbour throughput capacity of more than 700 tons per day; land use). (ii) in liquid form, outside an industrial complex, using pipelines, exceeding 1 000 metres in length, with a As this activity is within the Port throughput capacity of more than 50 cubic metres per boundaries which potentially is day; or within an industrial complex. (iii) in solid form, outside an industrial complex, using DEFF to confirm the applicability funiculars or conveyors with a throughput capacity of of this listed activity. more than 50 tons per day. Activity 14 The development and related operation of— The ships will be anchored and moored in existing port operational (ii)an anchored platform; or areas utilising the vessel’s (iii) any other structure or infrastructure — anchoring system. The on, below or along the sea bed; transmission of the NG gas will flow via a gas pipeline from the moored excluding — ship along the seabed to the main (a) development of facilities, infrastructure or ship for processing. The subsea structures for aquaculture purposes; or gas pipeline is proposed to be (b) the development of temporary structures or installed along the toe of the infrastructure where such structures will be removed existing dredged slopes between within 6 weeks of the commencement of development the floating storage regasification and where coral or indigenous vegetation will not be unit (FSRU) and Powership to cleared. ensure gas supply for power generation.

Activity No. Activity Description Applicability LISTING NOTICE 3 Activity 10 The development and related operation of facilities or The storage and handling of a infrastructure for the storage, or storage and handling dangerous good, where such of a dangerous good, where such storage occurs in storage occurs in containers with a

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Activity No. Activity Description Applicability LISTING NOTICE 3 containers with a combined capacity of 30 but not combined capacity of more than exceeding 80 cubic metres. 500 cubic metres. The FSRU with a maximum storage i. Western Cape capacity of 175000 cubic meters of i. Areas zoned for use as a public open space or LNG, is located approximately 3km equivalent zoning; from the shore on the Big Bay side. iii. Inside urban areas: (aa) Areas seawards of the development setback line As this activity is within the Port or within 200 metres from the high-water mark of the boundaries which is potentially sea if no such development setback line is an urban area, DEFF to confirm determined; the applicability of this listed (bb) Areas on the watercourse side of the activity. development setback line or within 100 metres from the edge of a watercourse where no such setback line has been determined; or (cc) Areas on the estuary side of the development setback line or in an estuarine functional zone where no such setback line has been determined. Activity 12 The clearance of an area of 300 square metres or This activity will be triggered by the more of indigenous vegetation except where such land based portion of the gas clearance of indigenous vegetation is required for pipeline combined with the laydown maintenance purposes undertaken in accordance area and transmission line as , it is with a maintenance management plan. within the littoral active zone and 100 metres inland from the i. Western Cape highwater mark of the sea i. Within any critically endangered or endangered ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004; ii. Within critical biodiversity areas identified in bioregional plans; iii. Within the littoral active zone or 100 metres inland from high water mark of the sea or an estuarine functional zone, whichever distance is the greater, excluding where such removal will occur behind the development setback line on erven in urban areas; iv. On land, where, at the time of the coming into effect of this Notice or thereafter such land was zoned

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Activity No. Activity Description Applicability LISTING NOTICE 3 open space, conservation or had an equivalent zoning; or v. On land designated for protection or conservation purposes in an Environmental Management Framework adopted in the prescribed manner, or a Spatial Development Framework adopted by the MEC or Minister. Activity 14 The development of— Although infrastructure or structures with a footprint of more (i) dams or weirs, where the dam or weir, than 10 square meters will be including infrastructure and water surface area developed within the Port and exceeds 10 square metres; or beyond, none of these occurs: (ii) infrastructure or structures with a physical  within a watercourse; footprint of 10 square metres or more;  in front of a development setback; or where such development occurs—  if no development setback has (a) within a watercourse; been adopted, within 32 (b) in front of a development setback; or metres of a watercourse, (c) if no development setback has been adopted, measured from the edge of a within 32 metres of a watercourse, measured from the watercourse; edge of a watercourse; It is uncertain whether the excluding the development of infrastructure or development of infrastructure and structures within existing ports or harbours that will not structure are deemed to increase increase the development footprint of the port or the development footprint of the harbour. port. If the exclusion applies, then the activity is not triggered. Western Cape i. Outside urban areas: DEFF decision on the (aa) A protected area identified in terms of applicability of this listing notice NEMPAA, excluding conservancies; to be confirmed given (bb) National Protected Area Expansion Strategy explanation above and the Focus areas; potential exclusion. (cc) World Heritage Sites; (dd) Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority; (ee) Sites or areas listed in terms of an international convention;

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Activity No. Activity Description Applicability LISTING NOTICE 3 (ff) Critical biodiversity areas or ecosystem service areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; (gg) Core areas in biosphere reserves; or (hh) Areas on the estuary side of the development setback line or in an estuarine functional zone where no such setback line has been determined.

NEM:AQA In terms of Section 21 of the Air Quality Act the Minister published a ‘list of activities which result in atmospheric emissions and which the Minister or MEC reasonably believes have or may have a significant detrimental effect on the environment, including health, social conditions, economic conditions, ecological conditions or cultural heritage’. In terms of Section 21 of the Air Quality Act the consequences of listing an activity is that:

‘No person may without a provisional atmospheric emission licence or an atmospheric emission licence conduct an activity— (a) listed on the national list anywhere in the Republic; or (b) listed on the list applicable in a province anywhere in that province.’

Table 2-3: Applicable Listed Activities Details of the Listed Activity for the proposed Gas to Power Powership Project (GG No. 37054, GN 893 of 22 November 2013, as amended) Category of Listed Sub-category of the Listed Activity Application Activity Category 1: Sub-category 1.5: Liquid and gas fuel All installations with design capacity equal to Combustion stationary engines used for electricity or greater than 10 MW heat input per unit, Installations generation based on the lower calorific value of the fuel use

The applicability of this listed activity has been investigated by the EAP upon advice of the air quality specialist and will be confirmed in consultation with the licensing authority.

Table 2-4: Minimum Emission Standards in mg/Nm3 for Subcategory 1.5 Substance or mixture of substances MES for sub-category 1.5

MES under normal conditions of 15% O2, 273 Common name Chemical symbol Kelvin and 101.3 kPa Particulate matter N/A 50 Oxides of nitrogen NOX 400 (Expressed NO2)

Sulphur dioxide SO2 N/A

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Project Locality

2014 EIA Regulations (as amended), Appendix 3 – 3 (1) an environmental impact assessment report must include (b) the location of the development footprint of the activity on the approved site as contemplated in the accepted scoping report, including: (i) the 21 digit Surveyor General code of each cadastral land parcel; (ii) where available, the physical address and farm name; and (iii) where the required information in items (i) and (ii) is not available, the coordinates of the boundary of the property or properties; (c) a plan which locates the proposed activity or activities applied for as well as the associated structures and infrastructure at an appropriate scale

Table 2-5: Location of the proposed activity Description Location of the Activity District Municipality West Coast District Municipality Local Municipality Saldanha Bay Local Municipality Ward 5 Area / Town / Village Port of Saldanha Bay Property Description & 21 Digit SG Code See Table 2-6 below

Table 2-6: Property Description & 21 Digit SG Code – As per options presented in Section 3. Properties 21 SG CODES CENTRAL GPS-COORDINATE Longitude Latitude Portion 2 of Farm Uyekraal 189 C04600000000018900000 32° 58' 54.2424'' 18° 2' 54.4344'' E S Remaining Extent of the Farm 196 C04600000000019600000 33° 0' 9.1224'' S 18° 0' 16.0632'' E Portion 8 of the Farm Pienaars Poort C04600000000019700000 32° 59' 48.1632'' 17° 59' 59.0172'' S E Portion 15 of the Farm Pienaars Poort C04600000000019700000 32° 59' 49.722'' S 17° 59' 41.262'' E Portion 2 of the Farm 1112 C04600000000111200000 32° 58' 41.088'' S 18° 0' 29.5884'' E Remaining Extent of the Farm 1132 C04600000000113200000 32° 58' 51.996'' S 18° 1' 19.1892'' E Remaining Extent of the Farm 1139 C04600000000113900000 32° 58' 59.5524'' 17° 59' 48.6492'' S E Portion 1 of the Farm 1139 C04600000000113900000 32° 59' 28.6872'' 17° 59' 50.9208'' S E The Farm 1185 C04600000000118500000 33° 0' 36.7956'' S 17° 59' 57.7644'' E Erf 11945 Saldanha C04600120001194500000 32° 59' 27.8988'' 18° 2' 12.3288'' E S Portion 17 (a portion of portion 13) of C04600000000012700000 32° 59' 27.8988'' 18° 0' 7.7976'' E the Farm Yzervarkensrug 127 S Remaining Extent of the Farm C04600000000012900000 32° 58' 33.3084'' 18° 0' 58.8492'' E Yzervarkensrug 129 S Remaining extent of Portion 3 of the C04600000000012900000 32° 58' 17.8968'' 18° 2' 12.3288'' E Farm Yzervarkensrug S Page 31

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Properties 21 SG CODES CENTRAL GPS-COORDINATE Longitude Latitude Portion 7 of the Farm Yzervarkfontein C04600000000012900000 32° 58' 33.3084'' 18° 0' 58.8492'' E 129 S

There were no fatal flaws in the alternate positions of the Powership assessed therefore both options with the corresponding gas pipeline and transmission route are presented below. No alternatives for the FSRU and proposed switching station was assessed.

Figures 2-4 – 2-5 below present the recommended options of the proposed Powership within the port, as well as the recommended routes for the gas pipeline and the transmission line (dependent on the position of the Powership) – from the Port to the existing Aurora- Saldanha Steel network via a new 132kV on shore switching station or to the existing Blouwater substation.

Figure 2-4: Map showing the proposed Gas to Power Powership Project – Port of Saldanha.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Transmission Line (Alt 1) with switching station Aurora – Saldanha Steel Towers 1 – 25

Transmission Line (Alt 2) To Blouwater Substation Towers 1 – 35 Laydown Area 1 and 2 with construction Powership Small Bay routes

Gas pipeline to Small Bay (Purple) Alternative connections to Transmission Line (Alt 1&2) from the Big Bay Powership Powership Big Bay option. (Blue)

Gas pipeline to Big Bay (Green)

FSRU and Gas Pipeline (Green and Purple)

Figure 2-5 Google Image showing project details.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

The preferred location of the FSRU and potential location of the Powership within the gazette Port Limits (Government Gazette No. 32873 –January 2010).

Site Access, Construction Routes and Proposed Laydown Areas The proposed location of the Project is situated within the existing and operational Port of Saldanha, therefore the existing access roads network will be used to access the Powership site. The position of the access road is indicated in the Figure below.

Include the position of the access road on the site plan and required map, as well as an indication of the road in relation to the site.

Access to Site

Figure 2-6 Google map showing existing access road system to the Port of Saldanha

Construction Routes and Proposed Laydown Areas:  Powership and FSRU Not applicable as the ships are built internationally and arrive fully equipped in the Port ready for operation.  Onshore and Offshore Gas Pipeline There are two laydown areas required for the installation for the gas pipelines as shown in Figure and Figure below. The central co-ordinate of Area 1 is situated at 32°59'41.748''S 18°0'19.8252''E and is approximately 0,426 Ha in size. The central co-ordinate of Laydown Area 2 is situated at 33°0'35.3592"S 18°0'46.5084"E and is approximately 1,029Ha size

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 2-7 Google image showing Laydown Area 1.

Figure 2-8 Google Image showing Laydown Area 2.

Transmission line and Switching Station For the evacuation route, the proposed switching station site situated at will serve as the laydown area for the project and no additional area is required.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

3 ALTERNATIVES ASSESSED IN THE EIA PROCESS

Approved site

2014 EIA Regulations (as amended), Appendix 3 - (h) a full description of the process followed to reach the proposed development footprint within the approved site as contemplated in the accepted scoping report, including: (i) details of the development footprint alternatives considered;

Considering the proposed project being a ship-based power generating operation (as opposed to land-based) requiring transmission of energy to land-based transmission connection points, locations within South Africa that provide infrastructure associated with the proposed technology were identified.

The Port of Saldanha Bay was identified for planned gas infrastructure by National Government and the Transnet Port National Authority (TNPA). The Port of Saldanha Bay is situated on the West Coast of South Africa and is a natural deep water Port. A Special Economic Zone (SEZ) has been declared in Saldanha Bay and construction is well underway for the establishment of infrastructure to stimulate economic development in and around the Port (NPP, 2019). As a result of the above, the Port of Saldanha is the preferred location, and no other sites within this region are proposed for this project. This site has been approved by DEFF following Scoping.

Development footprint (layout) alternatives assessed in EIA

Alternatives in Scoping Report (plan of study for EIA)

The following proposed alternatives were presented in the Scoping Report, specifically the plan of study for EIA (and subsequently approved by DEFF for assessment in the current EIA phase):  Positioning of Powership and FSRU (No alternative mooring sites due to need for deep waters, existing infrastructure and Port’s future development plans);  Gas pipeline – 2 alternatives presented for the on-shore gas line;  Transmission line – o 2 alternatives presented from the Powership to the first tower; o 3 alternatives presented the existing Blouwater substation all following the route of existing lines.

Layout Deviations from the Scoping Report

3.2.2.1 New Powership position The positions of the Powership and FSRU, as presented in the Scoping Report, were aligned with the short and medium term plans published in the 2019 National Ports Plan. Transnet National Ports Authority’s (TNPA) representative has however indicated a preference for the Powership to be moored in Big Bay, adjacent to the causeway within the Port, as described in the updated National Ports Plan still to be published. The project scope has thus been extended to include an alternate positioning for the Powership and associated gas and transmission line alignments so that the potential impacts could be assessed by specialists and comments could be obtained from I&APs and DEFF.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

3.2.2.2 New Gas line route alternative The position of the Powership dictates the gas line route therefore as a result of Transnet’s preference for the Powership to be moved to Big Bay, the pipeline route between the FSRU in Small Bay to the Powership in Big Bay a new gas line route was identified.

3.2.2.3 New transmission line route alternative and switching station Due to TNPA’s preference for the Powership to be moved to Big Bay, the starting point of the transmission needs to change. Furthermore, Eskom has subsequent to Scoping communicated to Karpowership that it may not link the Powership to the Blouwater Substation as was originally proposed and can connect to the existing Saldanha Steel transmission network instead. This requires a new onshore switching station and a 5,7km 132kV transmission line within existing servitudes. This line is thus 1.8 km shorter than the 7,5km initially proposed line to link to the national grid. Portion 2 of Farm Uyekraal 189 (owned by Eskom) is not applicable to this new alternative. As the new transmission line route alternative follows the route initially proposed in the scoping phase, all landowners and properties associated with the new transmission line route alternative were identified and consents were obtained.

Alternatives assessed in the EIA As a result of the abovementioned engagements with Transnet and Eskom, the alternative layouts relating to the positioning of the Powership, Transmission Lines and Gas Pipelines within the approved site have had to be amended and the scope of the specialist studies amended to assess these changes and associated impacts as part of the EIA phase. The position of the gas line route and the transmission route are dictated by the position of the Powership either within Small Bay (as proposed in the Scoping Phase) or Big Bay (as preferred by TNPA).

The layout alternatives are presented discussed in more detail below.

Powership position alternatives within the Port The Powership and FSRU are to be moored within the Port of Saldanha. The operational requirements at the Port cannot accommodate the use of existing berthing infrastructure and therefore the vessels have to be positioned in unused areas of the port and utilise their own mooring system comprising catenary mooring chains and anchors.

Key considerations for a feasible position are Port planning, and the turning circle for the LNG carrier as well as that of the approach channel to be shared with the container terminal, i.e. traffic in basin from container vessels, cargo vessels and tugs. The facility needs to be situated after the approach channel entrance and outside the turning circle so as to not too impede vessel traffic movement in the port. This will comply with the safety exclusion zones required for the ship-to-ship transfer from the LNG to the FSRU.

No alternative mooring sites were initially considered as per the Scoping Report as the preferred location is within the TNPA port limits and is aligned with the proposed plans (NPP, 2019) for the port. After engagements between Karpowership and TNPA, TNPA indicated a preference for the Powership to be located within Big Bay (Figure 3-2). This option has been included as an alternative, assessed by the specialists and provided to all stakeholders and I&APs for comment.

Alternative 1, as per the Scoping Phase, proposes that the Powership is moored in Small Bay while Alternative 2 is the new position identified through the public participation phase proposed in Big Bay. The

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. alternative positions for the Powership were investigated and both positions are considered to be suitable in terms of the specialist and technical requirements.

No dredging is required as the mooring location for Alternative 1 and 2 as it positioned in sufficient water depth to safely accommodate the moored vessels.

Table 2-7: Coordinates of the proposed locations of the Powership: Coordinates Alternative 1 Small Bay - 33° 0'20.42"S 17°59'24.20"E

Alternative 2 Big Bay - 33° 0'44.39"S 17°59'46.72"E

The alternatives are illustrated in the figures below:

Figure 3-1: Alternative 1 and 2: Position of Powership within Small Bay and FSRU within Big Bay.

Gas Pipelines Alternatives A gas line is required between the FSRU and Powership to ensure gas supply for power generation. An alignment for an onshore and offshore gas pipeline has been considered dependent on the position of the Powership to be moored within either Small Bay or Big Bay.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 3-2 Google Image showing the Gas Pipeline Alternatives

Two route alternatives were considered as shown in Figure 3-2 above. The subsea gas pipeline connecting the FSRU to the Powership (moored either at Big Bay or Small Bay) will be routed from the FSRU towards the shore with a land based option set out in front of the Saldanha Bay Iron Ore terminal via a flexible marine hose. The gas pipeline will be mounted on small footings requiring minor civil works to construct and install.

Table 3-1: Details of Proposed Route Gas pipeline route alternatives Alternative Coordinates Length (km) Area (m2) Gas Pipeline Alternative 1 Subsea (FSRU – Onshore Pipeline) Approx. 6km Approx. 51 000m2 (Powership at Small Bay) Start 33° 2'29.16"S 17°59'55.29"E End 33° 0'34.16"S 18° 0'43.22"E Onshore to Subsea Start 33° 0'34.16"S 18° 0'43.22"E End 33° 0'42.17"S 17°59'32.02"E Subsea to Powership Start 33° 0'42.17"S 17°59'32.02"E End 33° 0'20.42"S 17°59'24.62"E Gas Pipeline Alternative 2 Subsea (FSRU – Onshore Pipeline) Approx. 6,9km Approx. 51 000m2 (Powership at Big Bay) Start 33° 2'29.06"S 17°59'55.50"E End 33° 0'34.04"S 18° 0'44.19"E Onshore to Subsea Start 33° 0'34.04"S 18° 0'44.19"E End 33° 0'41.07"S 17°59'38.40"E Subsea to Powership Start 33° 0'41.07"S 17°59'38.40"E End 33° 0'43.69"S 17°59'45.97"E

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Transmission Lines Alternatives The transmission line alternatives for distribution to the National grid, largely follow a similar route and are considered the main routes. The connection of the transmission line from the Powership to the main route depend on the position of the Powership.

As motivated by Eskom, Alternative 1 proposes that the power from the Powership is evacuated by means of a double circuit twin Chicadee conductor 132kV line The proposed line, approximately 5,7km, will interconnect the Powership to the National Grid utilising the existing Aurora- Saldanha Steel network via a new 132kV on shore switching station (Proposed route from Tower 1 – 25 shown in Figure 3-3 and proposed switching station shown in Figure 3-4 below). The new route follows the route proposed in Alternative 2 however it is shorter.

Figure 3-3 Transmission Line to Aurora-Saldanha Steel Network

Figure 3-4 Proposed Switching Station associated with Alternative 1 only

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Table 3-2 Table including details of Alternative 1 route to Aurora -Saldanha Steel Network including proposed switching station Alternative Coordinates Length Area (m2) (km) Transmission Line Start - 33° 0'3.20"S 17°59'47.26"E Approx. 22 5000m2 Route Alternative 1 End - 32°58'34.03"S 18° 1'38.21"E 5,7km Switching Station Central - 32°59'53.56"S 17°59'50.61"E - 13 000 m2

The connection of the transmission line from the Powership to Blouwater substation, as presented in the Scoping Report and in Figure 3-4 below is regarded as Alternative 2. The proposed footprint is therefore approximately 210 000m².

Figure 3-5 Google image showing Alternative 2 to the existing Blouwater Substation

Table 3-3 Details of Transmission Line from Powership in Big Bay to Tower 1 or 2 Alternative Coordinates Length (km) Transmission Line Route Start 33° 0'41.86"S 17°59'33.33"E Approx. 2,6km Alternative A End 33° 0'5.68"S 17°59'49.71"E Transmission Line Route Start 33° 0'31.18"S 18° 0'3.29"E Alternative B End 33° 0'1.10"S 17°59'59.73"E

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Table 3-4 Details of Transmission Line from Powership in Small Bay to Tower 1 Transmission line Coordinates Length Area (m2) (km) From Powership to Start 33° 0'16.94"S 17°59'25.75" Approx. N/a Tower 1 End 33° 0'3.41"S 17°59'46.97"E 2.6km

Figure 3-2: Proposed Transmission line from the Powership to first tower.

The final alignment and methodology (overhead) is to be approved by Transnet and Eskom upon confirmation of preferred bidder status.

No-go option

The option of not implementing the activity is also referred to as the “No-go” alternative. In respect of the Project, it would mean that the existing status quo would prevail and that no additional power using this particular technology will be generated and transmitted for inclusion into the energy grid in the Western Cape and Saldanha Bay in particular. Please refer to Chapter 8 for the assessment of the No-go option.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

4 SITE DESCRIPTION OF SURROUNDING LAND USE

2014 EIA Regulations (as amended), Appendix 3 (1)- (h) (iv) the environmental attributes associated with the development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects;;

BIOPHYSICAL ENVIRONMENT

Regional Setting and Topography The proposed transmission and gas line will be situated near and in the Port of Saldanha Bay, Western Cape Province (refer to Figure 2-4) Saldanha Bay is a coastal bay located on the west coast of South Africa. The bay comprises three distinct areas: Outer Bay, which forms the approach to Saldanha Bay harbour between the North and South Heads and includes Malgas and Jutten Islands, Small Bay and Big Bay. To the south- east, 9 km from the proposed Powership location, Big Bay is directly linked to the shallow, subtidal Lagoon.

The project is situated in Quaternary Catchment G10M of the Berg - Olifants (DWS, 2016) Water Management Area (WMA 9). Two (2) sub-catchments were delineated for the project area and describes the natural drainage of the area. No major or secondary rivers are associated with the study area, and ephemeral runoff of rainwater for the sub-catchments is expected. Elevations on the site typically range from 0 to 30 metres above mean sea level (mamsl). Thickets, bare soil, bushes, short grass, long grass, sparsely woodland grasslands, thickets, low shrubs and bushes dominate the sub-catchment (DEA, 2019).

Climatic Conditions The Köppen Climate Classification indicates that Saldanha Bay is situated in a temperate climate (class = Csb) which receives rainfall in winter months (Kottek, Grieser, Beck, Rudolf, & Rubel, 2006). The Mean Annual Precipitation (MAP) is in the order of 300 mm/annum and the Mean Annual Evapotranspiration (MAE) in the order of 1 460 mm/a (S-Pan) (WRC, 2015).

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 4-1: Average temperature and rainfall – Saldanha Bay (Meteoblue, 2020)

Geology and Soils

Soils and land morphology

According to the Land types of South Africa databases (ARC, 2006), the soils in the project area fall within Hb14 (deep grey sands subdominant [comprise >20% of land type]) land types.

The original concept of this land type was one of light and grey coloured soils having formed from such coloured parent materials without distinct influences of redox processes. This implies that these soils have the colours of reduction related to bleached soils but not the chemical formation processes – an aspect that causes significant confusion in terms of the interpretation of wetland characteristics. The split of the Fernwood soil form has clarified the dry vs wet light-coloured soil form challenge somewhat through accommodating the former in the stratified regic sand and the latter in the new Fernwood concept. However, this development does not solve the challenge of identifying redox morphology in deep sandy profiles. It is generally accepted that mottling does not occur (or is very poorly discernible) in sandy soils due to the association of high chroma Fe accumulations with finer-textured material – that is absent in the sandy soils.

From the texture and porosity, it is evident that these soils and landscapes exhibit rapid drainage and percolation of water and therefore qualify as terrestrial soils. However, the presence of regional water tables leads to stagnation and shallow water tables in these landscapes but then without the clear redox morphology observed in other landscapes. The essence is that these soils and land types are very challenging when trying to identify wetland features based on soil properties. The general assertion listed for the podzol soils, one of increasingly dark and elevated organic C levels with increasing wetness, also applies effectively in this land type but will require empirical observation, measurement and description (Der Waals, 2019); (Job, et al., 2019).

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Generally, the same soil types are encountered in the study area, and is mainly due to the sub-surface geology and local rainfall patterns.

Figure 4-2 Land Morphology concept (Almond, 2016)

The soils in the project predominantly consist of fine to medium-grained sand of the Mispah and Fernwood soil forms (ARC, 2006) - refer to Figure 4-3 . The combined average diagnostic depth of all the soils range from 100 to 1200 mm. Average clay content for footslope soils range from 4 to 10% (ARC, 2006), and less clay content (0 to 3%) is associated with soils on the crest and midslope positions.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 4-3 Estimated Soil Distribution (Arc, 2006)

The combined average diagnostic depth of all the soils range from 100 to 1200 mm. Average clay content for footslope soils range from 4 to 10% (ARC, 2006), and less clay content (0 to 3%) is associated with soils on the crest and midslope positions.

Geohydrology

4.1.4.1 Local and Surface Water The sub-catchments for the site was delineated using 30m SRTM DEM (Farr & Kobrick, 2000). From this delineation, catchment characteristics, such as area, slopes and hydraulic parameters of the modelled river sections, were derived. The total surface area of the delineated sub-catchment is approximately 199 km2. The delineated watershed for the farm is the entire quaternary catchment due to the river morphology and size of the rivers.

4.1.4.2 Groundwater According to DWAF (2006), the groundwater depth on a quaternary scale is in the order of 10.5 mbgl. WRC (2015) and NGA data suggest that the groundwater table ranges from 3 to 15 mbgl, for the sub-catchment associated with the development site (refer to Figure 4-2). Literature further suggests that the groundwater table mimics the surface topography. Shallower groundwater levels will typically be associated with low lying areas surrounding, or areas where clay lenses occur (i.e. perched groundwater).

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 4-4: Groundwater users identified in the study area

Wetland Environment

A Wetland Delineation and Functionality Assessment was undertaken by Mr Suheil Hoosen in November 2020 for the proposed development. Based on the initial risk screening assessment, the Estuary/Port was the only watercourse identified and was assessed further in the Estuarine Impact Assessment. No wetland/riverine system will be at risk as a result of the proposed development.

4.1.5.1 Water Management Areas The proposed development was observed to fall within the Water Management Area (WMA): Berg, which falls under the lesser sub-WMA’s: Lower Berg and the quaternary catchment G20M. The aforementioned WMA is drained by several parallel rivers which flow in a south-westerly direction and eventually discharge into the Atlantic Ocean. The rivers which contribute to the highest flow within this WMA are the Berg, Diep and Steenbras rivers with several smaller coastal rivers that feed the aforementioned larger rivers (DWA, 2003).

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 4-5: Map of the WMA, sub-WMA and Quaternary Catchment that fall within the proposed development.

4.1.5.2 National Freshwater Ecosystem Priority Areas The National Freshwater Ecosystem Priority Areas (NFEPA), are a selection of rivers, wetlands and estuaries which have been identified as systems of strategic importance to the hydrological functioning of South Africa. These systems have been identified using scientific methodologies as well as consensus amongst researchers, government entities and the general public (Nel et al., 2011).

According to the NFEPA dataset, there will be no FEPA rivers or wetlands at risk as a result of the proposed development. The closest FEPA wetlands are approximately 700m away and were classified as one natural depression and several artificial depressions.

4.1.5.3 Estuarine Environment An Estuarine Impact Assessment was undertaken by Coastwise Consulting in February 2021, Based on the desktop delineation, the Langebaan Lagoon which is the defined estuarine area remains relatively unchanged with a few small-scale additions of important estuarine habitat above the 5m contour, and is referred in the most recent National Biodiversity Assessment (NBA) (CSIR, 2018; Van Niekerk, J. B. Adams, et al., 2019).

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 4-6 Location of the Langabaan Lagoon relative to the Port of Saldanha including the EFZ in blue

Vegetation and Flora

4.1.6.1 Vegetation types According to Mucina and Rutherford (2006), there are three vegetation types within the Karpowership site: Langebaan Dune Strandveld (FS 5), Saldanha Flats Strandveld (FS 3), and Saldanha Limestone Strandveld (FS 4). This vegetation is mapped in the National Vegetation Map Beta of 2018 (Mucina & Rutherford, 2018).

In terms of flora, some Species of Conservation Concern recorded from the site include Arctopus dregei, Ferraria parva, Limonium capense and Babiana nana (EN). Additional species including Aloe sp. are provincially protected.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

4.1.6.2 Western Cape Biodiversity Spatial Plan (WCBSP) The WCBSP has been developed by CapeNature Scientific Services Land Use Team in order to identify the priority biodiversity areas and ecological infrastructure that must be conserved to meet the provincial biodiversity mandate (Pool-Stanvliet et.al. 2017). The plan includes land use guidelines along with biodiversity priority areas, covering terrestrial, freshwater, coastal and marine areas. The plan identified areas as Critical Biodiversity Areas (CBAs) which cannot be lost if conservation goals are to be met, and Ecological Support Areas (ESAs).

4.1.6.3 Protected Areas Formal protected areas are those that are included in the National Environmental Management: Protected Areas Act (Act 57 of 2003) and include nature reserves, national parks and protected environments. Protected areas provide protection against climate change and aid in ecological sustainability (Government of South Africa, 2008). Proximity to protected areas is important, as sites close to these areas may be ecologically sensitive, and buffers around protected areas should be maintained to preserve biodiversity and connectivity. The closest protected area is the West Coast National Park and the Marcus Island Marine Protected Area both of which are located within 5km of the study area.

Due to its recognised ecological importance, the area forms part of the West Coast National Park Marine Protected Area (MPA) Network. The network comprises several MPAs which were declared at various times, including the West Coast National Park MPA surrounding Langebaan Lagoon (proclaimed in 1985 and revised in 2000), Malgas Island MPA (proclaimed in 1985) and Jutten and Marcus Island MPAs (proclaimed in 2000). These are managed in terms of the National Environment Management: Protected Areas Act 57 of 2003 (WCNP 2013). Langebaan Lagoon is also a RAMSAR site declared in 1988, and the area eastwards of the North and South Heads is a rock lobster reserve in which no rock lobster may be caught.

The West Coast National Park, Malgas and Jutten Island MPAs do not occur within the proposed powerplant development's immediate area and are 9, 9.3 and 10.5 km away from the Powership and FSRU locations, respectively. However, Marcus Island is much closer, occurring at the entrance to Small Bay and Big Bay, 5.3 km from the proposed FSRU location. Conservation areas at the local scale are discussed further in Section 2.6.

Avifauna

Together at 57 km2, the Saldanha Bay/Langebaan Lagoon complex makes up the largest body of wave sheltered water on the South African coast (Siegfried 1977). Langebaan Lagoon hosts ecologically important intertidal mud and sand flats used for foraging by seabirds and is an important nursery area for many marine fish and invertebrate species (TNPA 2020). The islands in the bay (Malgas, Jutten and Marcus Islands) provide breeding habitat for several seabird species, including Cape gannets (Morus capensis), bank cormorants (Phalacrocorax neglectus), kelp gulls (Larus dominicanus) and African black oystercatchers (Haemotopus moquini).

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 4-7 Important Bird Areas

Marine Baseline

4.1.8.1 Local Oceanography and Hydrodynamics The tides along the west coast of southern Africa, including Saldanha Bay, are semi-diurnal (two high and two low tides per tidal day). The tidal characteristics for Saldanha Bay are typical of a micro-tidal regime and indicate an approximate 2 m tidal range during spring tides (van Ballegooyen et al. 2007).

The hydrodynamics of the Saldanha Bay/Langebaan Lagoon system is complex. It is influenced by the cold, northward-flowing Benguela current that exerts large scale forcing functions in the Bay. Additionally, the circulation and currents within the system are influenced by the varied geometry of the bay and lagoon, winds and tides and the thermal stratification (CSIR 2014).

Past studies suggest that wind-forcing is the dominant mechanism controlling surface current direction and magnitudes within the Saldanha Bay. Current velocities within Small Bay are generally low, ranging between 0.05 and 0.15 m/s and tended to flow in a clockwise direction irrespective of the tidal or wind conditions. In Big Bay, greater current velocities ranging between 0.1 and 0.2 m/s were observed, and current directions (anti-clockwise) within the main channels were dependent on tidal conditions (CSIR 2014, Anchor 2020). The strongest tidal currents were recorded at Langebaan Lagoon's mouth with velocities of 0.5 - 1 m/s, and these were either enhanced and reduced by the prevailing wind direction (Shannon and Stander 1977; Anchor 2020). High current velocities, mainly due to tidal forcing, also occur at the entrance to Small Bay and between Elands Point and Marcus Island (CSIR 2014).

The predominant south-south-easterly wind results in a weak clockwise circulation in Small Bay and a stronger anti-clockwise circulation in Big Bay; water from Big Bay flows down the east side of the iron ore jetty and then enters Small Bay during the incoming tide. South-westerly winds cause a well-defined clockwise circulation in Small Bay, with the water flowing out of the bay along the iron ore jetty. North-westerly

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. winds (which typically occur during winter) cause water to enter Small Bay down the bay's centre and leave it against its east and west margins; circulation in Big Bay under north-westerly wind conditions is clockwise. Construction of the iron ore terminal and the Marcus Island causeway had a significant impact on the distribution of wave energy in Saldanha Bay, particularly in the area of Small Bay (Weeks et al. 1991). Wave conditions within the bay are sheltered compared to those outside the bay since all energy reaching the bay has to pass through the relatively narrow channel between Marcus Island and Elands Point. The median significant wave height measured in the entrance to the bay is 1.1 m, while the most notable occurrence of peak periods lies in the 10 to 12 s range. Measurements from a wave buoy near Small Bay entrance displayed the largest wave height in winter and the smallest in summer (CSIR 2008).

4.1.8.2 Port Water Quality Temperature Historical baseline data (before the development of the Bay as an industrial port) reported by Shannon and Stander (1977) indicate that surface water temperatures varied between 16 and 18.5 C during summer and between 14.5 and 16˚C during winter. During both the summer and winter surveys, higher temperatures were recorded in Langebaan Lagoon and the northern part of Small Bay, compared to Big Bay temperatures. During winter and spring, the water column was reasonably well-mixed (slight variation in temperature with depth). The absence of a thermocline was interpreted as evidence of wind-driven vertical mixing of the Bay's shallow waters. During summer and autumn, a clear shallow thermocline was observed at about 5 m depth at some deeper stations indicating a stratified water column. The absence of a thermocline at other shallow sampling stations was once again considered evidence of strong wind-driven vertical mixing (Shannon and Stander 1977). More recent surveys by van Ballegooyen et al. (2012) observed similar patterns to the historical data. Also, they found that in summer, stratification was less pronounced in Big Bay than in Small Bay. This was attributed to more turbulent conditions in Big Bay compared to Small Bay. A strong thermocline was also evident in the shipping channel, which is more accessible to the cold bottom waters associated with upwelling that enters the Bay (van Ballegooyen et al., 2012).

Data collected from April 2014 to April 2020 in Small Bay (reported in Anchor 2020) also showed a similar pattern to historical data, with warmer water temperatures during the summer and spring months ranging approximately from 10 (at 12 m) and 21°C (at the surface). During winter and autumn months, temperatures were cooler and ranged from approximately between 11 and 16°C.

Salinity Salinity values recorded for Saldanha Bay usually fall within the range of 34.6 and 34.9 PSU, the range of salinities that typically occur in inshore waters along the west coast of South Africa (van Ballegooyen et al. 2007). During summer, wind-driven coastal upwelling brings cooler less saline water into Saldanha Bay. Consequently, the bay's salinity is usually slightly lower in summer than in winter when the upwelling front breaks down and warmer, more saline surface waters enter the bay (van Ballegooyen et al. 2008). A collation of historical data (reported in Anchor 2020) also showed that when the water column is stratified in summer, surface salinities may be slightly elevated due to evaporation. pH Measurements of pH recorded by Shannon and Stander (1977) in Saldanha Bay were generally high, with values over 8.4 being recorded on several occasions. pH generally decreased with depth, and the mean levels within the bay ranging from 8.12 and 8.26. High levels are likely linked to primary production.

Dissolved Oxygen

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Dissolved oxygen concentrations measured by van Ballegooyen et al. 2012) indicated that concentrations are high in winter (approximately 8 mg/L) with slight variation in depth, whilst in summer and early autumn, surface concentrations were just over 8 mg.L-1 but decreased in the bottom waters to between 3 and 4 mg/L. The surface concentrations were similar to the baseline concentrations reported by Shannon and Stander (1977) of 8.6 mg/L; however, Shannon and Stander (1977) reported higher bottom concentrations of 5 mg/L for April 1974 to October 1975.

More recent dissolved oxygen measurements (2020 measurements) in Small Bay and Big Bay (reported in Anchor 2020) were also comparable to those measured by van Ballegooyen et al. 2012 as they showed that hypoxic conditions (reflecting low oxygen upwelled water) in bottom waters (<2 ml/L) continued until autumn (late May) after which the onset of winter led to higher concentrations as a result of the decline in upwelling and turbulent mixing of the water column (Anchor 2020). It was then noted in Anchor (2020) that the significant increase in the frequency of Small Bay hypoxic events occurred after the significant harbour development in the 1970s, and the situation did not appear to have changed much since the development.

Additionally, the more recent data revealed that Big Bay’s hypoxic events during autumn were of a lower magnitude seen in Small Bay. This was attributed to better mixing of the water column in Big Bay, lower retention times (enhanced flushing) and lower organic loading from anthropogenic sources (e.g., mariculture, fish factory effluent, wastewater treatment works) (Anchor 2015).

Turbidity van Ballegooyen et al. (2012) describe Saldanha Bay's water as being “fairly turbid”, the turbidity comprising both organic and inorganic particulates that are suspended in the water column. Strong wind conditions in the bay result in a peak of turbidity values due to wind and wave action that suspends particulate matter in the water column, particularly Big Bay. Phytoplankton blooms and shipping movements have also been observed to cause significant increases in turbidity in the Bay.

Turbidity data measured in Small Bay by van Ballegooyen et al. (2012) indicated that total suspended solids (TSS) concentrations were greatest near the seabed, particularly at the shallower areas. Concentrations generally did not exceed 10 mg/L, except for a few occasions where higher TSS of between 10 mg/l and 40 mg/l were observed typically in the near-bottom water at a Mussel Farm site in Big Bay and near the berths along with the iron ore terminal. A few values above 100 mg/L were recorded in the iron ore terminal's vicinity, attributed to shipping activities. The water column turbidity measurements reflected the same general trends as the TSS measurements, with turbidity in winter generally in the range of 5 to 12 NTU. In the other seasons, the turbidity typically ranged between 5 and 8 NTU (van Ballegooyen et al., 2012).

Nutrients As previously discussed, the water column in the bay becomes highly stratified in summer due to surface warming and the penetration of cold bottom water forced by coastal upwelling on the shelf (Monteiro and Largier 1999). The cold, upwelled water is rich in nitrogen, some of which enters the surface layer by advection. Phytoplankton biomass and productivity are primarily controlled by the physical state of the bay as determined by upwelling processes on the shelf, which control the advective exchange of phytoplankton and the input of nutrients from the coastal upwelling system and by local wind stress responsible for vertical mixing of the water column, thereby influencing the vertical distribution of phytoplankton and the entrainment of nutrients from bottom waters (Pitcher and Calder 1998).

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

4.1.8.3 Local Sediment Characteristics Particle Size The particle size composition of sediment provides important information for interpreting contaminant concentrations. Contaminants such as toxic organic pollutants and trace metals are strongly associated with fine sediment particles (mud and silt), as there is a larger binding surface (large surface area to volume ratio) (DEA 2012). Higher proportions of mud, relative to sand or gravel, can increase organic loading and trace metal contamination. Sediment particle size also influences the structure and composition of benthic macrofaunal communities.

The particle size of sediments occurring in the greater Saldanha Bay area is strongly influenced by wave energy and circulation patterns. Historically, surficial sediments in Big Bay and Small Bay comprised very fine (0.063-0.125 mm), fine (0.125-0.25 mm), or medium (0.25-0.5 mm) sand (Flemming 1977). Changes in the local wave climate and hydrodynamics due to the construction of port infrastructure have affected sediment particle size distributions. This was particularly evident in Small Bay in the early 2000s, where the reduced wave energy and sporadic dredging activities resulted in an accumulation of mud (<0.063 mm) along the iron ore jetty on the eastern side of the bay and near the yacht basin on the western side (Anchor 2020). Since 2010 the percentage of mud in sediments at most Small Bay sites has declined (Anchor 2020). Previously, the percentage of mud in sediments at sites in Big Bay was lower than those in Small Bay. The most recent State of the Bay survey, in which ten sites in Small Bay and nine sites in Big Bay were sampled (Figure 4-7), indicated that all sites predominantly comprised sand (0.063-2 mm), but sites in Big Bay on average had the highest proportion of mud (Anchor 2020). Sites in the vicinity of the FSRU and subsea gas pipeline (sites BB21, BB22, LPG, BB2 and BB26) had some of the highest proportions of mud.

Figure 4-8 Location and depth ranges of sites in Small Bay and Big Bay Anchor (2020)

Total Organic Carbon and Nitrogen Organic matter in the marine environment has multiple natural and anthropogenic sources. The accumulation and subsequent bacterial breakdown of organic matter in sediment can lead to hypoxia or anoxia, resulting in toxicity for living organisms, severely altering the structure and composition of bottom-dwelling communities.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Historical data show that, before any significant development, TOC levels in Saldanha Bay were mostly low (between 0.2 and 0.5%). With the construction of the iron ore terminal and the establishment of the mussel farms in Small Bay, there has been an increase in TOC levels, particularly at the yacht club basin, the Multi- Purpose Terminal and at the liquid petroleum gas facility (sites SB1, SB14 and LPG, Figure 4-7. In the first survey of TON levels within Saldanha Bay conducted in 1999, concentrations were low (<0.2%) at most sites but were elevated at the yacht club basin and near the mussel rafts in Small Bay (site SB9, Figure 4-7). Accordingly, in recent surveys, the concentrations of organic content were highest where mud accumulates in Small Bay at the yacht club basin, near the mussel rafts and at the Multi-Purpose Terminal and in Big Bay near the LPG facility, in the vicinity of the proposed FSRU location (Anchor, 2020). However, the TOC concentrations measured at these sites in the 2020 State of the Bay Survey have dropped slightly compared to the concentrations previously measured, but the TON concentrations have increased. Consequently, during the 2020 survey, the ratios between TOC and TON in sediments at these sites were increased. They were above the range characteristic of marine production, indicating either the terrestrial (anthropogenic) origin of organic matter in these areas or that denitrification has occurred (Anchor 2020). Given the shallow water depths at many of these sites, the former is most likely.

Trace Metals Disturbances in the marine environment, either anthropogenic or natural, can increase trace metal concentrations in seafloor sediments. These contaminants, if bioavailable, can have negative impacts on benthic communities, particularly filter feeders. The Benguela Current Large Marine Ecosystem (BCLME) program developed a standard set of sediment quality guidelines for the coastal zones of Angola, Namibia and the west coast of South Africa (CSIR 2006). These guidelines are used here to determine the quality of sediments, in terms of trace metal concentrations, in Saldanha Bay.

Dramatic and concerning increases in trace metal concentrations, especially cadmium and lead, were initially noted in Saldanha Bay after the port's commencement of lead and copper exports. Since 1999 however, although still above pre-development conditions (i.e. pre-1980), metal concentrations have been shown to decrease (Anchor 2020) generally.

Table 4-1 Trace metal concentrations (mg/kg) in surface sediment from sites in Small Bay and Big Bay Anchor (2020)

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

The BCLME recommended guideline level (RGL) and probable effects concentration (PEC) are also shown and concentrations above the RGL are highlighted in bold.

During the most recent State of the Bay survey, trace metal concentrations were generally elevated in Small Bay muddy sediments at sites situated near the Yacht Club Basin and adjacent to the iron ore jetty (Anchor 2020). Concentrations of cadmium (Cd) and copper (Cu) exceeded the recommended guideline level at the yacht basin (SB1), concentrations of nickel (Ni) exceeded the recommended guideline level at site SB5 and concentrations of lead (Pb) exceeded the recommended guideline level at the Multi-Purpose Terminal (SB14). Normalised metal/aluminium ratios indicated that in areas where the recommended guideline was exceeded, pollution sources were anthropogenic and were likely related to shipping and boating and industrial activities (Anchor 2020). However, all trace metal concentrations at these sites were within the BCLME guideline probable effect concentration (Table 4-1). Trace metal concentrations in sediment at all sites in Big Bay, including those surrounding the proposed FSRU and subsea gas pipeline location, were below the respective recommended guideline levels. While no BCLME guideline for manganese exists, higher manganese concentrations, relative to other sites, were found at areas surrounding the iron ore jetty (SB9, SB14, SB15 and BB22). These concentrations are likely explained by the increase in manganese exports from the Port since 2014.

4.1.8.4 Local Marine Ecology Marine ecosystems comprise a range of habitats, each supporting a characteristic biological community. Small Bay and Big Bay's important habitats include the subtidal macroalgae beds, the subtidal benthic zone, and the water body itself.

Intertidal and Shallow Subtidal Habitats Anchor Environmental has conducted annual sampling of Saldanha Bay's intertidal regions since 2005 as part of the annual State of the Bay monitoring. The majority of the Saldanha Bay system is characterised by relatively rocky intertidal shores where exposure to wave action is the primary driver of intertidal community assemblages. Exposed regions of the Bay are typically rocky and dominated by bivalves and filter feeders. In contrast, more sheltered areas are prone to sand and gravel accumulation and are generally dominated by seaweeds and macroalgae (Anchor 2019).

The rocky intertidal habitats in Saldanha Bay display typical zonation patterns, with total algal and biotic cover increasing from the high to the low shore. The species that occur are representative of rocky intertidal habitats in the southern Benguela (Anchor 2020). For the most part, the high shore regions throughout the Bay are primarily barren rock with minimal algal cover. In sheltered areas, the high shore is typically dominated by the winkle Oxystele Antoni while in exposed areas, the winkle Afrolittorina knysnaensis and the anemone Bunodactis reynaudi are generally present (Anchor 2020). In the mid-shore, prevalent within the smaller, sheltered rock pools are cushion starfish (Parvulastra exigua), the whelk (Burnupena spp.) and the periwinkle (Oxystele antoni). Regions exposed to higher wave action are typically dominated by filter feeders, including four alien species: the Mediterranean mussel Mytilus galloprovincialis, and three barnacle species Balanus glandula, Perforatus perforatus and Amphibalanus amphitrite (Anchor 2019, 2020). These species are typical of rocky intertidal habitats in the southern Benguela.

Sandy beach habitat also occurs in Big Bay and Small Bay, but beach erosion is a significant issue. The shallow intertidal beach area in Small Bay's northern section is essential for fish recruitment (Anchor 2020).

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Macroalgae Subtidal macroalgae beds, dominated by the agarophyte Gracilaria gracilis, occur loosely attached to or drifting above sandy substrates in Small Bay's northern inshore area 1.5 km from the proposed Powership mooring location. These beds provide habitat and grazing opportunities for multiple sandy bottom marine fauna, including fish, limpets and urchins (Anderson et al. 1993). Commercially, beach-cast seaweed is collected and is processed for agar, dried and exported to foreign markets and used as abalone feed (Rothman et al. 2008, TNPA 2020). Wash-ups of Gracilaria gracilis has been very sporadic over the last several decades. An initial significant decline in the resource occurred in 1974, probably due to an increase in development in the Bay, including the iron ore jetty (Rotmann 1990, Rothman et al. 2008). Subsequently, another collapse, attributed to grazing by herbivorous fish and invertebrates, happened in the late 1980s (Anderson et al. 1993). Diver surveys conducted in 2006 and 2007 at 50 sites in Small Bay estimated the standing stock to be 538 tons fresh weight (Rothman et al. 2008). Due to the variable and declining abundance of this resource, future development occurring in Small Bay needs to be cognisant of these macroalgae beds' effect.

Figure 4-9 Gracilaria gracilis washed up on beaches in Small Bay, Saldanha Bay September 2015. Photograph provided by Dr R. Anderson, Department of Biological Science, University of .

Subtidal rocky habitats within the Bay are dominated by kelp (Laminaria pallida and Ecklonia maxima). The kelp beds provide shelter for many species and are important for recruiting juvenile west coast rock lobster (Jasus lalandii) (CSIR 2014).

Benthic communities The numerous anthropogenic activities in Saldanha Bay in the early 1970s, including the iron ore terminal construction, altered physical conditions and led to declines and changes in the benthic communities present (Kruger et al. 2005). Since then, the annual State of the Bay monitoring had revealed that the macrobenthic community in Small Bay and Big Bay has been relatively stable over the period 1999 to 2020, except for three instances in 1999, 2008 and 2012 when declines in species abundance and biomass were observed (Figure 4-9), and shifts occurred in community composition (Anchor 2020). There was a decrease in the abundance and biomass of more sensitive filter feeders and an increase in shorter-lived opportunistic detritivores. It has been suggested that these changes in community structure are linked to dredging events.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

In the most recent State of the Bay survey, benthic community diversity was lowest in Small Bay in the vicinity of the yacht club basin and Sea Harvest (SH in Figure 4-10) discharge and Big Bay, near the proposed FSRU and subsea gas pipeline location, at the iron ore terminal and site BB26 (Figure 4-10). This is attributed to the higher levels of anthropogenic disturbance, including dredging and a high proportion of mud content in these areas (Anchor 2020). In 2019, reduced indices of abundance, biomass and diversity were observed at the LPG site, near the proposed FSRU location, which appears to be linked with the increased disturbance due to the installation of the single point mooring (SPM). In 2020, results showed evidence of recovery in this area (Anchor 2020).

Benthos species/taxa frequently found in Saldanha Bay include detritivorous crustaceans such as Spiroplax spiralis, polychaetes Polydora spp. and Orbinia angrapequensis, the sea cucumber Listriolobus capensis, predatory whelks of the genus Nassarius, filter-feeding amphipods Ampelisca spp. and the mud prawn Upogebia capensis; these species were common in samples collected from Small Bay and Big Bay (Anchor 2020).

Figure 4-10 Annual trends in the abundance and biomass of benthic macrofauna in Small Bay and Big Bay from 1999 - 2020 (Anchor, 2020)

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 4-11 Variation in the species diversity of benthic macrofauna in Small Bay and Big Bay (Anchor, 2020)

Phytoplankton Saldanha Bay is a highly productive system owing to its link to the southern Benguela upwelling system. Phytoplankton comprises the bulk of microalgae biomass in the Bay (CSIR 2002) and can attain concentrations exceeding 40 mg Chl-a/m3 (Pitcher et al. 2015). Mean water column concentrations in Small Bay and Big Bay, in waters surrounding the proposed FSRU and Powership locations, ranging from 5.4 to 31.5 mg Chl-a/m3, with sites in Small Bay generally being characterised by lower Chl-a concentrations and biomass (Pitcher and Calder 1998; Pitcher et al. 2015). Phytoplankton production rates in the Bay have marked seasonal trends, peaking at the end of the upwelling season in summer (Henry et al. 1977). Phytoplankton species composition in Saldanha Bay is characteristic of the southern Benguela system (Van Ballegooyen et al. 2007). In a study conducted by Marangoni et al. (2001), 173 taxa were identified in the Bay, with most of these belonging to the Bacillariophyta (diatoms) and Dinophyta (dinoflagellates). Common diatoms found, especially during the upwelling season, include species from the genera Thalassiosira, Chaetoceros, Eucampia, Stephanopyxis, Asterionella and Odontella. Species of the genera Dinophysis and Protoperidinium were the most common dinoflagellates (Marangoni et al. 2001). The phytoplankton community is dominated by larger celled diatoms in the early part of the upwelling season (spring/summer), which are replaced by dinoflagellates and coccolithophorids and microflagellates in late summer and autumn (Pitcher and Calder 1998). The larger celled phytoplankton's high production rates indicate increased availability of nitrate (NO3) (CSIR 2002). Intrusions of cold, upwelled waters supply these nutrients into Saldanha Bay from the southern Benguela, which are characteristically high in nitrate concentrations (Monteiro and Largier 1999).

Saldanha Bay is susceptible to seasonal blooms of harmful and toxic phytoplankton (harmful algal blooms – HABs) during the upwelling season. These HABs are typically imported features and can develop throughout the spring to autumn upwelling period on the continental shelf to the north of Cape Columbine, where conditions are favourable for dinoflagellate growth, and circulation patterns facilitate their build-up (Pitcher

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. and Calder 2000). HAB formation reaches its highest intensity in the late summer/early autumn period. The blooms may then be advected southwards around Cape Columbine in nearshore waters and then into Saldanha Bay during the relaxation of upwelling (Probyn et al. 2000, Pitcher et al. 2010). Both residence time and ongoing development of HABs within Saldanha Bay are constrained by the net export of surface water from the bay during active upwelling on the adjacent continental shelf (Monteiro and Largier 1999, Pitcher et al. 2010). Even though the HABs in Saldanha Bay primarily exist for relatively short periods, they can be very detrimental to the valuable mariculture activities in the area. Since 1994, paralytic shellfish poisoning caused by Alexandrium catenella and diarrehetic shellfish poisoning caused by Dinophysis acuminata and D. fortii has become common problems for the mariculture operations in the Bay (Probyn et al. 2001).

Another organism that can affect mariculture production is the small brown tide species Aureococcus anophagefferens. In contrast to the other HAB species recorded in the bay, blooms of A. anophagefferens occurred throughout Saldanha Bay and Langebaan Lagoon, persisting for 6-8 weeks in the late summer of 1998 but were not recorded on the adjacent continental shelf (Probyn et al. 2001). It is thought that the blooms of this species originated in a small, enclosed dam in the north-east corner of Big Bay which was an oyster farm site. The occurrence of the brown tide in Saldanha Bay resulted in reduced growth rates and production of farmed mussels and oysters (Probyn et al. 2001).

Zooplankton As seawater exchanges strongly influence Saldanha Bay with the adjacent continental shelf waters, the zooplankton species assemblage in the Bay strongly resembles that in the nearshore area of the southern Benguela upwelling system and is dominated by copepods (Grindley,1977; Shannon and Pillar,1986). Large numbers of meroplanktonic forms are present in the Saldanha Bay system represented by cirripede, polychaete and decapod larvae (Grindley,1977). On the eastern edge of Big Bay, at the head of Langebaan Lagoon, the zooplankton becomes more estuarine in character, as exemplified by the relatively high abundances of the copepod Paracartia africana (Grindley,1977).

Ichthyoplankton The Saldanha Bay/Langebaan Lagoon complex supports diverse and abundant fish communities and provides important nursery habitat for many species essential to ecosystem functioning and integrity. There is evidence of pipefish (Syngnathus acus), harder (Chelon richardsonii), Cape silverside (Atherina breviceps) and white stumpnose (Rhabdosargus globiceps) utilising the area for spawning (Grindley, 1977, Kerwath et al. 2009, Horton et al. 2019).

Fish As a part of the State of the Bay monitoring, seine-net sampling of nearshore fish assemblages (mainly juveniles) was started in 2008. The most recent survey results show some concerning trends in juvenile fish populations (Anchor, 2020).

Fish species diversity in Small Bay was the lowest recorded in the survey history but in Big Bay was equal to the long-term average. Fish abundance compared favourably to previous surveys conducted, but this

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. mainly reflected the abundance of the two most abundant fish in the area, harders (Chelon richardsonii) and Cape silversides (Atherina breviceps). In Small Bay, there has been a declining trend in white stumpnose (Rhabdosargus globiceps), blacktail (Diplodus sargus capensis) and goby (Caffrogobius spp.) abundance, while in Big Bay, average harder abundance was comparable to earlier surveys, but the abundance of the four following most common species, including white stumpnose and elf (Pomatomus saltatrix), was low. White stumpnose is the most important angling species in the Bay. However, recent studies show that the adult stock is overexploited (Parker et al. 2017). Juvenile elf has not been recorded in Big Bay since 2018, and not a single elf was caught at any of the other 15 sites sampled during the 2020 survey. This is concerning as adults of this species are also caught by the recreational fishery. Declines in the abundance of gobies in Small Bay cannot be attributed to fishery impacts; however, maybe as a result of a reduction in water quality. The evidence thus suggests that fishing pressure is having a severe effect on some adult fish populations in Small Bay and Big Bay, which affects juvenile abundance, and that there may be a decrease in habitat quality for juvenile fish in the area.

Several shark and ray species also occur in the Saldanha Bay area, including the smooth hound shark (Mustelus mustelus), which is resident in the Bay (da Silva, 2018). The species utilises the Langebaan Lagoon as a nursery area and mainly occurs in Small Bay and Big Bay during the winter months (da Silva, 2018).

Megafauna Several species of cetaceans are known to visit Saldanha Bay regularly. While there are seasonal peaks in their abundance, individuals are present in all months in the area. Humpback Whales (Megaptera novaeangliae) have been observed within Small Bay and Big Bay. Individuals utilise the waters of the southern Benguela for feeding and usually migrate past Saldanha Bay (Barendse et al. 2010). However, a supergroup comprising ~ 200 individuals was observed feeding in the mouth of the Bay in 2019 (Elwen 2020). Southern right whales (Eubalaena australis) have been observed in Outer Bay between Malgas, Jutten and Marcus Islands (Barendse and Best 2014). However, they have also been observed south of the iron ore jetty in spring are known to feed in this area in spring and summer (Elwen 2020). Dusky Dolphins (Lagenorhynchus obscurus) and Heaviside’s Dolphins (Cephalorhynchus heavisidii) have on occasion been observed in Outer Bay along the outer edge of the Marcus Island causeway. They are likely to occur in Small Bay and Big Bay (Elwen et al. 2010). Killer Whales (Orcinus orca) has also been observed within Small Bay and Big Bay (Best and Meyer 2010).

Although the Cape Fur Seal (Arctocephalus pusillus) no longer breeds or regularly “hauls out” on the islands within Saldanha Bay, a breeding colony occurs south of the entrance to Saldanha Bay, on Vondeling Island (Anchor 2020). The species is regularly observed in Small Bay and Big Bay's waters in all months of the year.

Discussion on the coastal and marine seabirds occurring within the local area is not included in the Marine Ecological Report and is covered by Avifauna specialist.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

4.1.8.5 Local Conservation and Biodiversity The available biological records for Small Bay and Big Bay in Saldanha Bay indicate that none of the marine algae, fish and invertebrate species/taxa has restricted distributions or small population sizes. Many of the organisms are representative of the wider southern Benguela region. Consequently, none of the recorded species is classifiable as either rare or endangered in terms of their conservation status.

Of the vertebrates, several of the fish and megafauna that are known to occur in Small Bay and Big Bay is listed as being threatened by the IUCN Red List (IUCN 2020). The white stumpnose and elf, both of which use the Bay as a nursery area, are Vulnerable, as are the smooth hound shark. Heaviside’s dolphins are listed as being Near Threatened. Several seabirds in the area are threatened, but these are discussed in the Avifauna Specialist Report.

Marcus Island MPA occurs at the entrance to Small Bay and Big Bay, approximately 5 km from the proposed FSRU location. It comprises sparse vegetation and boulders and is connected to the mainland by a 2-km causeway. The island provides critical seabird habitat and hosts breeding populations of African penguins (Spheniscus demersus), bank (Phalacrocorax neglectus), crowned (P. coronatus) and white-breasted (P. lucidus) cormorants and swift terns (Thalasseus bergii) (Animal Demography Unit, 2021).

4.1.8.6 Local Ecosystems Services Small Bay and Big Bay areas provide many of the provisioning, regulating, cultural and supporting services Most of these fall under socio-economic topics, but mariculture is directly dependent on ecosystem health and functionality as discussed below:

Mariculture Saldanha Bay is the only naturally sheltered embayment in the country and is considered a significant mariculture development area (Stenton-Dozey et al. 2001). In 2018, the Department of Agriculture Forestry and Fisheries (DAFF, now the Department of Environment, Forestry and Fisheries, DEFF) was granted authorisation to establish a sea-based Aquaculture Development Zone (ADZ) totalling 884 ha and comprising four areas within the Bay. Two of these areas occur within Small Bay and Big Bay, 1 to 2 km from the proposed Powership and FSRU locations. So far, approximately 36% of the area has been leased (although not all of that area is being actively farmed), and 15 mariculture companies are operational (Anchor 2020). Most established operations farm mussels and oysters, but rights to farm finfish (Atlantic salmon, Salmo salar and Rainbow trout, Oncorhynchus mykiss) have been issued to two farms. Some farms have rights to farm abalone, red bait and seaweed but do not currently practice this right (Anchor 2020).

Raft culture of mussels (Mytilus galloprivincialis and Choromytilus meridionalis) has been undertaken in Saldanha Bay since the mid-1980s (Stenton-Dozey et al. 2001). Most of the farming occurs in Small Bay. However, the Saldanha Bay Oyster Company and West Coast Oysters also grow mussels (and oysters) in Big Bay. Mussel production has been increasing exponentially since 2007, peaking in 2019 at 3053 t. In 2015, the mussel sub-sector contributed 48.83% of the total mariculture volume produced in the country (DAFF 2016). Oyster production has fluctuated around 250 t per annum and reached a peak in 2016 at 337

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. t but has since decreased to 288 t in 2019 (Anchor 2020). Stenton-Dozey et al. (2001) reported on organic enrichment and anoxia in sediments under the mussel rafts in 1997 and 1998 and an associated reduction in macrofauna's biomass. A study conducted by Olivier et al. (2013) investigated the bay's potential ecological carrying capacity to produce bivalves (oysters and mussels). They estimated that a 10-28 time increase in the size of this sector, providing additional employment for 940-2500 people, could occur without compromising the bay's environment and ecological functioning as a whole.

A previous attempt by Southern Atlantic Sea Farms to establish an Atlantic salmon cage farm in Outer Bay was unsuccessful. However Molapong Aquaculture (Pty) Ltd (Molapong) was successful in piloting a finfish farm in Big Bay, producing 50 t per annum. Molapong has since been granted authorisation for the phased installation of sea cages covering 40 ha in Big Bay to produce finfish, mussels and seaweed (Anchor 2020).

4.1.8.7 Marine Water The seawater temperatures in Saldanha Bay are characterised by two distinct seasons. During the winter months, the water column is well-mixed, while wind-driven upwelling and surface heating induce a stratified water column in summer. The time-series plot indicates that the model is able to adequately reproduce both the winter and summer temperature profiles.

The influx of upwelled cold water on the seabed is caused by wind-driven currents. Therefore, the accuracy with which the model is able to reproduce the upwelling events serves as an indication that currents in Small Bay and the exchange of water between the ocean and the bay are well-represented. The favourable comparison of surface temperatures during calm periods in summer also confirms that the heat exchange between the water surface and the atmosphere is adequately represented.

The dispersion of the resulting thermal plume depends on the flow rate, ΔT, discharge geometry, bathymetry, currents, winds and water column stratification. In confined water bodies with low water exchange there can be a build-up of temperature including recirculation from the intake to the outlet.

Typical ecological thresholds include ΔT = 3°C at 100 m from the discharge point (World Bank), ΔT = 1°C at sensitive receptors or the edge of the mixing zone, which for discharges beyond the surf-zone can be assumed as 300 m from the discharge point, according to the South African Marine Water Quality Guidelines (DWAF, 1995).

4.1.8.8 Marine Ecology The Port of Saldanha in located in Saldanha Bay on the west coast of South Africa. It occurs in the cold, temperate Southern Benguela Shelf Ecoregion and within the Cape Subregion, which encompasses the coast from Cape Point to Cape Columbine (Sink et al. 2019). The Southern Benguela is characterised by the Benguela Current and associated large-scale intensive upwelling of nutrient rich water. As a result, it is South Africa’s most productive ecoregion.

Saldanha Bay and the adjacent shallow, tidal Langebaan Lagoon comprise the largest body of wave- sheltered water on the South African coast and host ecologically unique and valuable resources. The water body includes four distinct areas: Outer Bay, Small Bay, Big Bay and Langebaan Lagoon. The port facilities

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. occur mainly within Small Bay, which is separated from Big Bay by the general cargo quay and the iron ore and oil terminal jetty. The proposed floating power plant facilities are located in Small Bay and Big Bay. A number of ecologically important and sensitive marine habitats (considered as those below the high water mark) occur in this area. These include: . The West Coast National Park Marine Protected Areas (MPA) Network which comprises the Langebaan Lagoon MPA as well as the Island MPAs of Malgas, Jutten and Marcus. These areas provide nursery habitat to a number of fish species, some of which are recreationally and commercially important. The islands provide important nesting sites for seabirds. . The Gracilaria beds which occur in the northern inshore area of Small Bay, approximately 1.5 km from the proposed Powership mooring location, and provide habitat and grazing for multiple marine fauna. This seaweed is also commercially harvested. . The water body in the port that supports ecological processes that sustain the biological communities of the system.

Importantly, the marine environment within Saldanha Bay is a major mariculture development area and forms one of the largest aquaculture development zones in South Africa. Much of the aquaculture in the area comprises mussel and oyster farms that occur in both Small Bay and Big Bay in close proximity to the proposed floating power plant facilities. Portions of the Big Bay precinct have also been designated for finfish culture.

4.1.8.9 Marine Traffic The Port of Saldanha Bay is South Africa’s deepest draft port and handles approximately 70 million tonnes of cargo per year (TNPA, 2019). The port was initially conceived as an iron ore export facility in order to exploit the discovery of highgrade iron ore at Sishen in the Northern Cape, 860 km to the north east of Saldanha Bay. The iron ore export jetty provides berthing for two Very Large Bulk Carriers (VLBCs), a liquid bulk berth for Very Large Crude Carriers (VLCCs) for the import of crude oil, as well as an LPG multi-buoy mooring (MBM) for gas import. The port has iron ore stockpiles on reclaimed land, a multi-purpose terminal with four berths, and ship repair facilities for offshore rig servicing and fabrication.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 4-12 Current layout of Port of Saldanha

A marine traffic analysis was undertaken to ascertain the effect of LNG vessels calling at the proposed FSRU spread mooring in the port. The effect will be ascertained on both the current and future vessel traffic of the Port of Saldanha. The FSRU will be refuelled by LNG carriers (LNGC) that will moor to the vessel in a Ship- To-Ship (STS) configuration. The Powership and FSRU will be moored on independent spread-moorings. LNG delivery will consider LNGC vessels, with a capacity of 218 000 m3 shall be considered. The marine traffic analysis is based on the upper LNG demand estimate of 24 vessel calls per annum.

The average number of traffic vessels calling at the Port of Saldanha Bay for a typical calendar year is 600 vessels. The largest number of vessel calls are in the Cape Size range, with the majority being for iron ore export. The existing traffic in the port considers MPT vessels of 60 000 DWT manoeuvring to and from berths 201 to 204, oil tankers of 200 000 DWT and bulk carriers of 150 000 DWT manoeuvring to and from the iron ore and oil jetty respectively. Other traffic in the port considers rig moves and ship repair vessel moves past the proposed FPP site towards the Rock Quay or Mossgas Quay. This traffic may impact the FPP site, but the assumed frequency of this traffic will be low, and it is further assumed that operational procedures in the port would only allow this traffic when environmental conditions are favourable.

Coastal and Climate Change 4.1.9.1 Coastal The Saldanha Bay port is protected on the west by a rocky headland and a constructed causeway that joins a small island to the mainland. To the east it is bound by the Sishen pier constructed principally for the transport of iron and steel by Sishen Pty Ltd. The predominant wave direction is from southeast with littoral drift along the coast in a northerly direction along the broader coastline. The waves do however tend to refract

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. around the two headlands in the bay, generally causing littoral drift from north to south along the bay under natural conditions (Gericke & Eckardt 2008).

Under natural conditions, the beaches in the vicinity of the harbour would supply sediment southwards towards Langebaan, but after construction of the causeway and Sishen pier, the littoral drift has effectively ceased to occur. The beaches to the south of the harbour were starved of sediment and eroded until a new equilibrium state was reached which occurred in succession southward over time.

Subsurface sediment is therefore presently in an unnaturally stable static state and impacts on beach sediments are unlikely to have any impact on beaches and similar subsurface and shoreline sedimentary features in the Langebaan/Saldanha system beyond impact sites.

Coastal dunes lie along the beach to the southeast of the Sishen pier. These dunes interact with the beach preferentially during the summer dry period (when sediment is dray and transported more easily) in southeast winds and are supplied with sediment from the beach. Given the reduction in availability of beach sediment over time, transport of sediment into the dunes is likely to reduce. In response the dunes have become largely vegetated and entered their own stable sedimentary state (Gericke and Eckardt 2008).

4.1.9.2 Climate Change The Saldanha Bay site is considered to have a low sensitivity and associated risk with regard to climate change adaptation. The most significant potential concerns include risks to the project as a result of climate change, including (sea-level rise) SLR projections and an increased incidence of extreme storms. These concerns are not considered to be of high significance because: i) most of the infrastructure associated with the project will not be susceptible to SLR (as the Powership and FSRU are mobile floating platforms); and ii) the location of the project within the port will provide ample protection from extreme storms.

There is a minor possibility that the project activities could exacerbate existing climate change concerns, including reduced water availability and the increased risk of wildfires. However, as the likelihood and significance of these impacts are minor, the project is likely to increase local adaptive capacity, by providing local, on-demand energy generation from a less carbon-intensive source.

Air Quality, Noise and Visual

4.1.10.1 Air Quality

Ambient SO2, NO2 and PM10 concentrations at the Saldanha Bay monitoring station in Saldanha Bay are relatively low and below the NAAQS. The additive effect of the contribution from the Karpowership Project is likely to be small and the potential increase in ambient concentrations is unlikely to result in exceedances of the NAAQS. Saldanha Bay Municipality is responsible for monitoring ambient air quality within its jurisdiction. Further engagements with SBM regarding this aspect is anticipated.

Natural Gas (NG) will be the primary fuel used for the generation of electricity in the proposed project. The pollutants that are usually emitted include oxides of nitrogen (NOx), sulphur dioxide (SO2) and particulate matter (PM10). Preliminary findings of the air emission impact are captured in Section 8 of this report – Preliminary Impact Assessment.

4.1.10.2 Noise

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

The Powership will be berthed along the quay in the Port of Saldanha, approximately 550m off the shore. The section below provides specific information on the receiving environment with regards to the noise impact assessment, including the results of field monitoring. The noise sensitive areas (NSA’s) have been identified and illustrated in Table 4-2 and Figure 4-12 below. The distances are calculated based on the closest noise source in relation to the noise sensitive area.

Table 4-2 Location of Noise Sensitive areas

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 4-13 Noise Sensitive Areas

The rating levels above indicate that in industrial districts (in the Port of Saldanha) the noise should not exceed 70 dB(A) during the day and 60 dB(A) at night. In Suburban areas such as BlouWater Bay, the noise should not exceed 50 dB(A) during the day and 40 dB(A) at night. There are however no rating levels for protected natural environments. These areas should ideally be free of any anthropogenic noise sources. These rating levels can thus be seen as the target levels for any noise emissions from a nearby industrial facility. As can be seen from the ambient noise monitoring results, the ambient noise is not exceeding the recommended day/night rating levels of industrial districts. Furthermore, the South African noise control regulations and the local authority regulations describe a disturbing noise as any noise that exceeds the ambient noise by more than 7dB. This difference is usually measured at the complainant’s location should a noise complaint arise. Once again this will not strictly apply to a protected area that has no permanent human recipients. The noise emissions primary impact will be on the terrestrial animals within the project area.

The most applicable standard for planning purposes used in this study is SANS 10103:2008 which provides typical rating levels for noise in various types of districts. Ideally, in such areas one does not want to experience any anthropogenic noise pollution. SANS 10103:2008 provides typical rating levels for noise in various types of districts, as described in Table 4-4 below.

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Table 4-3: Typical rating level for noise in various district types Equivalent Continuous Rating Level, LReq.T for Noise Outdoors (dB(A)) Indoors, with open windows (dB(A)) Type of District Day- Night- Daytime Day-night Daytime Night-time night time Rural Districts 45 45 35 35 35 25

Suburban districts with little 50 50 40 40 40 30 road traffic

Urban districts 55 55 45 45 45 35

Urban districts (Workshops; 60 60 50 50 50 40 business premises & main roads

Central business districts 65 65 55 55 55 45

Industrial districts 70 70 60 60 60 50

The highlighted red font are the rating limits applicable to this project in the Port of Saldanha (Industrial Districts) as well as the closest residential area, namely, Blouwater (Sub-urban District with little road traffic).

4.1.10.3 Visual The proposed site is located within the water space of Saldanha Bay as well as the immediately adjacent coastal plain. The general area has a mixture of development much of it is industrial, transport and logistics orientated. In the immediate vicinity of the proposed project major infrastructure and large scale industrial structures are dominant features.

Landform and Drainage  The study area is comprised of the west coast coastal plain. It is generally flat with limited undulations and ridgelines.  The landform rises relatively rapidly from the coastline to 60 - 70m amsl which is maintained to the foot of more mountainous area approximately 70km inland. The elevation does rise to approximately 150m amsl in the north around the town of Vrenderburg and to the south of Langebaan.  The Berg River is the main drainage feature located towards the north of the study area. This river has cut a broad valley through the landform reducing levels in the vicinity of the river channel to below 10m amsl.  The extent of open, relatively flat land surrounding the proposed development could mean that the proposed development may be visible over an extensive area.

Nature and Density of Development Built development within the study area can be divided into the following:  Urban development including the towns of Langebaan, Saldanha and . These are relatively small towns with reasonably good infrastructure. Views of the broader landscape are probably only possible from the edges of urban development areas.  Agricultural development in the study area is largely comprised of pasture for livestock production. This results in an open landscape within which the main elements that are likely to influence visibility

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of the proposed power line are the minor ridgelines located within the vicinity. Isolated farmsteads are located around the maize/wheat fields that include farmhouses, workers accommodation, storage and farm working areas. The farm houses and accommodation areas are often surrounded by trees that were possibly planted as wind breaks as well as for ornamental reasons.  Industrial Development including oil storage, paper production and steel production have all been attracted to the area around the port of Saldanha Bay. The necessary infrastructure to supply power and support these heavy industries is also evident throughout the landscape.  The water space within Saldanha Bay which is a major national port. Its main functions include that of a base for the South African Navy as well as being a major industrial port. The port is particularly important for the export of iron ore as it is linked directly to inland mines by rail link. It is also becoming increasingly important for offshore oil exploration. Specialist drilling ships and rigs are not unusual in the port. As with all South African Ports, whilst shipping operations are the prime function, it is also important for coastal recreation / tourism, aquaculture and bio-diversity.

Coastal areas to the west of the study area are also developed as tourist destinations. Mykonos, Langebaan and areas to the south particularly around the lagoon are tourism areas of possible national importance.

Two major conservation areas are located to the south east of the study area, these include;  The West Coast National Park which is a formally protected area, and  The Saldanha Nature Reserve which is a provincial nature reserve.

These areas are largely covered with natural Fynbos which produces a very open landscape.

Figure 4-14 Landcover map of Saldanha Bay

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

HERITAGE AND ARCHAELOGY

Heritage Numerous surveys have been undertaken in the Saldanha Bay IDZ and surrounding area (Kaplan 1994, 1996, 1997, 1998). The majority of the resources comprise isolated tools, and occasionally dispersed (i.e. low density) scatters of Early Stone Age and Middle Stone Age tools (of low archaeological significance), mostly always in a highly transformed and degraded context (see also Kaplan 2006, 2010; Hart 2003; Hart & Pether 2008). Occasionally, Later Stone Age remains have also been recorded (Kaplan 2007a, b).

Exceptions are at Hoedjiespunt and Sea Harvest directly at the coast, where Middle Pleistocene archaeological occurrences and the recovery of human remains in the Langebaan Formation deposits has provided some of the earliest evidence in the world for the human exploitation of coastal resources, more than 100 000 years ago (Grine & Klein 1993; Volman 1978). Beside evidence of well-preserved bone, ostrich eggshell, ochre and MSA stone implements, the Hoedjiespunt limestone sediments in Saldanha Bay also contains evidence of early modern human about 125 000 years ago (Berger & Parkington 1995).

Palaeontology The proposed project area is situated on the calcreted Langebaan Formation, beneath a thin cover of Springfontyn Formation Q1 surficial sands (Figure 4-3). Close to the coast the Witzand Fm. dunes (Figure 4- 3) are underlain by the older aeolianite of the Langebaan Formation and the interbedded shelly beach deposits of the Fm.

Figure 4-15: Surface Geology

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

SOCIAL AND ECONOMIC CONDITIONS Socio-Economic The area falls within Saldanha Bay Local Municipality, which belongs to the West Coast District Municipality. The local municipality encompasses towns such as Saldanha, Langebaan and Vredenburg.

The Saldanha Bay Local Municipality covers an area of 1 767 km2. According to the Municipality (http://www.saldanhabay.co.za) it has a population size of 88 000. Census 2001 reported a population figure of 70 441. This suggests an increase in the population of the area since 2001 of almost 25%. More than 75% of the municipality’s population live in Vredenburg, Saldanha or Langebaan approximately 12km, 7km and 10km away respectively from the proposed Powership.

The majority of the residents of Saldanha (67%) are – speaking coloured people. English and Xhosa are also spoken in the region. The industrial development in the area led to an influx of new people in the area looking for jobs and new opportunities. The population of the Municipal area increased from a total of 57 031 in 1996 to 84 474 in 2001. This is a 48% increase, which will continue to rise with development along the West Coast, such as increased imports and exports from Saldanha harbour, further industrial development and the possible construction of a gas plant in the vicinity of Saldanha Bay. Continued migration will increase the need for the delivery of basic services, and will be accompanied by secondary service delivery such as health, social and educational services (Saldanha Bay Interim IDP, 2004/5).

The growth rate for the next couple of years is expected to be at least 5%. If this expected growth rate actualises, a population of 250 000 is predicted by 2015. Approximately 33.4% of this population will be employed in the industrial and commercial sectors. This projection assumes that for each primary job opportunity created in the industrial sector, seven people will migrate to the area (Saldanha Bay Interim IDP, 2004/5).

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5 POLICY AND LEGISLATIVE FRAMEWORK

2014 NEMA EIA Regulations (as amended), Appendix 3 (1)- (e) a description of the policy and legislative context within which the development is located and an explanation of how the proposed development complies with and responds to the legislation and policy context.

NATIONAL REGULATORY FRAMEWORK

2014 NEMA EIA Regulations (as amended), Appendix 3 - 3(1)- (e) a description of the policy and legislative context within which the development is located and an explanation of how the proposed development complies with and responds to the legislation and policy context.

National legislation The Constitution, 1996 is the supreme law of the Republic. Any law or conduct inconsistent with it is invalid and the obligations imposed by it must be fulfilled.

 Chapter 2 of the Constitution contains the Bill of Rights, one of which is Section 24: everyone has the right to an environment that is not harmful to their health or well-being; and  to have the environment protected, for benefit of present and future generations, through reasonable legislative and other measures that:  prevent pollution and ecological degradation;  promote conservation; and  secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.

One of the key legislative measures that has been established is the promulgation of the National Environmental Management Act 107 of 1998 (NEMA). NEMA aims to provide for co-operative environmental governance by establishing principles for decision-making on matters affecting the environment, institutions that will promote co-operative governance and procedures for co-ordinating environmental functions exercised by organs of state; to provide for certain aspects of the administration and enforcement of other environmental management laws; and to provide for matters connected therewith.

NEMA prohibits a person from commencing a listed activity without environmental authorisation. The Project triggers several activities listed in the EIA Regulations Listing Notices 1, 2 and 3 of 2014 (as amended). The procedural requirements for such an application and associated EIA that needs to be undertaken, are prescribed by the EIA Regulations, 2014 (as amended) (the EIA Regulations, 2014) and informed by guidelines published in terms of Section 24J of NEMA as well as applicable protocols and minimum information requirements.

In addition, the Project triggers an activity listed under the National Environmental Management: Air Quality Act 39 of 2004 (NEMAQA) which requires an atmospheric emission licence (AEL). The same EIA process prescribed by the EIA Regulations, 2014 need to be applied to the AEL application, with a number of additional requirements set out in NEMAQA and its Regulations.

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As part of the EIA process, the EIA Regulations require that a description of the policy and legislative context within which the development is proposed is reported on in the EIA Report, including an explanation of how the proposed development complies with and responds to such legislation and policy context. This includes an identification of applicable legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks and instruments. This section has been prepared to satisfy this requirement.

The potential environmental impacts associated with the current project are required to be considered in compliance with the 2014 EIA Regulations (as amended), the SEMA’s and the following guidelines: National Environmental Management Act 107 of 1998 Legislation Section Relates to National Environmental Section 2 Contains sustainable development and other Management Act 107 of 1998 principles that apply throughout South Africa to the actions of all organs of state that may significantly affect the environment. Chapter 5 Provides for integrated environmental management including the prohibition, restriction and control of activities which are likely to have a detrimental effect on the environment. Section 28 The developer has a general duty to care for the environment and to institute such measures as may be needed to demonstrate such care. Section 30 Deals with the control of emergency incidents, including the different types of incidents, persons responsible for the incidents and reporting procedures to the relevant authority. Relevance to the Proposed Project, Compliance and Response: Three sets of listed activities, published 4th of December 2014 (w.e.f 8 December 2014) under Government Notices R.983, R.984, and R.985, and subsequently amended, describe the activities that require either a Basic Assessment (applies to activities in Listing Notices 1 and 3)), or Scoping and Environmental Impact Reporting (S&EIR) (applies to activities in Listing Notice 2)). All listed activities that are triggered in the above listing notices need to be assessed in the assessment report – refer to Section 2.2.

Because the Project triggers activities in Listing Notice 2, the application for environmental authorisation is subject to the S&EIR process for all activities, including those listed under Listing Notice 1 and 3. As set out by Section 24C of the NEMA, the relevant competent authority for this activity is DEFF.

The applicable 24J Guidelines which have been applied to the EIA process include:  Department of Environmental Affairs (2017), Public Participation guideline in terms of NEMA EIA Regulations, Department of Environmental Affairs, Pretoria, South Africa.  DEA (2017), Guideline on Need and Desirability, Department of Environmental Affair (DEA), Pretoria, South Africa

The applicable protocols and minimum information requirements which have been applied to this project include the Procedures for the assessment and minimum criteria for reporting on identified environmental themes when applying for environmental authorisation (GN320 in GG 43110 of 20 March 2020; and GN 1150 of GG 43855 of 30 October 2020).

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Measures to protect the environment by mitigating impacts and responding to emergency incidents are contained in the EMPr.

National Environmental Management: Waste Act 59 of 2008 Legislation Section Relates to National Environmental Sections 16 – 18, Provides for general and specific waste management Management: Waste Act 59 21 – 27, 35 - 41, measures; the remediation of contaminated land and of 2008 60 reporting. Sections 19, 20, Requirements for waste management licensing 43 – 59 Relevance to the Proposed Project, Compliance and Response: A number of regulations and standards regulating waste management have been published under NEMWA. including: . List of waste management activities, 2013 (amended) . Waste Classification & Management Regulations, 2013 . National Norms & Standards for the Assessment of Waste for Landfill Disposal, 2013 . National Norms & Standards for Disposal of Waste to Landfill, 2013 . National Norms and Standards for the Remediation of Contaminated Land and Soil Quality, 2014

The EMPr contains a number of impact assessment outcomes and actions that include waste management measures to ensure that: . All reasonable measures must be taken to avoid the generation of waste and where such generation cannot be avoided, minimise the toxicity and amounts of waste that are generated; reduce, re-use, recycle and recover waste; where waste must be disposed of, ensure that the waste is treated and disposed of in an environmentally sound manner; . Manage the waste in such a manner that it does not endanger human health or the environment or cause a nuisance through noise, odour or visual impacts; . Prevent any employee or any person from contravening this Act; and prevent the waste from being used for an unauthorised purpose;

The proposed development does not trigger any listed activities (under Categories A and B) of this Act and as such does not require a Waste Management Licence.

National Environmental Management: Air Quality Act 39 of 2004 Legislation Section Relates to National Environmental Provides for the protection of the environment by regulating air quality in Management: Air Quality Act order to prevent air 39 of 2004 Pollution. Sections 22, 21 Atmospheric Emission Licensing. 22A Sections 23-25 Controlled emitters Section 32 Control of dust Section 34 Control of noise Section 35 Control of offensive odours Relevance to the Proposed Project, Compliance and Response:

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A number of regulations and standards regulating air quality have been published under NEMAQA. including: . National Ambient Air Quality Standards, 2009 . National Ambient Air Quality Standard for Particulate Matter of Aerodynamic Diameter less than 2.5 micron metre (PM2.5), 2012 . Declaration of a Small Boiler as a Controlled Emitter and Establishment of Emission Standards, 2013 . National Dust Control Regulations, 2013 . Listed Activities and Associated Minimum Emission Standards 2013 (amended) . Regulations regarding Air Dispersion Modelling, 2014 . National Atmospheric Emission Reporting Regulations, 2015 . National Greenhouse Gas Emissions Reporting Regulations, 2016 . Declaration of greenhouse gases as priority air pollutants, 2017 . National Pollution Prevention Plans Regulations, 2017 (amended)

The proposed project requires an Atmospheric Emission Licence which will specify conditions. The appointed specialist has applied the air dispersion modelling requirements and the impacts were assessed as very low. Dust related mitigation measures for the construction phase was addressed in the EMPr. GHG emission have also been assessed. It is likely that the steam turbines will be regulated as controlled emitters.

Marine Living Resources Act 18 of 1998 Legislation Section Relates to Marine Living Resources Act Regulates the utilization, conservation and management of marine living (Act 18 of 1998) amended resources and the need to protect whole ecosystems preserve marine 2000 biodiversity and minimize marine pollution. Relevance to the Proposed Project: The Act requires the sustainable utilisation of marine resources. Due to the project being located in the Port of Saldanha Bay, all reasonable measures must be taken to avoid marine pollution that may affect marine living resources. The findings and recommendations of the relevant specialists, including the marine ecologist will be included in the EMPr.

National Environmental Management: Integrated Coastal Management Act 24 of 2008 Legislation Section Relates to National Environmental Section 2 Provides for the protection and to enhance the status Management: Integrated of coastal public property, and secure equitable Coastal Management Act 24 access to the opportunities and benefits of coastal of 2008 public property. Section 13 Persons right of reasonable access to coastal public property as well as the entitlement to use and enjoy coastal public property. Section 58 Duty to avoid causing adverse effects on coastal environment Section 69 Stipulate requirements for permits to discharge effluent that originates from a source on land into coastal waters.

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Relevance to the Proposed Project, Compliance and Response: The discharge of cooled water from the Powership operations is from the moored Powership into the sea, i.e. there is no discharge from land-based activities. DEFF has confirmed that a coastal waters discharge permit is not required. Measures to protect the coastal environment by mitigating impacts and responding to emergency incidents are contained in the EMPr. Further, discharge temperatures will conform to the current guideline, the South African Water Quality Guidelines for Coastal Marine Waters, Volume 1, Natural Environment (1995), i.e. the maximum acceptable variation in ambient temperature will not exceed + or – 1°C, in terms of the targeted value for the South African coastal zone.

National Water Act 36 of 1998 Legislation Section Relates to National Water Act 36 of Regulates the protection, use, development, 1998 conservation, management and control of water resources. Section 19 Prevention and remedying the effects of pollution Section 20 Control of emergency incidents Section 21 Permissible water use, including discharge & abstraction and development within 500m of a watercourse (including wetlands). Relevance to the Proposed Project, Compliance and Response: Should the proposed transmission line be constructed within or within close proximity to a watercourse or wetland a water use license may be required for the proposed development. The Wetland Specialist did not identify and watercourses within close proximity to the proposed project. This information was submitted to the Department of Water and Sanitation. The Department did not indicate the need for any Water Use Authorisation. Measures to protect water resources by mitigating impacts and responding to emergency incidents are contained in the EMPr.

National Forest Act 84 of 1998 Legislation Section Relates to National Forest Act 84 of Section 12 Provides for protection, control and licencing for 1998 cutting, disturbing, damaging or destroying protected trees Relevance to the Proposed Project, Compliance and Response: If any protected trees in terms of this Act occur on site, the developer will require a licence from the DEFF to perform any of the above-listed activities.

National Environmental Management: Biodiversity Act 10 of 2004 Legislation Section Relates to National Environmental Provides for the management and conservation of biodiversity, protection Management: Biodiversity of species and ecosystems, and sustainable use of indigenous biological Act 10 of 2004: resources, including threatened and protected species and ecosystems, Threatened or Protected and invasive and alien species Species Regulations and lists (2007 & 2017 (marine));

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Alien and Invasive Species Regulations and lists (2020) Relevance to the Proposed Project, Compliance and Response: The EIA, including specialist studies and the EMPr identify impacts and contain mitigation measures to: . avoid or minimise impacts on protected and threatened ecosystems and species to protect biodiversity; . Identify permit requirements without which protected species may not be removed or damaged; . Keep the proposed site and transmission routes clear of alien and invasive vegetation using appropriate means.

National Environmental Management: Protected Areas Act 31 of 2004 Legislation Section Relates to National Environmental Provides for the protection and conservation of ecologically viable areas Management: Protected representative of South Africa’s biological diversity and its natural Areas Act (31 of 2004) landscapes and seascapes. Promotes sustainable utilisation of protected areas for the benefit of people, in a manner that would preserve the ecological character of such areas. Relevance to the Proposed Project, Compliance and Response: The Project is situated within the Port of Saldanha, approximately 3.5 km from the Langebaan Lagoon MPA, and the sensitive marine and estuarine habitats therein.

National Environmental Management: Protected Areas Act (31 of 2004) - Strategy on Buffer Zones for National Parks (106 of 2012) Legislation Section Relates to National Environmental Defines buffer zones to protect important areas of high value for Management: Protected biodiversity and/or to society where these extend beyond the boundary of Areas Act (31 of 2004) - the Protected Area; and stipulate legal requirements for developments Strategy on Buffer Zones for within formally established buffer zone. National Parks (106 of 2012) Relevance to the Proposed Project, Compliance and Response: The proposed project is situated within the Port of Saldanha, approximately 3.5 km from the Langebaan Lagoon MPA, and the sensitive marine and estuarine habitats therein, aprt of the West Coast National Park Marine Protected Areas (MPA) Network. The project will be situated well outside the buffer areas.

National Heritage Resources Act 25 of 1999 Legislation Section Relates to National Heritage Resources Section 34 No person may alter or demolish any structure or part Act (No 25 of 1999) and of a structure which is older than 60 years without a regulations permit issued by the relevant provincial heritage resources authority. Section 35 No person may, without a permit issued by the responsible heritage resources authority destroy, damage, excavate, alter, deface or otherwise disturb any archaeological or paleontological site.

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Section 36 No person may, without a permit issued by the South African Heritage Resource Agency (SAHRA) or a provincial heritage resources authority destroy, damage, alter, exhume, remove from its original position or otherwise disturb any grave or burial ground older than 60 years which is situated outside a formal cemetery administered by a local authority. “Grave” is widely defined in the Act to include the contents, headstone or other marker of such a place, and any other structure on or associated with such place. Section 38 This section provides for Heritage Impact Assessments (HIAs), which are not already covered under the ECA. Where they are covered under the ECA the provincial heritage resources authorities must be notified of a proposed project and must be consulted during the HIA process. The Heritage Impact Assessment (HIA) will be approved by the authorising body of the provincial directorate of environmental affairs, which is required to take the provincial heritage resources authorities’ comments into account prior to making a decision on the HIA. Relevance to the Proposed Project, Compliance and Response: . No person may alter or demolish any structure or part of a structure, which is older than 60 years or disturb any archaeological or paleontological site or grave older than 60 years without a permit issued by the relevant provincial heritage resources authority. . No person may, without a permit issued by the responsible heritage resources authority destroy, damage, excavate, alter or deface archaeological or historically significant sites. . Cultural and palaeontological impact assessments have been included as specialist studies in the EIA and any permits required will need to be obtained from the provincial heritage authority.

Conservation of Agricultural Resources Act 43 of 1983 Legislation Section Relates to Conservation of Agricultural Prohibition and control of weeds and invader plant species Resources Act 43 of 1983 Control measures for erosion and Regulations Relevance to the Proposed Project, Compliance and Response There are no applicable permit or licence requirements, however cognisance of these requirements is to be taken during vegetation clearance and the maintenance of the existing servitudes, for the entire duration of the project lifecycle. Provision for control of invasive species and soil erosion are contained in the EMPr.

National Ports Act 12 of 2005 Legislation Relates to National Ports Act (12 of Provide for the establishment of the National Ports Authority and the Ports 2005) Regulator; to provide the administration of certain ports by the National Ports Authority; and to provide for matters connect therewith.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Prescribes that the National Ports Authority is to prepare and periodically update a Port Development Framework Plan (PDFP) for each port. The creation of new capacity in the ports’ system results from the implementation of the Port Development Framework Plans. Relevance to the Proposed Project, Compliance and Response: TNPA is required by the Act to promote economic development of the Port. Further, a balance between environmental protection and economic development must be achieved. The compatibility of the Project with Port planning is discussed in Section 6.

Occupational Health and Safety Act 85 of 1993 Legislation Section Relates to Occupational Health and Section 8 General duties of employers to their employees Safety Act 85 of 1993 and Section 9 General duties of employers and self-employed Regulations persons to persons other than their employees Relevance to the Proposed Project, Compliance and Response: The developer must be mindful of the obligations contained in the OHSA and mitigate any potential impacts. Hazardous Chemical Substances and Major Hazardous Installations are regulated under the Act. The associated requirements have been considered by the risk assessment specialist. Recommendations will be included in the EMPr.

Hazardous Substances Act 15 of 1973 Legislation Section Relates to Hazardous Substances Act Provides for the definition, classification, use, operation, modification, 15 of 1973 and regulations disposal or dumping of hazardous substances Relevance to the Proposed Project, Compliance and Response: Provision is made in the EMPr to: . Manage the hazardous substances in such a manner that it does not endanger human health or the environment.

SANS 10103 (Noise Standard) Legislation Section Relates to SANS 10103 (Noise The measurement and rating of environmental noise with respect to Regulations) annoyance and to speech communication, as well as the categories for community responses to excess environmental noise. Relevance to the Proposed Project, Compliance and Response: The ambient noise level guidelines in SANS 10103:2008 is 70dBA during the day and 60dBA at night in industrial districts. These levels can be seen as the target levels for any noise emissions within the Port and adjacent industrial area. Furthermore, the South African noise control regulations describe a disturbing noise as any noise that exceeds the ambient noise by more than 7dB. This difference is usually measured at the complainant’s location should a noise complaint arise. Therefore, if a new noise source is introduced into the environment, irrespective of the current noise levels, and the new source is louder than the existing ambient environmental noise by more than 7dB, the complainant will have a legitimate complaint. Guidelines for expected community responses to excess environmental noise is reflected in Table 5-2 below.

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Table 5-1: Categories of environmental community / group response (SANS 10103:2008). Excess Lr dB (A) Estimated Community/Group Response Category Description 0 -10 Little Sporadic complaints 5 – 15 Medium Widespread complaints 10 – 20 Strong Threats of community / group action 15 Very Strong Vigorous community / group action

Provision is made in the EMPr to manage the Noise Impacts during in the construction and operational phases.

National Road Traffic Act 93 of 1996 Legislation Section Relates to National Road Traffic Act (No Provides for controlling transport of dangerous goods, hazardous 93 of 1996) substances and general road safety Relevance to the Proposed Project, Compliance and Response: The requirements stipulated in the NRTA will need to be complied with during the construction and operational phases of the proposed project and included in the EMPr.

Gas Act 48 of 2001 Legislation Section Relates to Gas Act 48 of 2001 This Act regulates the development and operation of gas transmission, storage, distribution, liquefaction and re-gasification facilities.

No person may construct or operate gas storage facilities without a licence issued by the Gas Regulator (NERSA) except if listed in Schedule 1, in which case, registration may be required. Schedule 1 includes any person engaged in the transmission of gas for that person’s exclusive use. Registration with NERSA is also required for the importation of gas. Relevance to the Proposed Project, Compliance and Response: As Karpowership will be importing, storing and regasifying natural gas and transporting it between its ships via a pipeline, it will need to comply with the provisions of this Act by applying for the necessary licence and/or registration. These application processes do not form part of the application process for environmental authorisation and AEL.

Electricity Regulation Act 4 of 2006 Legislation Section Relates to Electricity Regulation Act 4 of The Act’s main objective is to establish a national 2006 regulatory framework for the electricity supply industry and to make the National Energy Regulator of South Africa (NERSA) the custodian and enforcer of the national electricity regulatory framework. The Act empowers the Minister of Mineral Resources and Energy, in consultation with NERSA, to:

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Legislation Section Relates to . determine that new generation capacity is needed to ensure the continued uninterrupted supply of electricity; . determine the types of energy sources from which electricity must be generated, and the percentages of electricity that must be generated from such sources; . determine that electricity thus produced may only be sold to the persons or in the manner set out in such notice; . determine that electricity thus produced must be purchased by the persons set out in such notice; . require that new generation capacity must - o be established through a tendering procedure which is fair, equitable, transparent, competitive and cost-effective; o provide for private sector participation. The Act also gives NERSA various powers to carry out its functions, including the power to consider applications for the licences required and issued under this Act. No person may operate any generation, transmission or distribution facility without a licence issued by NERSA.

Electricity Regulations on The objectives of the Regulations published under New Generation Capacity, the Act are to: 2006 . to facilitate planning for the establishment of new generation capacity; . the regulation of entry by a buyer and a seller into a power purchase agreement; . to set minimum standards or requirements for power purchase agreements; . the facilitation of the full recovery by the buyer of all costs efficiently incurred by it under or in connection with a power purchase agreement including a reasonable return based on the risks assumed by the buyer thereunder and to ensure transparency and cost reflectivity in the determination of electricity tariffs; and . the provision of a framework for implementation of an IPP procurement programme and the relevant agreements to be concluded. Integrated Resource Plan The IRP 2019 was issued by the Minister of Mineral (IRP) 2019 Resources and Energy under Notice No 1360 dated 18 October 2019 in Government Gazette 42784. The

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Legislation Section Relates to IRP is South Africa’s national electricity infrastructure plan in which the country’s energy mix is determined. Relevance to the Proposed Project: The primary enabling legislation for the Risk Mitigation IPP Procurement Programme is the Electricity Regulation Act, together with the Electricity Regulations on New Generation Capacity and the IRP 2019. Karpowership’s proposal for New Generation Capacity through its Powership projects falls under the Risk Mitigation IPP Procurement Programme.

In order to generate and transmit electricity, Karpowership will require a generation licence from NERSA. This application is separate to the application process for environmental authorisation and an AEL.

National Energy Regulator Act 40 of 2004 Legislation Section Relates to National Energy Regulator This Act establishes a single regulator to regulate the electricity, piped-gas Act 40 of 2004 and petroleum pipeline industries. The statutory body is the National Energy Regulator of South Africa (NERSA).

This Act requires NERSA inter alia to undertake the functions of the Gas Regulator as set out in section 4 of the Gas Act and the functions set out in section 4 of the Electricity Regulation Act, 2006, which includes the planning for new generation capacity and integrated resource plan. Relevance to the Proposed Project, Compliance and Response: NERSA has been identified an organ of state having jurisdiction in respect of an aspect of the activities for which the EIA process is being conducted and thus has been registered as an I&AP as required by the EIA Regulations, 2014.

Infrastructure Development Act 23 of 2014 Legislation Section Relates to Infrastructure Development . To provide for the facilitation and co-ordination of public infrastructure Act 23 of 2014 development which is of significant economic or social importance to the Republic; . to ensure that infrastructure development in the Republic is given priority in planning, approval and implementation; . to ensure that the development goals of the state are promoted through infrastructure development; . to improve the management of such infrastructure during all life-cycle phases, including planning, approval, implementation and operations; and . to provide for matters incidental thereto. Relevance to the Proposed Project, compliance and response: The Risk Mitigation IPP Procurement Programme has been designated as a Strategic Integrated Project.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Provincial legislation and planning The Project’s compatibility with provincial and conservation planning is discussed in Section 6.

Table 5-2: Applicable Provincial Plans, Strategies and Programmes Legislation Section Relates to Cape Nature and Regulation of natural conservation for the protection of biodiversity and Environmental Conservation natural resources Ordinance (19 of 1974) Western Cape Biosphere Facilitation of the designation and management of biosphere reserves Reserves Act (6 of 2011) through framework plans Western Cape Land Use Provides for Provincial planning, regional planning and development. Planning Act (2015) Urban and rural development, regulation. Support and monitoring of municipal planning and regulation. Western Cape Estuarine Provides for guidance in terms of physical structures built in the littoral Management Framework active zone, managing erosion and accretion in estuaries, erosion and Implementation Strategy protection, bank stabilisation and management of due environments. (“WCEMFIS”): Best Practice Activity Guidelines (October 2019 Western Cape Provincial Framework for Western Cape province’s urban and rural areas, supporting Spatial Development the municipalities planning mandate aligned to the national and Provincial Framework (2014) agendas West Coast National Park To effectively manage the patterns and processes of the unique Management Plan ecosystems of the Langebaan Lagoon, the offshore islands, the Marine (SANParks, 2013) Protected Areas and the terrestrial surrounds”. Province of the Western The measurement and rating of disturbing noise with respect to the end of Cape: Provincial Gazette a total period of at least 10 minutes, after such meter had been put into Extraordinary 7141 – operation. Western Cape Noise Control Regulations - PN 200/2013 (20th June 2013). Western Cape Climate The Western Cape Climate Response Strategy acts as a provincial level Response Strategy (2014) strategy modelled on the NCCRP. The strategy sets out the priorities for the Western Cape with regards to climate change adaptation and mitigation. Western Cape Biodiversity This spatial tool comprises the Biodiversity Spatial Plan Map (BSP Map) Spatial Plan (2017) of biodiversity priority areas, accompanied by contextual information and land use guidelines that make the most recent and best quality biodiversity information available for land use and development planning, environmental assessment and regulation, and natural resource management. The BSP Map covers both the terrestrial and freshwater realms, as well as major coastal and estuarine habitats.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Local legislation and planning The Project’s compatibility with regional and local municipal and conservation planning is discussed in Section 6.

Table 5-3: Applicable Legislation – Regional and Local Planning Frameworks Legislation Section Relates to Saldanha Local Area Plan Acts as a medium to long term spatial plan (15-20 years) for the town of (2014) (SSC WC Q 60/2013 Saldanha, providing for decision-making in terms of future land use DRDLR) applications and spatial interventions Saldanha Bay Municipality Provides for informed spatially related management decisions for future Volume 2: Spatial growth, development and management of the Saldanha Bay Municipal Development Framework Area. Report (28 May 2019) Draft Environmental The Environmental Management Framework for the Saldanha Bay Management Framework for Municipality outlining Status Quo, Strategic Assessment and Strategic the Greater Saldanha Area Environmental Management Plan. (2017) 4th Generation Integrated Provides for guidance to municipal planning, budgeting and development Development Plan 2017 – in support of sustainable development 2022 Saldanha Bay Municipal The CMP is deemed to be a tool which should be used to manage the Coastal Management diverse range of activities that occur in the coastal zone, without Programme (2019) compromising environmental integrity or economic development (SBM, 2019). Saldanha Bay Solid Waste Disposal of solid waste. Disposal By-law

INTERNATIONAL AGREEMENTS South Africa is a party to a number of international agreements which regulate shipping as well as the protection of marine resources:

 International Convention for the Prevention of Pollution from Ships - MARPOL 73/78 o The MARPOL Convention regulates pollution from ships – accidental pollution and pollution from the general operations associated with shipping; Preserves the marine environment by eliminating pollution from harmful substances. Ships sailing under the flag of a country that has entered into the MARPOL convention are expected to comply with the regulations. The MARPOL Convention was ratified by South Africa in 1985.  Convention on Biological Diversity - 1992-1995  International Convention on Civil Liability for Oil Pollution  Damage - 1969-1997  International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Casualties - 1969-1986  Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (London Convention) - 1972-1978

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

 Protocol to the 1972 Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter - 1996-1998  United Nations Convention on the Law of the Sea (UNCLOS) - 1982-1997  Protocol relating to intervention on the high seas in cases of pollution by substances other than oil - 1973-1997  International Convention for the Safety of Life at Sea - 1974-1980  Convention on the Conservation of Migratory Species of Wild Animals  Agreement on the Conservation of African-Eurasian Migratory Waterbirds, or African-Eurasian Waterbird Agreement (AEWA)  Framework Convention on Climate Change  Paris Agreement

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

6 MOTIVATION, NEED AND DESIRABILITY

2014 EIA Regulations (as amended), Appendix 3 (1) (f) a motivation for the need and desirability for the proposed development, including the need and desirability of the activity in the context of the preferred development footprint within the approved site as contemplated in the accepted scoping report; (g) a motivation for the preferred development footprint within the approved site as contemplated in the accepted scoping report;

PROPOSED DEVELOPMENT This section contextualises the strategic planning context within which the Project is being proposed.

South African legislation, including the Constitution and NEMA, entrenches the principle of sustainable development as do the various National strategies, policies, programmes and plans, including the National Development Plan 2030 (NDP). The motivation for the need and desirability motivation for the proposed Project thus needs to be assessed within the context of these strategies, policies, programmes and plans by specifically looking at whether the proposed project is ecologically sustainable and socially and economically justifiable.

STRATEGIC OVERVIEW

The United Nations Sustainable Development Goals (SDGs) or Global Goals were adopted by all member states of the United Nations in 2015 in the commitment to end poverty, protect the planet and ensure peace and prosperity for all people by 2030. South Africa was one of these nations.

The provision of electricity falls under the SDG 7: Affordable and Clean Energy. Notably, the goals are integrated and an improvement in one area affects the outcome of the other SDG areas. For example, an improvement in SDG 7: Affordable and Clean Energy is likely to lead to an improvement in the other SDGs such as: 1 (No Poverty); 3 (Good Health and Well-Being); (8 (Decent Work and Economic Growth); 9 (Industry, Innovation and Infrastructure); 11 (Sustainable Cities and Communities) and 13 (Climate Action).

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 6-1: United Nations Sustainable Development Goals (Source: UN General Assembly, 21 October 2015)

Environmental The principles outlined in the National Environmental Management Act 107 of 1998 (NEMA) must be applied to all decision-making that may affect the environment and its biodiversity. The first two principles in Section 2 of NEMA are that, “environmental management must place people and their needs at the forefront of its concern, and serve their physical, psychological, developmental, cultural and social interests equitably” and “[development must be socially, environmentally and economically sustainable”.

Given the integrative nature of sustainability, the requirement for and provision of reliable energy will cross cut various environmental, social and economic goals. Various specialist environmental studies are being commissioned to identify the potential environmental impacts of the proposed project on life below water, life on land and climate change in order to establish required mitigation in terms of alternatives and other mitigation measures during the EIA phase. Preliminary findings indicate that: . GHG emissions, due to the use of natural gas rather than LPG as energy source, are low; . Marine environment impacts such as physical disturbance of the littoral zone, increased seawater temperatures and modifications to the hosted biological communities may occur. However, gas pipeline design and construction as well as mitigations for e.g. temperature increases as per maritime engineering may be effected within coastal temperature discharge standards thereby reducing impacts; . Risk management can be applied to limit air quality or maritime related incidents; . Life on land impacts e.g. vegetation clearance, aquatic and wetlands are within the limits of acceptable change as the relatively short distance (less than 10km) 132KV transmission line is the only aspect of the project to have a terrestrial impact. The Karpowership with its relatively small footprint will be moored in the port and have no significant footprint typically associated with power stations or solar power plants. . Abstraction for cooling purposes will be from the coastal waters with an abundant supply being available in the Port. Fresh water resource allocation, protection of the reserve as well as concerns related to water scarcity, usually associated with land-based power stations, will therefore not be a concern. . Waste management impacts to the marine environment from black and grey water can be avoided in accordance with the MARPOL requirements.

The concept of generating power on the ocean has several benefits over land-based power plants, including a small footprint (e.g. the same amount of output can be achieved in a much smaller area compared to land based power plants), significantly shorter timeframes for project delivery / adding capacity, as the Powership arrive already assembled and ready-to-operate, and land-based impacts are limited and of short term, associated with the establishment of the transmission line and the temporary assembly area for the gas pipeline.

More detail of each of these environmental factors is provided in the relevant draft EIA report sections, namely the project scope alternatives (Section 3), baseline environment section (Section 4) as well as impact assessment (Section 8).

These impacts also need to be considered together with the socio-economic-context i.e. the need to improve the economy and job creation, sustaining businesses and industry within a constrained energy sector and ensuring

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. energy provision for a growing population where many is still disadvantaged and have to making a living without energy. The proposed project is likely to have a significant socio-economically benefit locally, provincially and nationally based on the proposed capacity to be generated and supplied to the grid network, as expanded in the following sections.

The environmental as well as socio-economic impacts will be assessed in more detail in the EIA phase.

Socio-economic The importance of energy for socio-economic benefit is well documented as early as 2012- The Draft 2012 Integrated Energy Planning Report: Executive Summary (IEPR) stated that “energy access is now widely recognised as a prerequisite for human development”. The Draft 2012 Integrated Energy Planning Report: Executive Summary (IEPR) states that “energy access is now widely recognised as a prerequisite for human development”. The access to electricity is outlined within the Municipal Services Act 32 of 2000, giving priority to the provision of basic needs to the local community that is “conducive to the prudent, economic, efficient and effective use of available resources”. NEMA supports this through the principle of “equitable access to environmental resources, benefits and services to meet basic human needs and ensure human well-being must be pursued and special measures may be taken to ensure access thereto by categories of persons disadvantaged by unfair discrimination”, as would be the case for facilities and citizens unable to afford the more expensive countermeasures to stable electricity supply throughout load shedding.

According to the National Development Plan (NDP) (2030), Government is committed to ensure economic growth and development through adequate provision of sustained energy services that are competitively priced, reliable and efficient. This must be ensured to promote sustainable development and to ensure that the living standard of South African citizens is maintained and improved.

South Africa has experienced a progressively worsening energy crisis from 2007 that has resulted in numerous load shedding events including Level 6 load shedding. Eskom, which provides over 90% of power generating capacity in South Africa (Donnelly, 2018; Mthethwa, 2019; Gosling, 2019; Cohen & Vecchiatto, 2019), has been unable to meet the demands of both the private and public sector. The load shedding measures which were implemented to prevent a total blackout has had dire effects on the South African Economy according to Goldberg, 2015 and Makinana, 2019. Load shedding reduced the South African GDP by roughly 0.30% in 2019, which translates to 8.5 billion of real, inflation-adjusted Rand (Writer, 2019).

Government interventions of introducing additional power stations, generators and even tariff increases have proved to be inefficient in terms of addressing the country’s electricity shortages. The Integrated Resource Plan (IRP) 2019 stressed a short-term gap in supply to be anticipated between 2019 and 2022 due to the time expected for the new power stations (Medupi and Kusile) and the Renewable Energy Independent Power Producer Procurement Programme (REIPPPP) to come online. This may further be delayed by the poor design and planning of the Medupi and Kusile plants and the delayed correction thereof (Hosken, 2020). The IRP specified the need for new energy efficient technology and the diversification of both the supply and nature of energy production to reduce pollution and minimise impacts related to climate change.

The CSIR (Setting up for the 2020s: Addressing South Africa’s electricity crisis and getting ready for the next decade, 2020) further predicts that load shedding can be expected for the next 2 – 3 years and that an urgent response is required to ensure reliable short-term energy supply. Page 89

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 6-2: Extract from the CSIR Report (Setting up for the 2020s: Addressing South Africa’s electricity crisis and getting ready for the next decade, 2020)

The Minister of Mineral Resources and Energy published regulations to help address South Africa’s ongoing power issues (Staff Writer, 2020 (b)). In addition, the National Development Plan (2030) outlined the need to move the electricity system from Eskom to an independent system and for accelerated procurement of independent power producers on a wide range of alternatives, moving away from the unsustainable use of coal as fuel resource.

The proposed Project, is aligned with National Government initiatives e.g. the “RFI Response Risk Mitigation Power Procurement Programme” and Request for Proposal (RFP) which aims to alleviate the immediate and future capacity deficit as well as the limited, unreliable and poorly diversified provision of power generating technology with its adverse environmental and economic impacts. The RFP stipulated stringent environmental, social and economic criteria inclusive of e.g.: . the shift from coal and LPG to NG as a cleaner and more cost effective resource; . BBBEE criteria; . Skills development.

Karpowership, in submitting applications in terms of the IPP initiatives will comply with sustainable development criteria as these applications are compiled with input from various Government Departments that need to ensure compliance with the Constitution and NEMA principles and meet the country’s international obligations.

According to Karpowership, projects will meet and exceed Economic Development qualification criteria stipulated within the RMIPPPP RFP. Karpowership will engage with local businesses and award contracts to local service providers for maintenance aspects as well as waste management, food and other daily consumables. They take pride in their positive impact on local communities through both social responsibility programs, tailored to the specific needs of the community, and the career opportunities that are provided.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Karpowership projects create significant direct and indirect employment, driving knowledge and skills transfer across a broad spectrum of disciplines including some that are unique to floating power plants. Karpowership also emphasizes youth development as the future of our business, industry, and the local economy. As a globally recognized leader with 1,800+ direct employees, they provide an opportunity for South Africans, which will make up the majority of their personnel, to develop specific skills and knowhow which will ultimately benefit the South African economy. They will also be provided with the opportunity to become part of an internationally diverse team, gaining and sharing experience and knowledge either locally or worldwide alongside industry leading colleagues.

There will be a significant number of local employees for both the construction and operation period which will exceed the Economic Development criteria that must be reached under the terms of the RMIPPPP. They also believe that the job creation, including within the power generation function, will be comparatively more than a renewable energy project should the project be selected to proceed. Detailed job creation and other local economic development activities will be provided at preferred bidder stage during EIA preparation.

The project will be creating negative direct, secondary and cumulative impacts on the local communities, specifically areas surrounding the site where the proposed facility is to be built. The main factors that will cause this negative impact are (1) the influx of workers and job seekers from outside of the local community, (2) the impact on the surrounding economic and social infrastructure and (3) the limited visual and noise disturbances that could be created by the construction activities as the footprint of the facility grows.Potential negative impacts can largely be mitigated, and their significance reduced.

The project is anticipated to make a notable contribution towards the national and local economy. It is estimated that a total of R154.7 million of new business sales, R324.3 million of GDP and 1 525 FTE employment positions will be generated by the project in the national economy through multiplier effects. Aside from the above positive effects, the project will contribute to skills development in the country, increase government revenue, as well as raising household earnings. The increase in household earnings is also likely to improve the standards of living of the affected households albeit temporarily.

The operation of the proposed Powership and their associated infrastructure will generate R88.6 million of new business sales, contribute R254.9.0 million to GDP and create 240 sustainable FTE employment positions. In addition, government revenue will rise, electricity supply will be increased, and various socio-economic and enterprise development initiatives will be undertaken from the revenue generated by the development. These funds will be allocated towards socio-economic development in the area and are expected to bring a significant benefit to local communities.

NEW GENERATION CAPACITIY AND RISK MITIGATION IPP PROCUREMENT PROGRAMME

The Department of Mineral Resources and Energy (DMRE) issued the Request for Proposals (RFP) to procure new energy generation capacity as per Government Notice 753 (7 July 2020): Determination Under Section 34(1) of the Electricity Regulation Act, 2006 (Act No. 4 of 2006) wherein the Minister, in consultation with the National Energy Regulator of South Africa (NERSA) has determined “that new generation capacity is needed to be procured to contribute towards energy security” and “the electricity must be purchased from independent power producers”.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

The Risk Mitigation Independent Power Producer (IPP) Procurement Programme has been identified by the DMRE as the appropriate programme to procure the new generation capacity designated in the above Determination. As such, a call for proposals to IPPs was published by DMRE “to ensure the establishment of this new generation capacity through the Risk Mitigation IPP Procurement Programme:  The Risk Mitigation IPP Procurement Programme has been designed to procure the target of 2000 MWs of new generation capacity to be derived from different types of dispatchable power generation projects that will enter into public-private agreements with Eskom to provide new generation capacity in compliance with the Performance Requirements, among other things.  The dispatchable power generation projects may utilise fuel to produce the energy output and may be comprised of more than one facility and project Site.  Furthermore, the selected projects will contribute towards socio-economic development and sustainable economic growth, while enabling and stimulating the participation of independent power producers in the electricity supply industry in South Africa.”

The updated Integrated Resource Plan (IRP) 2019 was developed as a “co-ordinated schedule for generation expansion and demand-side intervention programmes, taking into consideration multiple criteria to meet electricity demand”. The IRP is a plan for infrastructure development based on a least supply and demand balance approach, taking into account security of supply and minimising negative emissions and water usage impacts on the environment. It has been developed within a context characterised by changes in energy technologies and their associated uncertainty of the impact on the future energy provision system. With this uncertainty expected to continue, a cautionary approach must be adopted when making assumptions and committing for the future in this rapidly changing environment. As such, long-term commitments are to be avoided as much as possible, to eliminate the risk that they might prove costly and ill-advised (IRP, 2019).

The decommissioning of the existing coal fleet (due to end of design life) can provide space for a relatively different energy mix. It must be noted that, in the period preceding 2030, the system requirements are largely for incremental capacity addition (modular) and flexible technology, to complement the existing installed inflexible capacity (IRP, 2019). This is essentially what a system like the Karpowership fleet can provide, ship-based power generating and transmission of energy to land-based transmission connection points. This capacity can be modularly up-scaled on site with a very short lead time to meet additional requirements, should these be required at a later stage. The RFP limits the project proposal to a delivered capacity of 450MW at the power station. The best suited configuration of the Powership generates an output of 415MW.

Also of particular importance is securing energy security by developing adequate electricity generation capacity to meet our demand under both the low-growth economic environment as well once the economy improves to the level of 4% growth per annum. Electricity generation capacity must therefore be paced to restore the necessary reserve margin and to be ahead of the economic growth curve at least possible cost (IRP, 2019).

One concern and risk raised during the August 2018 public participation process undertaken for the IRP 2019 update, was related to the capacity provided for and practicality of gas to power and the risks it poses since South Africa does not currently have adequate gas infrastructure. The Karpowership generation process proposes the use of internationally sourced LNG gas supply that will be transported via a LNG carrier to the proposed FSRU location. A gas line will be established between the FSRU and Powership to provide a secured supply of natural

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. gas. No gas supply is required from local South Africa resources to ensure efficient operations and all other infrastructure will be supplied.

ESKOM POWER RELIABILITY AND GOVERNMENT’S RESPONSE TO THE ENERGY DEMAND

Eskom’s existing generation plant Energy Availability Factor (EAF) was assumed to be averaging 86% in the promulgated IRP 2010–2030. The actual EAF at the time (2010) was averaging 85%. Since then, Eskom’s EAF declined steadily to a low average of 71% in the 2015/16 financial year before recovering to average around 77% in the 2016/17 financial year. Information as at January 2018 indicated that EAF had regressed further to levels below 70%. This low EAF was the reason for constrained capacity early in December 2018 and January 2019 that resulted in load shedding (IRP, 2019).

Additionally, the IRP (2019) states that there are a number of Eskom coal plants that will reach end of design life from year 2019 and that most of the Eskom plants were designed and constructed for operation for 50 years. Eskom had also submitted a revised plant end of design life (decommissioning) plan. This submission brings forward the shutdown of some units at Grootvlei, Komati and Hendrina. The IRP (2019) showed that approximately 5 400 MW of electricity from coal generation by Eskom will be decommissioned by year 2022, increasing to 10 500 MW by 2030 and 35 000 MW by 2050. The socio economic impact of the decommissioning of these Eskom plants were not quantified or included in the IRP.

A number of Eskom power plants (Majuba, Tutuka, Duvha, Matla, Kriel and Grootvlei) have been retrofitted with emission abatement technology to ensure compliance with the law (IRP, 2019). In 2014 Eskom applied for postponement of the date for compliance and permission in this regard was granted for a period not exceeding 5 years. According to the IRP (2019), Grootvlei was the only station that has been brought to compliance and failure to undertake abatement retrofits is likely to result in non-compliant plants. Eskom has been known to apply to postpone compliance with the minimum emissions standards for air pollution. With multiple additional postponement application for the majority of their powerstations during 2020. Eskom has stated that it will apply for rolling postponement rather than trying to meet the sulphur dioxide standards. Should these not be issued, Eskom maybe required to expedite plans to decommission old polluting stations that cannot meet the MES with potential dire consequences for secured energy supply.

Simulations used to update the IRP (2019) show that there is an immediate risk of energy shortage in the immediate term. Eskom’s early shutdown of non-performing units (Grootvlei, Komati and Hendrina), coupled with the non- compliance status of some plants and the de-rating of Medupi and Kusile to below name-plate rating result in an immediate risk of huge power shortages. The recently experienced load shedding as well frequent alerts of possible shortages corroborate the observations from the power system simulations.

Industrialisation of South Africa has led to increased demand for electricity by an ever-growing population from a strained power service operated by, Eskom. This has led to a number of power shortfalls throughout the country, as supply cannot meet demand. The power shortfalls and the unreliable electricity generation has had major impact on the South African economy (Goldberg, 2015; Makinana, 2019). Furthermore, certain temporary and permanent shut downs of power plants across the country have come with serious impacts to energy supply. These shutdowns directly impact the energy supply to the host community thus directly impact the local economy. This has generated

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. the need for a diversified/ innovative power supply. This is based on national policy and informed by ongoing planning undertaken by the Department of Energy (DoE) and the National Energy Regulator of South Africa.

The National Development Plan 2030 has outlined access to electricity as one of the “Elements of a Decent Standard of Living”. South Africa has faced significant electricity shortages over a number of years and the escalating electricity crises experienced since 2007 has significantly impacted the standard of living of its citizens and resulted in ruinous economic losses.

In order to achieve sustainable and inclusive growth by 2030, South Africa needs to invest in a strong network of economic infrastructure to support the country’s medium and long term objectives according to the National Development Plan (NDP) 2030.

The vision of the NDP includes the promotion of economic growth and development though adequate provision of quality energy services that are competitively priced, reliable and efficient. Addressing access to energy will promote sustainable development, encourage economic competition and ensure that living standards are maintained and improved. According to the Integrated Resource Plan 2019, the Minister of Energy determined that 39,730 MW of new generation capacity must be developed. Currently 18,000 MW of the required 39,730 MW has been committed to as follows: . 6,422 MW new capacity under the REIPPP with a total of 3,876 MW operational on the grid; . 4,514 MW Eskom build with remaining planned build of 6,418 MW; . 100 MW of Sere Wind Farm; and . 1,005 MW from OCGT for peaking.

A key component of the 20 year master-plan is the requirement for new energy generating capacity from a range of technologies like renewables and natural gas. Alternative sources of power generation allow countries to move away from open cycle gas turbines (OCGTs) (South Africa’s- Eskom situation), and use of expensive diesel to generate electricity during peak demand (Siyobi, 2015).

The use of natural gas from LNG in power generation provides a cleaner alternative to coal and other fossil fuels, reducing carbon and other emissions such as SO2 and PM10, resulting in both immediate and long-term benefits for public health and the environment. LNG shipments allow the environmental benefits of natural gas to be spread around the world and can help reduce global greenhouse gas emissions according to a report by PACE Global LNG and Coal Life Cycle Assessment of Greenhouse Gas Emissions. The ability to burn natural gas for power generation is an ideal complement to renewable energy generation, like wind and solar power, which can be intermittent and inconsistent in their output. Natural gas power plants can be quickly turned on and off or ramped up and down to help provide consistent electricity production when solar or wind resources fluctuate.

As part of his 2020 State of the Nation Address on 13 February 2020, the President announced that government would implement measures to “rapidly and significantly increase generation capacity outside of Eskom”. Established measures include the Section 34 Ministerial Determination that supports the Integrated Resource Plan 2019, which facilitates additional energy generation to the national grid through renewable energy, natural gas, hydro power, battery storage and coal.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

The Emergency/Risk Mitigation Power Purchase Procurement Program (2000 MW) (ERMPPPP) has been declared a Strategic Integrated Project (SIP) under the Infrastructure Development Act, 2014 under SIP 20. One of the objects of this Act is “the identification and implementation of strategic integrated projects which are of significant economic or social importance to the Republic or a region in the Republic or which facilitate regional economic integration on the African continent, thereby giving effect to the national infrastructure plan”.

South Africa’s electricity generation capacity shortfall can only be solved by additional generating capacity. Although additional power stations are under construction, there is a lengthy gap of time between the present shortage and the commissioning of all units of these new power stations. In the meantime, the economy suffers from the reduction of productivity and increased costs resulting from power interruptions caused by equipment failure (so-called unplanned maintenance) and load shedding.

Access to cost-effective temporary base-load generation of a significant magnitude will help to solve the problem by supplying the power to meet the load which is often being shed or reduced at present. Reliable power generation facilities are required to address both the immediate power shortfalls, as well as the longer term increasing demand for electricity. Powership can deliver electricity in a very short timeframes as the normal delays associated with land-based power plants construction are negated as these Powership have been purpose built prior to deployment.

As per the President’s speech at the 2021 State of the Nation Address on 11 February 2021, in December 2020, government and its social partners signed the historic Eskom Social Compact, which outlines the necessary actions to be taken collectively and as individual constituencies, to meet the country’s energy needs now and into the future. Government have taken action to urgently and substantially increase generation capacity in addition to what Eskom generates. The following actions were highlighted as per the President’s address:

The Department of Mineral Resources and Energy is expected to announce the successful bids for 2,000 megawatts of emergency power within the first quarter of 2021.

Government will soon be initiating the procurement of an additional 11,800 megawatts of power from renewable energy, natural gas, battery storage and coal in line with the Integrated Resource Plan 2019.Despite this work, Eskom estimates that, without additional capacity, there will be an electricity supply shortfall of between 4,000 and 6,000 megawatts over the next 5 years, as old coal-fired power stations reach their end of life”.

ECONOMIC RECOVERY AND ENERGY REQUIREMENTS

Sustainable energy provision is also key to ensuring economic recovery. The CSIR reported that in 2019 load shedding reduced the South African economy by between R 60 billion to R 120 billion (Wright and Callitz, 2020). There are estimations that the overall economic loss to the South African economy over the last 10 years is as high as R 338 billion. Energy analysts have determined that every hour of every stage of load shedding costs the economy R 50 million to R 100 million (Hosken, 2020). Energy analysts predict that load-shedding will have a greater detrimental impact to South Africa’s failing economy and may drive many businesses into bankruptcy and reduce investment into the country (Hosken, 2020).

IMPORTANCE OF NATIONAL & PROVINCIAL COLLABORATION AND PRIVATE PARTNERSHIPS Page 95

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

The planned economic recovery for the Country will be impossible in the absence of a reliable and adequate power supply to the economic sectors. Therefore, the success of one province impacts on the success of other provinces. The establishment of reliable power in one province has a domino effect on other provinces.

PORT PLANNING

Transnet have been actively involved over an extended period of time with the identification of gas to energy options to be established within the Ports e.g. “Transnet preparations for gas infrastructure in South Africa” as part of the South Africa Gas Options Conference held on September 2015 in Cape Town.

The short (2019-2028), medium (2029-2048) and long-term (beyond 2048) Port Development Framework Plans (PDFPs) for the Port of Saldanha Bay in terms of the National Ports Plan 2019 was considered. A summary of relevant foreseen changes are listed below:  Short-term: - New liquid Bulk storage areas. These areas are located within the port limits and within the new proposed ports limits. The total area of the proposed liquid bulk is 197 ha; - LNG gas to power FSRU structure connected to the new LNG facilities; and - Expansion of the commercial logistics area (Port Logistics Park) to 17 ha;  Medium- term: - Land reclamation next to the current iron ore stockyard for the construction of new LNG facilities (long term) / increase of iron ore stockpile area; and - LNG gas to power FSRU structure connected to the new LNG facilities  Long-term: - New proposed land-based LNG storage area inside the port limits.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Figure 6-3 Port of Saldanha Bay short-term layout

The project proposal, having been independently assessed by PRDW in relation to the proposed Port Plans, is aligned with the Transnet studies and plans.

SEZ PLANNING

The Saldanha Bay Industrial Development Zone (SBIDZ) is bringing in investment worth US$18.3m (Mtezuka, 2020). These investment projects are anticipated to increase job creation and bolster the local economy. The SBIDZ has implemented a “Project Leasing Facility” to facilitate government energy projects which can be completed in less than 24 months. The proposed Powership project requires no construction, however the transmission line connecting the Powership to the national grid would require construction that would be completed well within 24 months. The “Project Leasing Facility” would assist the Transnet National Ports Authority (TNPA) with storage space aiding in provision of renewable energy independent power producer programme (REIPPP). As outlined in the SBIDZ Corporate Plan 2019/ 2020 the area of gas to energy is to be focused on, especially in the development of skills and job creation within this sector. The gas to power Powership project enables for the creation of jobs and development of skills in this sector. The Applicant has committed to prioritising employment of local people wherever possible, as well as developing local skills to make it possible in cases where those skills do not exist in the local workforce.

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PROVINCIAL PLANNING

Western Cape Provincial Spatial Development Framework The Provincial Spatial Development Framework of Western Cape supports the National Development Plan’s spatial agenda and supports the Provincial Strategic Objectives. The National Development Plan 1.4.1.2 Improving Infrastructure, speaks of diversifying the energy mix, incorporating liquid natural gas and renewables. The proposed Powership project for Saldanha feeds into this strategy. One of the significant target areas within the Western Cape Economic sector is Gas - new LNG terminal facilities in Mossel Bay and between Saldanha Bay and Cape Town, associated gas power stations, and conversion of nearby industrial areas. The proposed Powership will be powered by Liquid Natural Gas (LNG), based in Saldanha Bay and feeding power to the surrounding industrialised areas.

The 2013 Western Cape Infrastructure Framework (WCIF) promotes innovative methods for infrastructure to meet the growing demand. In particular for the energy systems, “Aligning energy generation infrastructure with point of gas import (i.e. Saldanha Bay and Mossel Bay)” and “Procure land for a gas-based energy system, including liquid natural gas (LNG) port facilities, gas plants (3 envisaged), and gas pipelines”.

MUNICIPAL PLANNING

Saldanha Bay Municipal Spatial Development Framework According to the Saldanha Bay Municipal Spatial Development Framework – Spatial Analysis, there is additional demand for electricity projected for Saldanha Bay and the IDC area. With new industry coming in to the area, it is projected that this demand will continue to grow. The Municipal Spatial Development Strategy underlines that “Critical to any growth management strategy will be the timeous provision of bulk infrastructure capacity (water, sewerage, electricity) in the identified growth areas, to address both existing capacity backlogs and the supply of additional capacity to provide for growth”. From this 6 key strategies were developed. (iv) Bulk Service Infrastructure Provision Strategy: Compile a co-ordinated bulk infrastructure supply provision policy which prioritises the implementation of bulk infrastructure based on the municipal spatial development concept / Growth Management Framework. The Powership project is in direct support of Strategy 4.

Saldanha Bay Municipality 4th Generation Integrated Development Plan The Integrated Development Plan (IDP) 2017 – 2022 forms the strategic framework guiding planning within the municipality. An analysis of the energy grid within the municipality has identified that a concern of note is the Eskom owned Duferco substation (based within the Saldanha Port) which has a availability of supply capacity that has not been utilised which may be a limiting factor if not capitalized on. During the 2016 Risk Assessment disruptions in electricity supply was noted as an area of risk and major concern.

Strategic Objective 4 of the Saldanha Bay IDP is “to maintain and expand basic infrastructure as a catalyst for economic development”. This is proposed to be achieved through provision of a quality electricity supply, managing demand and maintaining existing infrastructure. The proposed Powership project allows for the reliable supply of power facilitating economic growth and allowing for job creation in a struggling economy.

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Saldanha Local Area Plan The vision for the Local Area Plan (LAP) is for Saldanha Bay Municipality to be a modern, integrated, clean and model town with satisfied and happy citizens. As outlined in the LAP and in the Port Development Framework Plans (2014) plans to expand the port and its current activities are afoot. The proposed Powership project would directly support this by facilitating the expansion through provision of power.

THE ACTIVITY IN THE CONTEXT OF THE PREFERRED DEVELOPMENT FOOTPRINT WITHIN THE APPROVED SITE

Location and Land Use Suitability Being a ship-based power generating operation (as opposed to land-based) with transmission of energy to land- based transmission connection points, the location within the Port of Saldanha, which is adjacent to the Saldanha Industrial Development Zone, is suited for the importation of LNG as fuel source, the generation of power and the evacuation either to the Aurora-Saldanha Steel Network or to the Blouwater substation situated within Saldanha Bay.

Port Traffic, Navigational Requirements and Extent of Marine Based Infrastructure The Port provide adequate footprint for the mooring of the Powership and the FSRU and provides adequate clearance for the delivery of LNG via LNG Carriers.

The gas pipeline to transfer natural gas from the FSRU to the Powership can be accommodated along the breakwater and overland, minimising potential marine impacts.

Environmental Sensitivities

Numerous independent specialist studies were conducted to assess the potential impact on the environmental and socio-economic aspects related to the proposed gas to Powership project. The alternatives presented in Section 3 of this report have considered environmental, engineering and socio-economic factors. No fatal flaws were identified during the Specialist assessments and EIA process.

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7 PUBLIC PARTICIPATION PROCESS

2014 EIA Regulations (as amended), Appendix 3 (1) (h) (ii) details of the public participation process undertaken in terms of regulation 41 of the Regulations, including copies of the supporting documents and inputs; (iii) a summary of the issues raised by interested and affected parties, and an indication of the manner in which the issues were incorporated, or the reasons for not including them.

PRE-APPLICATION CONSULTATION A virtual pre-application meeting was held with DEFF on 17th September 2020 via Microsoft Teams. A public participation plan was subsequently approved by DEFF according to which the public participation process was conducted. Other points discussed in the meeting and addressed in the report include assessing the compatibility of the proposed project with Port’s planning, assessing cumulative impacts (to be further assessed during the next phase of the application process), and the involvement of the DEFF Air Quality Branch. The assessment of the decommissioning phase will be included in the next EIR phase. The minutes of the pre-application meeting have been included in Appendix D12.

REGISTERED INTERESTED AND AFFECTED PARTIES A proponent or applicant must ensure the opening and maintenance of a register of interested and affected parties and submit such a register to the competent authority, which register must contain the names, contact details and addresses of— (a) all persons who, as a consequence of the public participation process conducted in respect of that application, have submitted written comments or attended meetings with the proponent, applicant or EAP; (b) all persons who have requested the proponent or applicant, in writing, for their names to be placed on the register; and (c) all organs of state which have jurisdiction in respect of the activity to which the application relates.

An I&AP register was opened at the onset of the Scoping Phase and has been maintained to date. A copy of the database reflecting details captured up to the end of the Scoping phase is included in Appendix D7, although contact details of private persons have been omitted in interests of privacy. The register will continue to be updated on an ongoing basis during the EIA process. A complete version of the I&AP register will be submitted with the final EIA Report to DEFF.

LANDOWNER NOTIFICATION The properties that are directly affected by the proposed development are listed in Table 2-6. The details of the affected landowners are included in the IAP database. Although there are deviations from the Scoping Phase, the changes occur within the properties previously identified and landowner consents have been obtained.

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Properties Landowner CENTRAL GPS-COORDINATE Longitude Latitude Portion 2 of Farm Uyekraal 189 C04600000000018900000 32° 58' 54.2424'' S 18° 2' 54.4344'' E Remaining Extent of the Farm 196 Transnet Ltd 33° 0' 9.1224'' S 18° 0' 16.0632'' E Portion 8 of the Farm Pienaars Poort Transnet Ltd 32° 59' 48.1632'' S 17° 59' 59.0172'' E Portion 15 of the Farm Pienaars Poort Transnet Ltd 32° 59' 49.722'' S 17° 59' 41.262'' E Portion 2 of the Farm 1112 Duferco Steel Processing 32° 58' 41.088'' S 18° 0' 29.5884'' E Pty Ltd Remaining Extent of the Farm 1132 Saldanha Steel Pty Ltd 32° 58' 51.996'' S 18° 1' 19.1892'' E Remaining Extent of the Farm 1139 Afrisam South Africa Pty 32° 58' 59.5524'' S 17° 59' 48.6492'' E Ltd Portion 1 of the Farm 1139 Transnet Ltd 32° 59' 28.6872'' S 17° 59' 50.9208'' E The Farm 1185 Transnet Ltd 33° 0' 36.7956'' S 17° 59' 57.7644'' E Erf 11945 Saldanha Transnet Ltd 32° 59' 27.8988'' S 18° 2' 12.3288'' E Portion 17 (a portion of portion 13) of Transnet Ltd 32° 59' 27.8988'' S 18° 0' 7.7976'' E the Farm Yzervarkensrug 127 Remaining Extent of the Farm Arcelormittal South Africa 32° 58' 33.3084'' S 18° 0' 58.8492'' E Yzervarkensrug 129 Ltd Remaining extent of Portion 3 of the Transnet Ltd 32° 58' 17.8968'' S 18° 2' 12.3288'' E Farm Yzervarkensrug Portion 7 of the Farm Yzervarkfontein Transnet Ltd 32° 58' 33.3084'' S 18° 0' 58.8492'' E 129

According to regulation 39(1) of GN No. R. 982 of 4 December 2014 (as amended), if the proponent is not the owner or person in control of the land on which the activity is to be undertaken, the proponent must, before applying for an environmental authorisation in respect of such activity, obtain the written consent of the landowner or person in control of the land to undertake such activity on that land. This requirement does not apply inter alia for linear developments (e.g. pipelines, power lines, roads) or if it is a SIP as contemplated in the Infrastructure Development Act, 2014.

Please refer to correspondence received from DEFF IQ dated.

NOTIFICATION OF INTERESTED AND AFFECTED PARTIES – SCOPING PHASE Site Notification (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 or proposed application relates is or is to be undertaken; and (ii) any alternative site;

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A total of three A2 site notices in English and Afrikaans were strategically placed along the proposed transmission line route in Saldanha Bay. Photographic evidence of the site notice placements including the coordinates is provided below in Appendix D4. In addition, in an effort to notify I&APs in the surrounding community, A5 flyers were placed at the following locations: . Club Mykonos, Langebaan; . Pienaar brothers at Trisano Centre, Saldanha Bay; . Protea hotel, Saldanha Bay; and . Blue Bay Lodge and Resort, Saldanha Bay.

(b) giving written notice, in any of the manners provided for in section 47D of the Act, to— (i) the occupiers of the site and, if the proponent or 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 the site where the activity is or is to be undertaken and to any alternative site where 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 and to any alternative site where the activity is to be undertaken; (iii) the municipal councillor of the ward in which the site and alternative site is situated and any organisation of ratepayers that represent the community in the area; (iv) the municipality which has jurisdiction in the area; (v) any organ of state having jurisdiction in respect of any aspect of the activity; and (vi) any other party as required by the competent authority;

(i) 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 undertaken;

With regards to Stakeholder and I&AP communications, all relevant authorities have been notified of the application and have been provided with copies of this report. Refer to Appendix D4 - Appendix D4: Proof of Notifications, Notices and Flyers.

Advertisements (c) placing an advertisement in— (i) one local newspaper; or (ii) any official Gazette that is published specifically for the purpose of providing public notice of applications or other submissions made in terms of these Regulations; (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 boundaries of the metropolitan or district municipality in which it is or will be undertaken: Provided that this paragraph need not be complied with if an advertisement has been placed in an official Gazette referred to in paragraph (c)(ii); and

Advertisements regarding inter alia the proposed project scope of works, location and details of locations and date for draft Scoping Report review as well as details of EAP were placed in English and Afrikaans in The Cape Times and the Cape Argus on 22nd September 2020 as part of the Public Participation Process during the Scoping Phase.

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Refer to Appendix D6 – Proof of Placement of Advertisement.

Background Information Document: During the PPP, BID (including registration and comments forms) was distributed via email, stakeholders, as well as other interested and affected parties (I&APs) on 22nd September 2020. Refer to Appendix D8 – BID and Comment Form.

Additional Media Sources: Since commencement of the public participation process on the 22nd September, the media and public assisted in expanding the reach through the following methods: . Online post by the Saldanha Water Quality Trust Forum https://sbwqft.org.za/Powership-in-saldanha-bay- environmental-impact-assessment/; . Online news post by West Coast Business Chamber https://weskussakekamer.co.za/Powership-in- saldanha-bay-environmental-impact-assessment/; . Cape Times online advert publication https://www.pressreader.com/south-africa/cape- times/20200922/page/13; . Article published in Die Weslander on the 01 October 2020; . Online article shared in the Weslander on the 05 October 2020 https://www.netwerk24.com/ZA/Weslander/Nuus/openbare-deelname-vir-drywende-kragskip-in-saldanha- 20200930-2; . Online post by Paradise Beach HOA https://www.paradisebeachhoa.co.za/

Refer to Appendix D11 – Additional Media Sources for copies.

Public Meeting: Virtual Public Meetings were undertaken as part of the Scoping Phase. The primary aim of the public meeting was to: . provide I&APs and stakeholders with information regarding the proposed project and associated infrastructure; . provide I&APs and stakeholders with information regarding the EIA process; . provide an opportunity for I&APs and stakeholders to seek clarity on the project; . record issues and concerns raised; and . provide a forum for interaction with the project team.

Phelamanga, an independent public participation facilitation company, was employed to facilitate the public participation process.

Recognising that not all stakeholders and I&APs are available at certain times of the day, the online meeting platform enabled Phelamanga to provide a morning and evening meeting option for the relevant Stakeholders and registered I&APs to interact. The same information was provided at both sessions and registered I&APs received the minutes of both sessions and the comments and issues trail. The meeting was held via Microsoft Teams and the meeting link was shared to relevant stakeholders and Registered I&APs. Page 103

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Date: 15 October 2020 Time: 10am and 6pm Online Platform: Microsoft Teams

Relevant Stakeholders and registered I&APs were encouraged to submit questions or comments in advance of the online meeting so that feedback can be provided. Refer to minutes of the public meeting in Appendix D11.

Public Review of the Draft Scoping Report: The draft Scoping Report was made available for public review for a period of 30 days review from 06 October 2020 to 06 November 2020 during which I&AP’s were afforded the opportunity to raise any further issues and concerns, until the finalisation of the document for submission to the Department of Environmental Affairs, Forestry & Fisheries (DEFF).

A hard copy of the report was made available at the Cup of Cake Restaurant (37 Main Rd, Saldanha, 7395) because it was reported to be easily accessible to local I&APs.

The report was also available at Triplo4 Ballito Offices (Suite 5, The Circle, Douglas Crowe Drive, Ballito) and made available electronically on Triplo4’s Website www.triplo4.com.

No requests or comments were made to view the hardcopy of the draft scoping report at either location during the Scoping Phase.

Public Review of the Draft Scoping Report: The draft Scoping Report was made available for public review for a period of 30 days review from 06 October 2020 to 06 November 2020 during which I&AP’s were afforded the opportunity to raise any further issues and concerns, until the finalisation of the document for submission to the Department of Environmental Affairs, Forestry & Fisheries (DEFF).

The report was also be made available at the following public locations within the study area, which are all readily accessible to I&APs: . Cup of Cake Restaurant: 37 Main Rd, Saldanha, 7395 . Triplo4 Ballito Offices: Suite 5, The Circle, Douglas Crowe Drive, Ballito; and . Triplo4 Website: www.triplo4.com.

Comments Received on the Draft Scoping Report: 44. (1) The applicant must ensure that the comments of interested and affected parties are recorded in reports and plans and that such written comments, including responses to such comments and records of meetings, are attached to the reports and plans that are submitted to the competent authority in terms of these Regulations. (2) Where a person desires but is unable to access written comments as contemplated in sub regulation (1) due to— (a) a lack of skills to read or write; Page 104

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(b) disability; or (c) any other disadvantage; (d) reasonable alternative methods of recording comments must be provided for.

All concerns, comments, viewpoints and questions (collectively referred to as ‘issues’) from the Scoping Phase have been documented and responded to in the Comment and Response Report.

Refer to Appendix D9– Comments and Responses Trail which includes the comments received during Scoping and the corresponding responses.

PUBLIC PARTICIPATION DURING EIA PHASE Maintenance of I&AP Database A database of I&APs (refer to Appendix D7), which includes authorities, different spheres of government (national, provincial and local), stakeholders, landowners, interest groups and members of the general public, was maintained during the EIA phase.

Since the submission of the Final Scoping Report was submitted to DEFF on 17 November 2020, Triplo4 continued to receive requests to be added to the database or to be provided with the associated project information.

Requirements of the approved PP Plan The requirements of the EIR phase as per the approved PP Plan are listed below: . An email notification to registered I&APs will be sent out to inform them of the availability of the Draft Environmental Impact Assessment (EIA) Report for review. . Flyers will again be distributed locally and put up on public notice boards. Again, assistance form the municipality and ward councillor will be obtained to ensure these are widely distributed. . The Draft EIA Report will be made available to I&APs, including State Departments and DEFF for public comment for period of 30 days. The report will be available on the Triplo4 website (www.triplo4.com). In addition, the EIA Report will also be electronically available via an online platform such as Dropbox or GoogleDrive which will be emailed to all registered I&APs. Electronic copies will also be sent to DEFF and organs of state, including State Departments. . The public copy venue will be confirmed with the municipality and ward councillor and will depend on what public venues are open under Covid restrictions. Other arrangements will be made to ensure people have access to the report should they be unable to access the public venue copy or the electronic copy. . A virtual Public Meeting will be held during the EIR review period, with reasonable notice period given. It is proposed that this meeting will be done via a Webinar and not at the physical site locations. An attendance register and minutes of the meeting will be distributed; . Should I&AP’s be unable to participate in the virtual meeting, a standard contact public meeting will be arranged during the 30 day comment period with reasonable notice period given; . Where I&APs indicate that they are unable to participate in the virtual meeting, they will be personally contacted and their issues, questions and concerns will be discussed and recorded. . All Comments received during the Public Participation Process (PPP) will be captured in a Comment and Response Report/ Issues Trail; Page 105

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. The Final EIA Report will be submitted in an electronic format to DEFF, for a decision; . Registered I&APs will be notified of the decision on the Environmental Authorisation as well as be provided with access to the decision.

Public Meeting As part of the public participation process, meetings will be independently facilitated, using online meeting platforms to allow for participation during the COVID-19 pandemic. Phelamanga, an independent public participation facilitation company, will facilitate the public participation process for the EIA phase as completed during the Scoping phase.

Two meeting time options will be offered - a morning session and an evening session. The same information will be provided at both sessions and registered I & APs will receive the minutes of both sessions.

The meetings will be conducted on Wednesday, 15th March 2021 at 10:00 and at 18:00 and the links to enable to join the online meetings will be provided to registered I&APs approximately a week in advance.

I&APs who are unable to participate on such platforms, were requested to contact Triplo4 in advance so that additional assistance or alternative arrangements to participate can be made.

This draft EIA report will be made available before the Webinar dates, and Stakeholders and registered I&APs are encouraged to submit questions or comments in advance of the online meeting so that feedback can be provided.

Minutes of the public meetings will be attached to the final EIA report.

Public Review of Draft Environmental Impact Assessment Report This draft Environmental Impact Assessment Report will be made available for public review for a period of 30 days review from 26 February 2021 to 31 March 2021 during which I&AP’s will be afforded the opportunity to raise any further issues and concerns, until the finalisation of the document for submission to the Department of Environmental Affairs, Forestry & Fisheries (DEFF).

A hard copy of the report will be made available at the Cup of Cake Restaurant (37 Main Rd, Saldanha, 7395) as done during the Scoping phase because it was reported to be easily accessible to local I&APs.

The report will also be made available at Triplo4 Ballito Offices (Suite 5, The Circle, Douglas Crowe Drive, Ballito) and on Triplo4’s Website www.triplo4.com. I&APs are requested to contact the Triplo4 office if you experience any difficulty in accessing these reports.

Comments and Responses Trail Report The Comments and Responses Trail Report was maintained with comments received after the submission of the Final Scoping Report and was included in the distribution of the Draft EIA Report. The Comments and Responses Trail Report records the date that issues were raised, a summary of each issue, and the response from the team

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Summary of Issues Raised by I&APs All views, issues and concerns raised so far (up until the start of the EIA phase public comment period) have been captured into the Comments and Responses Report (see Appendix D9). Full copies of the comments submitted are included in Appendix D. A summary of the key issues that were raised by Stakeholders and I&APs is included in the table below:

MAIN ISSUES RAISED DURING SECTIONS ADDRESSING THESE ISSUES IN THE DRAFT SCOPING EIAR Synergy between Sunrise Energy and the This comment could not considered as the Sunrise Energy deals Proposed Gas to Power Powership Project with LPG while the client proposes the use of LNG. at Saldanha Bay. Sourcing of natural gas and extraction As per Section 2, the natural gas will be internationally sourced considerations. therefore the impacts from the extraction of gas falls outside the scope of this project. Safety and Security Risks Section 2.1.1 – Safety and Security Section 8 – Impact Assessment Appendix I – Specialists Studies: Major Hazard Installation Risk Assessment Appendix G - EMPr Coastal and Climate Change Risks Section 2.1.2 – Berthing and Mooring Section 8 – Impact Assessment Appendix I – Specialists Studies: Climate Change Impact Assessment Appendix G - EMPr Leakage / spill risk from gas pipeline and Section 2.1.1 – Technology and Concept Designs potential impacts Section 2.1.3 – Gas pipeline maintenance Section 8 – Impact Assessment Appendix I – Specialists Studies: Marine Ecology Assessment Appendix I – Specialists Studies: Major Hazard Installation Risk Assessment Appendix G - EMPr Source of the LNG Section 2.1.4 – Source of LNG Socio-economic benefits and impacts Section 6 – Motivation, Need and Desirability Section 8 – Impact Assessment Appendix I – Specialists Studies: Socio-Economic Impact Assessment

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Appendix G - EMPr Potential unplanned power supply Section 2.1.1 – Technology and Concept Designs interruptions due to Powership system failure Risk of bad weather preventing refuelling Section 2.1.7 – Refuelling Carbon Footprint and GHG emissions Section 6.1 – Motivation, Need and Desirability Section 8 – Impact Assessment Appendix I – Specialists Studies: Greenhouse Gas Emission Report Appendix J – Specialists Studies: Atmospheric Impact Report Detailed Layout and Sensitivity Maps Appendix A – Site Plans Public Participation Process in line with Section 7 – Public Participation Process legal requirements Cumulative Assessment Section 8 – Impact Assessment Appendix I – Specialists Studies List of all applicable listed activities Section 2.2 - All Listed and Specified Activities Triggered in terms of NEMA and NEM: AQA Alternatives assessment, including the Section 3 – Alternatives option of not implementing the activity and Section 8 – Impact Assessment the proposed location for the laydown area for gas pipeline installation Mitigation measures to reduce impacts on Section 2.1.1 – Technology and Concept Designs ocean and coast environment Section 2.1.3 – Gas pipeline maintenance Section 8 – Impact Assessment Appendix I – Specialists Studies: Marine Ecology Assessment Appendix I – Specialists Studies: Coastal and Estuarine Assessment Appendix I – Specialists Studies: Major Hazard Installation Risk Assessment Appendix I – Specialist Studies: Climate Change Assessment Appendix G - EMPr Detailed methodology for the installation of Appendix J – Technical Reports: Gas pipeline Installation the gas pipeline Methodology Assessment of potential impacts on the Section 8 – Impact Assessment Estuarine Functional Zone Appendix I – Specialists Studies: Estuarine and Coastal Assessment

Managing impacts on local species during Section 8 – Impact Assessment breeding seasons during construction Appendix I – Specialists Studies: Estuarine and Coastal phase Assessment Appendix I – Specialists Studies: Ecological Assessment Appendix I – Specialists Studies: Marine Ecological Assessment Appendix G - EMPr

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Atmospheric Impact Assessment to Section 4.1.8.1 – Air Quality consider the study performed from 2017 to Appendix I – Specialists Studies: Atmospheric Impact Report 2019, showing a considerable increase in

PM10 exceedences at different monitoring stations. Life span of the project Section 2.1 – Description of the activities Location of the LNGC Section 2.17 – Refuelling

NOTIFICATION OF ENVIRONMENTAL AUTHORISATION On issuing of a decision by DEFF, notices will be sent to all registered Interested and Affected Parties that the Environmental Authorisation (EA) has been granted or refused and that it is available for review. These notices will indicate the process required to lodge an appeal, as well as the prescribed timeframes in which documentation should be submitted

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8 ENVIRONMENTAL IMPACT ASSESSMENT

OVERVIEW OF EIA PROCESS The EIA process, including public participation that is required for an application for environmental authorisation and an atmospheric emission licence is prescribed by the EIA Regulations, 2014. Thus, the EIA process for the proposed Gas to Power via Powership project has to comply with these Regulations in order for the application to be valid. The process applicable to Karpowership’s application is Scoping & Environmental Impact Reporting (S&EIR).

Subsequent to the application form for environmental authorisation having been submitted to the competent authority, DEFF at the beginning of October 2020, Triplo4, the Environmental Assessment Practitioner (EAP) commenced with the first phase, Scoping. In order to meet the prescribed 44-day timeframe, Triplo4 had already started identifying, notifying and engaging with Interested and Affected Parties (I&APs) in September 2020.

The EAP, with guidance from DEFF, and input from specialists and I&APs, including relevant organs of state identified issues, impacts and risks associated with the proposed activities and their alternatives in context of the receiving environment and regulatory framework. The Scoping Report was made available for a 30-day comment prior to it being submitted for consideration to DEFF on 17 November 2020.The Scoping Report, including the plan of study for EIA contained therein was accepted by DEFF on 6 January 2021. This automatically triggered the commencement of the current phase, the EIA (also referred to as the EIR) for which the applicant and EAP have 106 days to complete.

In preparing this draft EIA Report for I&AP comment, Triplo4 engaged with numerous specialists and detailed studies were conducted and considered. Refer to Table 1-1 for the details of Specialist and Technical Team, as well as Appendix I for the full specialists and technical studies. Section 4 of this report contains the baseline descriptions of the environment, based on research conducted by the specialists’ in the various field of expertise.

The site layout alternatives assessed during Scoping and considered feasible were brought forward to the EIA phase for further assessment, and are discussed in Section 3 of this report. They all fall within the site approved by DEFF at the end of Scoping, which is the Port of Richards Bay. The No-Go Option is also an alternative that is required to be assessed as part of the EIA.

The methodology used to assess the potential impacts is described in Section 8.2. Deviations from approved Scoping Report (including Plan of Study) and the assumptions, uncertainties and gaps in knowledge relating to the assessment and mitigation measures proposed are also presented in Sections 8.7 and 8.8 respectively.

The findings of the assessment of the potential impacts and risks associated with the proposed project and alternatives, as well as identification of mitigation measures, are reported in detail in Section 8. The mitigation

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IMPACT ASSESSMENT METHODOLOGY

2014 NEMA EIA Regulations (as amended), Appendix 3 (1) (v) the impacts and risks identified including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts; (vi) the methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks; viii) the possible mitigation measures that could be applied and level of residual risk.

This section describes the method used to assess and rank the impacts and risks of the site layout alternatives, including cumulative impacts for all phases of the proposed project, and indicates of the extent to which the issue and risk can be avoided or addressed by the management actions.

The following criteria were considered for the assessment of each impact.

The nature of an impact is the type of effect that the activity will have on the environment. It includes what is being affected and how.

The significance of an impact is determined by a combination of its consequence and likelihood.

The table below describes the scoring of the impacts and how they determine the overall significance.

Scoring of Impacts Consequence Severity 1 – Insignificant / Non-harmful 2 – Small / Potentially harmful 3 – Significant / Slightly harmful 4 – Great / Harmful 5 – Disastrous / Extremely harmful Duration 1 – Up to 1 month 2 – 1 month to 3 months 3 – 3 months to 1 year 4 – 1 to 10 years 5 – Beyond 10 years / Permanent Spatial Scale 1 – Immediate, fully contained area 2 – Surrounding area 3 – Within business unit area or responsibility

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4 – Within mining boundary area / Beyond BU boundary 5 – Regional, National, International Overall Consequence = (Severity + Duration + Extent) / 3 Likelihood Frequency of the Activity 1 – Once a year or once / more during operation / LOM 2 – Once / more in 6 months 3 – Once / more a month 4 – Once / more a week 5 – Daily / hourly Probability of the Incident / Impact 1 – Almost never / almost impossible 2 – Very seldom / highly unlikely 3 – Infrequent / unlikely / seldom 4 – Often / regularly / likely / possible 5 – Daily / highly likely / definitely Overall Likelihood = (Frequency + Probability) / 2 Overall Environmental Significance = Overall Consequence X Overall Likelihood Overall Environmental Significance: 0 - 2.9 Very Low 3 - 4.9 Low 5 - 6.9 Medium - Low 7 - 8.9 Medium 9 - 10.9 Medium - High 11 and above High

The impacts identified in the Scoping Report have been expanded on in this EIA Report following receipt of more information from the various specialist studies. Impacts scoring a higher significance in the Scoping Report, received more attention in this EIA Report. The impacts identified in the impact assessment were identified in the specialist reports and through the public participation process. The scoring and assessment of impacts as well as discussion of mitigations in this EIA Report have followed a detailed assessment process.

Refer to Section 8.4 (Impact Assessment) for the impacts and mitigation measures associated with the proposed activity.

Environmental, social and economic impacts associated with the project were further identified through site visits undertaken by project team and various specialists, consideration of the project description, site layout and the specialist studies. As part of the public participation process, I&APs were given an opportunity to provide input to the project at the public meeting sessions and through the review of the BID, advertisements, site notices and the Draft Scoping Report. I&APs will be given a further opportunity to provide input through the review of the EIA Report and/or summary. The feedback received from I&APs also provided input into the identification of environmental and socio-economic issues to be assessed.

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SPECIALIST FINDINGS AND RECOMMENDATIONS

A description of the environmental impacts and risks identified during the EIA is described in this section.

The following potential impacts were considered in the Environmental Impact Assessment Phase for the proposed project. The specialist reports will be made available with the draft EIA report for public comment, and will take into account the comments submitted by I&APs during Scoping. Recommendations from the specialists for the mitigation of potential impacts were incorporated to the EMPr, attached as Appendix G.

Terrestrial Ecology The transmission line is located within areas of complete transformation (for example both options) as well as in severely degraded to degraded indigenous vegetation. No SCC were recorded from the area traversed by the current transmission line route. This indicates that the site is of low sensitivity with some areas of indigenous vegetation and fewer aliens of moderate sensitivity.

Findings The site comprises a mix of several vegetation units, many of which have been negatively impacted by the current land use for the area. Some areas have been completely transformed, whilst others are degraded natural habitats. Vegetation types include the dominant Saldanha Flats Strandveld, with some areas of transition between Saldanha Flats Strandveld and Saldanha Limestone Strandveld. All areas of indigenous vegetation are degraded and have high levels of weeds (both indigenous ruderal species and aliens as well as alien invasive plants). Updated alternatives to transmission line routes are located within a transformed port area, and the impacts on terrestrial biodiversity associated with these is negligible. The addition of land-based gas pipelines and a laydown area within the dunes and beach most likely comprising Saldanha Dune Strandveld are likely to have high negative impacts.

Impacts during Construction and Operation:  Loss of vegetation communities  Loss of Species of Special Concern and Biodiversity  Ecosystem function and process

The site is mostly of low sensitivity due to the wide distribution of modified and degraded habitats and the alignment of the transmission line route with existing infrastructure. This places the route primarily within transformed or modified habitat, resulting in little overall loss of indigenous vegetation. Impacts are Moderate and can be reduced to low with the recommended mitigation measures. Impacts within the dune areas are the highest, if it is not possible to relocate these aspects, then rehabilitation must be completed immediately after construction.

Recommendations The specialist supports the development provided the mitigation measures presented are implemented. The following pre-commencement conditions should also be undertaken  A walk through of the site prior to any construction to determine the presence of any Species of Conservation Concern (SCC)  Application for permits for removal of any SCC where required.

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 The development of a rehabilitation plan in line with port expansion plans and in conjunction with Transnet and the IDZ  The development and implementation of an alien invasive plant management plan.  Confirmation if relocation of the dune-situated aspects is possible.

Avifauna Desktop Scan Findings Based on a desktop sensitivity scan of the proposed project in relation to Birdlife South Africa’s avian sensitivity map, the proposed Gas to Power Powership project is situated in an area of low-bird sensitivity (score ~ 50-100) whilst darker squares surrounding the project area depict medium bird sensitivity (highest scores 400-600). The line bisects one pentad of low (197) sensitivity. See http://www.birdlife.org.za/conservation/terrestrial-bird- conservation/birds-and-renewable-energy/solar-farm-map.

Figure 8-1 National Bird Sensitivity in Saldanha Bay

Site Findings To provide more exact estimates of the risk to birds in the Saldanha Bay area, the specialist determined the number of birds that may cross the lines by recording the number of priority species per hour of observation from the two Vantage Points overlooking the beach, and the iron ore facility where the lines will come onshore. The passage rate was relatively high at 9.85 birds per hour for all nine species identified which included two Red Data species – Caspian Terns and Cape Cormorants – both in low numbers. A total of five priority birds were recorded. Flight heights were often at power line height of 0 to 50m (31 of 38) for all species combined. Thus, while Passage Rates were high, the number of priority species was low. The findings suggests that few fatalities will occur if another line is erected parallel to the existing lines.

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Risk to priority collision-prone birds was measured by walking and driving 9,1km of the existing lines. Only three fatalities and three species were found in the nine kilometres surveyed, to give a fatality rate of 0.33 birds per kilometre. No priority bird species were found as power line victims. The three species identified (Kelp Gull, Crow and Sacred Ibis) are all common Least Concern species.

Powerlines are on rare occasion used for breeding by raptors or crows. One prominent and unusual breeding species was a Yellow-billed Kite Milvus parasitus found just outside the main entrance of the Saldanha steel works.

Recommendations Suitable mitigations measures were provided along the proposed routing, especially in the ship-to-shore section across open water. In order to reduce potential avian fatalities, it is recommended that the proposed transmission line is aligned with the existing 132kV line and staggering the pylons (Pallett et al. in prep) of the two adjacent lines. Another measure to prevent bird fatalities is to add bird diverters to all sections of the line as it erected and made bird friendly to avoid electrocutions. Furthermore, construction and post-construction monitoring must take place to ensure that any line-related fatalities are documented and addressed immediately.

Wetland Desktop Assessment Findings The desktop assessment allowed for certain watercourses within the study area to be excluded from further investigation based on whether these systems were likely to be impacted upon by the proposed development. The watercourses within the study area were identified on a desktop level, classified and delineated in-field and subsequently mapped utilising GIS (QGIS 2.14 and Google™ Earth Pro) and available spatial data.

Figure 8-2 below demonstrates the delineated watercourses identified within the study area during the field assessment. Due to no watercourses being found to be at risk, there will be no need to conduct any further assessments in terms of integrity, functionality, EIS, buffer calculation and RAM.

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Figure 8-2 Wetland Delineation

Recommendations As no watercourses were found to be at risk, the mitigation measures are general and will be incorporated in to the Environmental Management Programme. Project specific measures for construction, operation and post construction relate to stormwater management.

Hydropedology Desktop Assessment Findings Available soil data were evaluated for the project area to produce a soil distribution map. The soil map was used to categorize the hydrological soil types (HST), into the following categories:  Recharge.  Responsive (shallow).  Responsive (saturated).  Interflow (A/B); and  Interflow (A/bedrock).

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Generally, interflow (A/Bedrock or Soil/Bedrock) soils are dominant across the study area. Hydromorphic properties in these soils signify temporal build of water on the soil/bedrock interface and slow discharge in a predominantly lateral direction. These soils and landscapes exhibit of the project area is that of rapid drainage and percolation of water.

Available data suggest that interflow (A/B) soils may occur in areas associated with man-made and infilled areas (near the industrial developments in the project area). In interflow (A/B) soils the flow path is predominantly downslope in a lateral direction. If interflow (A/B) soils occur downstream of interflow (soil/bedrock) and overland flow at the soil interface may occur. Deep secondary flow towards the saturated zone is expected.

Several hydropedological risks were identified for the construction of the transmission line associated with site preparation, excavation, soil contamination and vegetation loss during construction and activities such as stockpiling and spill contamination during operational phase as detailed in Section 8.4 below. The risk associated with the construction and operational phase is estimated to be low and decrease to marginal after consideration of proposed mitigation measures.

Due to the project type (i.e. linear development over a large area, where only a small soil area will be disturbed) no impacts on the suppression of hydropedological flow drivers are anticipated. No wetland areas were identified in the vicinity of the proposed development. Based on the project type, no hydropedological flow buffers will be required.

Recommendations Waste management, implementing measures such as covering stockpiles and erecting erosion protection structures where vegetation is to be cleared during construction of the transmission line recommended. The Department of Environmental Affairs (DEA) published a generic Environmental Management Plan (EMPr) for substations and powerlines (22 March 2019). It is proposed that the mitigation and monitoring plan presented in this report be further supplemented by the generic EMP document.

River and Riparian (Aquatic) One assessment site was investigated 3km to the west of the proposed development. Although the assessment event was undertaken in spring, directly after the winter rainfall season unique to the Western Cape, no water flow was present within the study site. Therefore, no aquatic assessment could be conducted, in accordance with the SASS5 protocol. Considering the absence of any surface watercourses near the proposed transmission lines and the linear nature of the project it was established that there will not be any impacts on the aquatic environment, and this project can be considered for approval.

Recommendations The specialist indicated that it is not necessary to implement a biomonitoring plan for the proposed project as the construction and associated impacts of the transmission lines will be once off, and the operational phase will have no further inputs or impacts on the receiving environment. The Department of Environmental Affairs (DEA)

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Surface Water (Hydrology) The study site falls within a Winter rainfall region and experiences peak rainfall and evaporation in June. The MAP, MAE, and MAR for the quaternary catchment are 225 mm, 1 460 mm and 6.5 Mm3, respectively. The proposed development site at Saldanha Bay was assessed and it was noted that there is no significant surface water bodies nearby the site. For this reason, flood line modelling was not justifiable for this site. Since there are no nearby surface water bodies at the proposed Saldanha Bay development site, it can be said that there is no risk posed to surface water in the area.

Groundwater (Geohydrology) Findings Two (2) aquifer systems are envisaged, namely, an unconfined aquifer associated with the unconsolidated sands; and a confined and fractured aquifer network associated with deeper and older granite/gneiss rock. Available groundwater level data suggest that the water table for the area range from 3 to 15 metres below ground level (mbgl). Based on the Source-Pathway-Receptor (SPR) model, the following receptors are noted for the project area: the non-perennial streams and wetland (estuary) system downstream of the site; the vadose zone soils; and the groundwater table.

Recommendations The specialist recommended that a proper monitoring programme be implemented to monitor both the water quality and quantity at the site as described in Section 6 of the Geohydrology Assessment. Waste management, implementing measures such as covering stockpiles during construction of the transmission line recommended. The Department of Environmental Affairs (DEA) published a generic Environmental Management Plan (EMPr) for substations and powerlines (22 March 2019) and the measures included can be used to supplement the Geohydrology Assessment.

Climate Change The following section provides context to the emissions assessment undertaken for the proposed activities at Saldanha Bay. An overview of global GHG emissions is presented, followed by the corresponding national context. Given the high methane content in natural gas, the global and national status quo of methane emissions are also summarised.

Operational emissions efficiency by contracted capacity From an emissions perspective, the Powership performs most efficiently when operating at full capacity. The fuel efficiency of the generators will be based on several factors including temperature/cooling, revolutions per minute (RPM), generating capacity, and load capacity. What becomes evident is the increased fuel efficiency of larger generators operating at full load capacity, as opposed to the smaller generators, or operating at lower load. The ship at Saldanha Bay has an emission profile of 0.505 tons per MWh, increasing to 0.506 between 90-80% capacity. From 55% and lower, emissions increase from 0.506 to ~0.513 at 25% capacity. For the worst-case scenario (i.e. Page 118

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. operating at the design capacity of the Powership), there is a decreased emission rate to 0.504 CO2e/MWh when operating at 125.4% of the contracted capacity delivering 401.3 MW net.

Given the generation capacity of the ships located at Saldanha Bay is 415MW the emissions from 100% capacity are 209.16t CO2e. The reduction of efficiency from lowering contracted capacity will have adverse implications for emissions per MW generated. For the Powership at Saldanha Bay with the reduced efficiency when not operating at 100% there are anomalies (Figure 27). From 90-80% and 60-55% capacity there are ~0.4 tons CO2e/MWh emitted. At the lower capacities of 45, 35, and 25% the emission per MWh increases to 1.2, 2.5, and 3.3 tons CO2e, respectively.

CO2e Emissions calculations Anomaly tons CO2e from 100% contracted operations 0,514 3,5 0,513

0,512 3,0

0,511 2,5 0,510 2,0 0,509 1,5

0,508 GHG GHG CO2e factor 0,507 CO2e (tons) MWh / 1,0

0,506 0,5 0,505 -

0,504

70 95 90 85 80 75 65 60 55 50 45 40 35 30 25

100 95 90 85 80 75 70 65 60 55 50 45 40 35 30 25 100 % Contracted Capacity % Contracted Capacity

Figure 8-3 Saldanha Bay GHG efficiency at varying operational levels (left), anomaly GHG emissions at varying operational levels (right)

The National Climate Change Response Policy (NCCRP) defines two primary climate change-related considerations when considering industrial and economic development projects or activities. These are: i) the use of appropriate risk identification and risk reduction measures, including observed and projected climate change impacts and appropriate mitigation measures; and ii) assessment of whether project activities reduce rather than enhance adaptive capacity of communities at local, provincial, or national level. The proposed project has been evaluated against the best available data and information to identify climate risks and impacts, including dynamically downscaled climate models. Appropriate mitigation measures are proposed based on their potential to reduce the significance of the identified climate change impacts and risks. The proposed activities are likely to indirectly increase the adaptative capacity of local communities through improved energy security and potential trickle-down benefits of greater efficiency within the SEZ and its dependent sectors.

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This climate change impact assessment study therefore concludes that the significant climate change impacts that have been identified can be offset to acceptable levels through proactive implementation of appropriate mitigation measures. The extent to which the project proponent contributes to carbon capture, storage or offset initiatives will depend on the final quantification of GHG emissions, including the emissions associated with LNG extraction and transport.

Estuary The proposed project will occur 3.5 km from the Langebaan Lagoon MPA, and the sensitive marine and estuarine habitats therein. The majority of the potential impacts associated with the project are likely to be highly localised, that is, in situ of the project components within the Port of Saldanha, and not anticipated to have a direct effect on the integrity and ecology of the lagoon. There is concern, however, of the potential impact of the overhead powerlines on the local and migratory bird species that utilise the lagoon and surrounding coastal areas.

The current pressures on the coastal zone as a whole, while limited, need to be considered holistically in relation to the modification of the coastal environment and loss of habitat as a result of the port development coupled with ongoing modern-day impacts of the special economic industrial zones. While the protection and sustainable development of the coastal environment remains critical, this needs to be counter-balanced with the value provided by the ports and adjacent industrial areas which are specifically designated to take advantage of the blue economy. A full estuarine impact assessment for the Langebaan Lagoon is not deemed necessary as a specialist Marine Ecological Assessment, as well as an Avifauna Specialist Assessment/ Terrestrial Ecological Assessment specifically in respect to the powerline transmission route is considered to be suitable.

Marine Ecology The activities involved in the proposed FPP facility's construction and operation will result in interactions with receptors in the marine environment. Disturbances that have the potential to result in significant impacts are assessed by the specialist as detailed below:

The effects of gas pipeline construction and installation and vessel mooring on the littoral and benthic community The gas pipeline construction and installation and vessel mooring will have an effect on the littoral and benthic community. It is anticipated that the subsea and intertidal section of the pipeline will have a servitude of approximately 10 m to allow for mounting and protection, and this section of the pipeline will be approximately 4 200 m long. This will result in a benthic habitat disturbance of approximately 42 200 m2 (pipeline x servitude + mooring blocks) within the local scale area of about 5000 ha. This will result in the modification of approximately 0.08% of the community structure on site.

Assuming colonization of the hard surfaces by indigenous fauna will represent a minor increase in benthos biodiversity in the project area. Furthermore, this is within an already compromised area of the port. The subtidal benthic macrofauna in the Port of Saldanha Bay is detailed in the baseline. Trace metal concentrations in the vicinity of the proposed Powership are generally elevated to exceed the recommended guidelines, indicating a disturbed environment (Anchor 2020). Additionally, Anchor (2020) report that benthic community diversity was lowest in Big Bay, near the proposed FSRU and subsea gas pipeline location and at the iron ore terminal. This is attributed to the higher levels of anthropogenic disturbance, including dredging and a high proportion of mud content in these areas.

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The gas pipeline will be located in a sandy shore region where seaweeds and macroalgae generally dominate (Anchor 2019). Additionally, beach erosion is a significant issue in Big Bay and Small Bay. Given the low density of marine fauna in the littoral zone and the indication that area in the vicinity of the proposed FPP facilities is disturbed, ecological damage can be considered minor.

The effects of the uptake of cooling water on marine organisms in the surrounding water body Seawater abstracted by the Powership will entrain small marine organisms such as holoplankton, meroplankton and ichthyoplankton from the surrounding water body condenser cooling systems. This will be coupled with the impingement or trapping of larger organisms against the screens used to prevent debris from being drawn into the cooling water intake. As entrained organisms pass through the pumps, they are exposed to collective changes in hydrostatic pressure, shear forces, accelerative forces from changes in velocity and direction, and mechanical buffeting and collision against the pump mechanisms' hard surfaces. These can cause physical damage to marine organisms, especially larger, more fragile species, resulting in death or incapacitation, the latter reducing their ability to escape predators post-discharge. Furthermore, the abstracted seawater receives excess heat and increases in temperature through the cooling process, inducing thermal stress on entrained organisms. Temperatures of the cooling water can be expected to increase by 15°C (ΔT) whilst in the system. Rapid temperature increases above ambient conditions can affect marine organisms' survival, growth, metabolism, morphology, reproduction, and behaviour. No chemical stress on organisms is predicted as no biocides, chemicals, or brine will be discharged.

Saldanha Bay is a highly productive system owing to its link to the southern Benguela upwelling system. Mean water column concentrations in Small Bay and Big Bay, in waters surrounding the proposed FSRU and Powership locations, ranging from 5.4 to 31.5 mg Chl-a/m3, with sites in Small Bay generally being characterised by lower Chl- a concentrations and biomass (Pitcher and Calder 1998; Pitcher et al. 2015). The zooplankton species assemblage in the Bay strongly resembles that in the southern Benguela upwelling system in the nearshore area, indicating that seawater exchanges strongly influence the bay with adjacent continental shelf waters; there are large numbers of meroplanktonic forms present in the Bay system (Grindley 1977). The Bay/Langebaan Lagoon complex supports diverse and abundant fish communities. It provides important nursery habitat for many species (mainly in Langebaan Lagoon and shallow nearshore waters) that are essential to ecosystem functioning and integrity (Grindley 1977). The communities mentioned above also play a critical role in providing local ecosystem services such as fisheries and aquaculture/mariculture.

Plankton biomass recovers quickly due to short generation times (~0.3/day), and populations are quickly replenished via tidal mixing processes from the wider port water body and the adjacent continental shelf. Accordingly, it is anticipated that the volumes of plankton entrained will not affect broader ecosystem functioning. Additionally, there is a lack of project-specific literature on uptake and entrainment, i.e. plankton mortality data. However, it is reported by Poornima et al. 2005, amongst others, that the mortality rate from thermal and mechanical stress of plankton entrained is not 100%.

The seawater abstraction process also affects other, generally larger, marine organisms such as juvenile fish through impingement on the intake pipes' screens. Notable organisms that can be impinged in the Port of Saldanha Bay include juvenile fish, several shark species and several species of cetaceans (detailed in section 2.5.6). However, in Small and Big Bay, there has been a declining trend in fish and juvenile fish species (detailed in 2.5.5).

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This has been attributed to fishing pressure, a decrease in habitat quality for juvenile fish, and water quality reduction.

Although the cooling water intake velocities are large (2.4 to 11.4 m3/s), in comparison to the approximate total volume of water at the site-specific scale around the Powership (>6million m3; site-specific area x average depth), volume intake per time by the Powership is low. Furthermore, larger organisms will likely be able to swim away from intake pipes.

The effects of the discharge of cooling water on the marine ecology in the receiving water body The operation of the Powership will involve the continuous discharge of cooling water into the sea at a depth of 7m, as recommended in the modelling report (PRDW 2020).

The seawater is discharged through multiple outlets on the vessel hull (Figure 3.1). The outlets have diverting elbows and pipes running down the vessel hull to discharge below the water surface. Total intake/outlet flow rates range from 2.4 to 11.4 m3/s, and the increase in temperature of the seawater (ΔT) ranges from 4 to 15°C. It is understood that no biocides, brine or chemicals such as chlorine will be discharged with the cooling water.

The discharge of warmed cooling water to the surrounding water body causes temperature changes which generate chronic level effects on biota. These include alterations in growth, metabolism, respiration patterns and reproduction, and/ or influence ecosystem-level processes such as alterations of the amount of oxygen dissolved in seawater, which can be detrimental to marine life (Robinson 2013, Anchor 2015). The sensitive receptors comprise the ‘resident biota’, including seaweeds (Gracilaria beds), mussels and oysters in mariculture farms, and fish larvae. The latter are abundant in the nearshore shallow waters, which serve as an important nursery ground for juvenile marine fish, including the declining Rhabdosargus population. The fish recruit from here to the bay and adjacent coastline of this Southwestern Cape coastal ecoregion. Larger animals that are more mobile are not considered sensitive, as they can move away from areas of warmer water if they feel discomfort.

Recommendations  The contractors laying the pipes and anchors should minimise the area of seabed disturbed.  The operator must ensure that water temperatures at 100 m from the discharge points are compliant with the Water Quality guideline ecological threshold. This will confirm the performance of the discharge system and the numerical model predictions.  All records of discharge volumes and quality are to be kept for auditing purposes.

Air Quality The combustion of gaseous fuel for steam production or electricity in a reciprocating engine with design capacity equal to or greater than 10 MW heat input per unit is a Listed Activity under Category 1: Combustion Installation, and sub-category 1.5: Reciprocating Engines. Minimum Emission Standards (MES) for reciprocating engines using gas are set for NOX and particulates, but not for SO2. The MES are shown in Table E1 with the proposed emission concentrations for the Karpowership engines. It appears that emission standards are not prescribed for steam turbines with a capacity of less than 50 MW.

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Table 8-1 Minimum Emission Standards in mg/Nm3 for Reciprocating Engines

The Karpowership Project at the Port of Saldanha Bay comprises the Powership, the FSRU and the LNG supply vessel. Each engine and the steam turbines have a dedicated stack, or point source. On the Khan Class Powership, the 21 stacks are orientated along the vessel from bow to stern. LNG supply vessels will restock the FSRU approximately every 20 days. For the purposes of this assessment the emissions from the LNG resupply are regarded as fugitive emissions. Emissions result from the ship manoeuvring from the port entrance to the berth, and during the LNG transfer when berthed alongside the FSRU. Total annual emissions resulting from the Karpowership Project are listed in Table 8-2.

Table 8-2 Annual emissions from the Powership Project

The DEA approved CALPUFF dispersion model is used to predict ambient concentrations of SO2, NO2 and PM10 resulting from the Karpowership Project emissions. Modelling is done according to the DEA modelling regulations and 3-years of hourly surface and upper air meteorological data are used.

The closest residential area to the proposed site is Bluewater Bay, which is located adjacent to the western border of the Port and approximately 1.64 km from the proposed Karpowership Project at the Port of Saldanha Bay. The maximum predicted annual SO2, NO2 and PM10 concentrations and the 99th percentile concentration of the 24- hour and 1-hour predicted concentrations are very low relative to the NAAQS (Table 8-3).

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Table 8-3 Maximum predicted ambient annual SO2, NO2 and PM10 concentrations in μg/m3 and the predicted 99th percentile concentrations for 24-hour and 1-hour averaging periods, with the South African NAAQS

Ambient SO2, NO2 and PM10 concentrations at the Saldanha Bay monitoring station in Saldanha Bay are relatively low and below the NAAQS. The additive effect of the contribution from the Karpowership Project is likely to be small and the potential increase in ambient concentrations is unlikely to result in exceedances of the NAAQS. For predicted SO2, NO2 and PM10 the highest ambient concentrations are predicted to occur north of the Port of Saldanha Bay over parts of the Saldanha Bay industrial area and open land, and south of the project area towards the Port entranced and the Atlantic Ocean. While the contribution from the Karpowership Project emissions will add to the relatively low existing ambient concentrations, the added effect is small and will not result in exceedances of the NAAQS.

The NEMA EIA Regulations (DEA, 2014a) describe the significance of environmental impacts considering the consequence of the impact and the likelihood of the impact occurring. The consequence of an impact is the sum of the severity of the impact, the duration of the impact and spatial scale of the impact. The rating of these parameters is based on the findings of the assessment and professional judgement of specialists. The likelihood of an impact is the sum of the sum of the frequency of the activity causing the impact and the probability of the impact occurring.

With low predicted ambient concentrations for SO2 and PM10 the consequence of impacts is very low. The predicted ambient NO2 are somewhat higher, but the consequence of the impact is low. The likelihood of occurrence of impacts associated with SO2, NO2 and PM10 is very low. Therefore, the significance of impacts resulting from the Karpowership Project is predicted to be very low. The consequence and likelihood scores listed in Table E4 for the Karpowership Project with the Project adding to existing ambient concentrations, showing the impact significance.

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Table 8-4 Air quality impact scores

From an air quality perspective, it is the reasonable opinion of the specialists that the project should be authorised considering the findings of this assessment.

Heritage, Archaeology and Palaeontology Findings The route options are not distinguished by differing palaeontological sensitivities and do not differ in their impacts.

Recommendations It is recommended by the specialist that monitoring is undertaken during the construction of the transmission line. A Fossil Finds Procedure was provided so that the earth works personnel can be involved in mitigation by watching for fossils. Workers seeing potential objects are to cease work at that spot and to report to the field supervisor who, in turn, will report to the Environmental Control Officer (ECO). The ECO will contact the palaeontologist or archaeologist contracted to be on standby in the case of finds. The latter will liaise with Heritage Western Cape on the nature of the find and suitable consequent actions such as an immediate site inspection, application for a palaeontological collection permit and the drafting of a work plan for the collection of the find. If a significant occurrence of fossil bones or shells is discovered a professional palaeontologist must be appointed to collect them and to record their contexts. The palaeontologist must also undertake the recording of the stratigraphic context and sedimentary geometry of the exposure and the compilation of the report to Heritage Western Cape and the IZIKO S.A. Museum.

Risk Assessment The proposed LNG operations were modelled for this Risk Assessment. The main risk contributing part of the operation is the possible rupture of one of the transfer hoses. The risks were found to be acceptable for the Port and normal Port operations can continue at the other berths while LNG is being offloaded at the facility.

Recommendations  There must be an Operations Manual for the transfer process;  The operations site must be considered an Major Hazardous Installation;  The Emergency Plan must be approved by the Port Authorities. The risks will not impact on any other neighbouring flammable installations;

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 Only suitably qualified people must be used for all operations;  The visiting Ship Captains must provide Port Management with their detailed STS Operations Manual before offloading;  All equipment, including radios used within the operations area, must be intrinsically safe;  Service Logbooks must be kept for all hoses and pipelines and checked regularly;  The Port Fire Department will handle all fire-fighting and emergencies

Socio-Economic

The proposed Powerships and their associated infrastructure will generate both positive and negative impacts starting from the construction period and ending with the decommissioning phase. The following paragraphs and tables summarise the key socio-economic impacts that were identified to have the potential to occur during the different phases.

Construction During the construction phase, the proposed Powerships and their associated infrastructure will have both positive and negative effects on the socio-economic environment.

The project is anticipated to make a notable contribution towards the national and local economy. It is estimated that a total of R154.7 million of new business sales, R324.3 million of GDP and 1 525 FTE employment positions will be generated by the project in the national economy through multiplier effects. Aside from the above positive effects, the project will contribute to skills development in the country, increase government revenue, as well as raising household earnings. The increase in household earnings is also likely to improve the standards of living of the affected households albeit temporarily.

Aside from the positive impacts though, the project will be creating negative direct, secondary and cumulative impacts on the local communities, specifically areas surrounding the site where the proposed facility is to be built. The main factors that will cause this negative impact are (1) the influx of workers and job seekers from outside of the local community, (2) the impact on the surrounding economic and social infrastructure and (3) the limited visual and noise disturbances that could be created by the construction activities as the footprint of the facility grows. Potential negative impacts can largely be mitigated, and their significance reduced. The minimal visual impacts anticipated, however, cannot be fully eliminated although it is also possible to reduce their significance.

Operations During the operation of the proposed Powerships and their associated infrastructure the socio-economic impacts are likely to last longer when compared to those observed during the construction phase. This is the case for both positive and negative effects.

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The total impact on production in the country as a result of the Powerships and their related infrastructure’s operations will equate to R419.7 million in 2020 prices per annum. Aside from the utilities sector, industries that will experience the greatest stimulus from the project will include electrical machinery and apparatus, insurance, and transport service. Due to the annual spending on labour and procurement of local goods and services required to operate of the Powerships and related infrastructure (i.e., utilities, sundries, certain electrical components, etc.), the majority of the new business will be generated on an annual basis in the WCDM through the multiplier effects. Only a small proportion of the annual production resulting from the facilities operations will be accounted for in other parts of the country, including the Western Cape. This is under the assumption that the revenue generated by the project is accounted for in the WCDM, rather in the province where the headquarters of the developer are located.

It is estimated that the project will directly generate R94.4 million of value add per annum. Through indirect and induced effects, an additional R160.6 million of GDP will be generated per annum, which means that the total impact of the project on the national GDP will equate to R254.9 million per annum in 2020 prices.

The operation of the proposed Powerships and their associated infrastructure will generate R88.6 million of new business sales, contribute R254.9.0 million to GDP and create 240 sustainable FTE employment positions. In addition, government revenue will rise, electricity supply will be increased, and various socio-economic and enterprise development initiatives will be undertaken from the revenue generated by the development. These funds will be allocated towards socio-economic development in the area and are expected to bring a significant benefit to local communities. Several small fishermen spoken to during the study have raised concerns about the impact of the proposed development, given that they fish in and around the Port of Saldanha and that this activity is their only form of livelihood. The effects on the community’s sense of place will initially be felt during the construction period and will continue into the operational phase. The assessment of the negative change in the sense of place provided for the construction phase will be almost identical to that of the operational phase.

Negative impacts include the potential changes in the sense of place. These potential losses, if they do occur, are likely to be small, given the industrial nature of the proposed development area. As in the case with the impacts observed during construction, negative effects can be mitigated, and positive impacts enhanced. Mitigation of the negative impacts though will not result in their complete elimination as visual disturbance of the nature inherent to the project are difficult to eradicate entirely. Nevertheless, the significance ratings of the negative impacts are expected to be reduced.

Based on the information presented in this report, it is evident that the net positive impacts associated with the development and operation of the proposed Powership and their associated infrastructure are expected to outweigh the net negative effects. The policy reviewed supports the proposed development form a planning perspective as it will contribute to the development of the economic and social environment of the region. The project is envisaged to have a positive stimulus on the local economy and employment creation, leading to the economy’s diversification and a small reduction in the unemployment rate. The project should therefore be considered for development. Page 127

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No fatal flaws were identified as part of the socio-economic assessment.

It should, however, be acknowledged some negative impacts may arise and that these will largely be borne by households in proximity to the development. The limited number of such households within close proximity to the development will help to notable reduce this impact.

Equally it needs to be noted that many of the positive impacts will be concentrated in the local and national economies, creating a potential imbalance with the potential negative impacts that would exclusively be concentrated at a local level.

Due to this imbalance, it is recommended that the mitigation measures suggested being strictly adhered. Application of these mitigation measures will ensure that the negative impacts on nearby households will be significantly minimised and that the distribution of the potential benefits of the project are more balanced.

Landscape and Visual Impact Assessment The proposed grid connection will involve the development of a new overhead 132kV power line approximately 7km long between the existing Iron Ore and Oil Jetty within the port and the Blouwater Substation.

The proposed Powership and FSRU are large industrial ships that will be located within the port. Whilst they will include industrial superstructure that is not typical of most shipping that visits the port, they are essentially ships within a busy port. It was also noted that the port is becoming increasingly important for oil and gas exploration and that drilling ships and rigs are often seen in the port.

The proposed 132kV overhead power line will be located within an existing infrastructure corridor that includes a rail link and overhead power lines including the High Voltage Aurora to Blouwater power line. The project will therefore not introduce elements that are out of keeping with existing development.

From the assessment the following potential landscape and visual impacts have been identified:  The project has the potential to bring industrial / port elements closer to the settlements, beach areas on the eastern side of the Bay including Langebaan and Mykonos;  The proposed project could intensify visual impacts associated with industrial / port elements on the Saldanha beach and adjacent residential area; and  3The project could intensify the visual impact of infrastructure in close proximity to the existing infrastructure corridor between the Iron Ore and Oil Jetty and the Blouwater Substation.  The Project could intensify the Visual Impact of Infrastructure in close proximity to the existing infrastructure corridor between the Iron Ore and Oil Jetty and the Blouwater Substation.

The landscape architect concluded that the identified visual impacts are all likely to be insignificant. There is no reason from a landscape and visual impact perspective why the proposed project should not proceed. Page 128

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Noise

Findings The impact of the noise pollution that can be expected from the site during the construction and operational phase will largely depend on the climatic conditions at the site. The noise impact will be the most significant during calm meteorological conditions when little wind noise masking will occur, therefore the wind speed and direction was not considered in the modelling.

The field study results showed that the ambient noise levels in the area of the proposed development was 54.9 dB(A). Noise sensitive area (NSA) 2 is approximately 1280m away from the nearest pipeline location. Taking this distance and the impact statement for the construction phase into consideration, it can be inferred that NSA 2 will experience noise levels of 49 dB(A).

With the effective implementation of the above recommended mitigation measures, the residual noise impact associated with construction activities are predicted to be of very low significance. It is recommended that the ambient noise around the project and at the closest receptors be monitored during the construction phase.

Figure 8-4 Predicted noise levels during the operational phase of the project

The modelling results are only for noise from the operational activities and exclude other noise sources around the site, such as road traffic and the noise in the existing port areas, which are part of the existing ambient noise (therefore all points where negative values are computed are shown as zero as the noise is attenuated by distance). Furthermore, the effects of wind noise have been ignored, as the highest impact will be under calm atmospheric

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. conditions. Other weather conditions considered were a temperature of 20°C and 70% relative humidity. The infrastructure is predicted to be 100% operational 80% of the time. The modelling results are valid for the terrestrial impacts only and does not apply to the underwater impacts.

Figure 8-5 Noise Level at receivers during operational phase

The operational noise levels of the proposed project exceed the SANS 10103:2008 rating limits for a number of the human receptors. The results indicate that, from a noise perspective, the Big Bay site would have less of an impact on NSAs in the area. The noise impact associated with the operational activities of the proposed project is predicted to be of Medium-Low significance after mitigation at the Port of Saldanha.

The results of the noise impact assessment of the proposed Gas to Power - Powership Project within the Port of Saldanha shows that a number of the terrestrial receptors (refer to Table 9), the SANS 10103:2008 rating limits will be exceeded, especially the sensitive residential areas, such as Blue Bay Lodge. Modelling of the Big Bay alternative indicates that the NSAs will be less impacted and thus, from a noise perspective, would be the preferred site option. It is not anticipated that there will be complaints from the industrial areas. The noise impact associated with the operational activities of the proposed project is predicted to be of Medium-Low significance after mitigation at the Port of Saldanha. The construction related noise impacts will be of Very- Low significance.

The following is highly recommended:  The noise impacts are re-modelled when the final design of the infrastructure and methods of construction is determined. This will enable extra noise mitigation measures to be determined before the equipment is finally installed.  Install acoustic enclosures around all major noise emitting components to supress the noise emissions from equipment such as engines, exhaust stacks etc.  Install silencers on equipment such as exhaust stacks outlets and all air outlets and inlets.  A separate study should be considered to determine the impact on the marine environment. This should include the impact of anthropogenic noise on any protected terrestrial species within Saldanha Bay, as well as the underwater noise impacts on marine animals.  Periodic noise measurements are taken during the construction and operational phases. Page 130

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 A long-term hydrophone system is installed in the vicinity of the FSRU, LNGC berth, harbour entrance and other sensitive areas in Saldanha Bay to determine the current underwater noise environment.

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IMPACT ASSESSMENT FINDINGS

Assessment of the significance of each impact, risk and an indication of the extent to which the issue and risk can be avoided or addressed by the management actions.

The assessment of the significance of potential impacts, including the extent to which impacts can be avoided or mitigated, is included in this section and Appendix C.

The following potential impacts have been considered in the EIA Phase for the proposed project:

Terrestrial Ecological Impacts The site is mostly of low sensitivity due to the wide distribution of modified and degraded habitats and the alignment of the transmission line route with existing infrastructure. This places the route primarily within transformed or modified habitat, resulting in little overall loss of indigenous vegetation. Impacts are Medium and can be reduced to Very Low significance with the recommended mitigation measures.

The updated layout includes land-based gas pipelines and a temporary laydown area located on the beach and within the Saldanha Dune Strandveld. This vegetation will be lost, and there will be impacts to the dynamic dune system and associated successional vegetation. As this area was not assessed in field by the specialist (not part of the layout at the time of the site visit), a comprehensive impact rating cannot be made. The impact on the Saldanha Dune Strandveld, if the precautionary approach is taken, will be a high negative. It is not recommended to place any infrastructure within beach and dune areas and such development components should be relocated to disturbed areas. It is recommended that the dune areas be assessed in the field prior to any construction taking place; and that alternatives be considered for the placement of this infrastructure within, in order of preference, already transformed, degraded or disturbed areas.

The transmission line alternatives were assessed in the same impact assessment tables for the construction and operation phases as the minor differences in the route alignments posed no significant changes in the scoring of the impacts.

8.4.1.1 Impact assessment findings (with and without mitigation): Transmission Line Alternatives 1 and 2: Construction Phase The impact of the loss of the Saldanha Flats Strandveld in the construction phase will be short-term, with a significant severity within the site extent resulting in a Medium negative significance. With mitigation measures, this impact can be reduced to a small impact over the short term, with a significance of Low negative. With regards to the loss of transition vegetation the impact will be short-term, within the site extent, with a small severity rating resulting in a Medium-Low negative significance. With mitigation measures, this impact can be reduced to an insignificant impact over the short term, with a

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. significance of Very Low negative. The loss of Species of Conservation Concern will be permanent, of national extent and probable, with a harmful severity resulting in a High negative significance. With mitigation measures, this impact can be reduced to an insignificant impact over the short term, with a significance of Low negative. The loss of biodiversity in general will be short-term, within the site extent, with an insignificant severity resulting in a Low negative significance. With mitigation measures, this impact can be reduced to a significance of Very Low negative. Fragmentation will be permanent, of national extent with a high likelihood, and a significant severity resulting in a Medium-High negative significance. With mitigation measures, this impact can be reduced to an insignificant impact over the short term, with a significance of Very Low negative. The invasion of alien species will be permanent, of national extent, with a significant severity resulting in a High negative significance. With mitigation measures, this impact can be reduced to insignificant impact over the short term, with a significance of Very Low negative.

Overall Overall Risk/ Aspect Significance - Significance - Activity Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Construction of Loss of Saldanha Medium  No construction or storing of materials should be located Low transmission line and Flats Strandveld outside of the defined construction area. These areas should be laydown areas demarcated prior to any activities commencing and personnel instructed of the rules to stay out of these areas (unless clearing alien invasive plants).  Development and implementation of an alien invasive plant species management plan, which would remove and control the alien vegetation within and bordering the site.  Keep the construction footprint as small as possible.  No use of the surrounding vegetation should be allowed. This includes use as a toilet facility, for hunting, harvesting of indigenous plants, making fires etc.  Construction of the proposed monopole structures should be executed using the least impactful methods as far as is practicable. Ideally, this should be the avoidance of clearing of servitudes, but rather the erection of each individual pole, reducing the footprint as far as possible.

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Overall Overall Risk/ Aspect Significance - Significance - Activity Description Pre Mitigation Of Impacts Post Construction of third Loss of transition Medium-Low  No construction or storing of materials should be located Low section of transmission vegetation outside of the defined construction area. These areas should be line demarcated prior to any activities commencing and personnel instructed of the rules to stay out of these areas (unless clearing alien invasive plants).  Development and implementation of an alien invasive plant species management plan, which would remove and control the alien vegetation within and bordering the site.  Keep the construction footprint as small as possible. No use of the surrounding vegetation should be allowed. This includes use as a toilet facility, for hunting, harvesting of indigenous plants, making fires etc.  Construction of the proposed monopole structures should be executed using the least impactful methods as far as is practicable. Ideally, this should be the avoidance of clearing of servitudes, but rather the erection of each individual pole, reducing the footprint as far as possible. Construction of the Loss of Species of High  Construction measures must consist of the least impactful Low transmission line, Conservation individual erection of monopole structures and all protected laydown area and Concern species avoided where possible. switching station  Micro siting of the monopole structures and construction footprint should be done to ensure no protected species are affected wherever practicable.  No use of the surrounding vegetation should be allowed. This includes use as a toilet facility, for hunting, harvesting of indigenous plants, making fires etc.  A full site walk-through should be conducted in the summer prior to any construction activities to list all SSC and associated permits should be obtained for their removal or transplantation. Page 134

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Overall Overall Risk/ Aspect Significance - Significance - Activity Description Pre Mitigation Of Impacts Post All SCC must be compensated for at a ratio of at least 3:1 either in gardens or as part of restoration and conservation efforts within the Saldanha Bay IDZ. INDIRECT IMPACTS Construction of the Loss of biodiversity Low  Boundaries should be strictly maintained, and impacts retained Very Low transmission line, in general within the boundary of the site. laydown area and  Development and implementation of an alien invasive plant switching station species management plan, which would remove and control the alien vegetation within and bordering the site. Restoration of areas utilized during construction, but not operation, should be considered in conjunction with the IDZ. Loss of dispersal, Fragmentation Medium-High  The majority of the indigenous vegetation should be maintained Very Low pollination and gene as a part of the open space and managed for conservation if issues during possible, in partnership with Transnet and the IDZ. construction  Boundaries of the site should be adhered to, and no additional loss of vegetation should occur.  Development and implementation of an alien invasive plant species management plan, which would remove and control the alien vegetation within and bordering the site. The land beneath the transmission line, and any other areas required for construction, but not for the operational phase, should be rehabilitated with indigenous species to retain connectivity within the system. INDIRECT IMPACTS Construction of Invasion of alien High  The area of construction and operation should be demarcated, Very Low transmission line, species and personnel not allowed to use the surrounding natural laydown area and vegetation. switching station

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Overall Overall Risk/ Aspect Significance - Significance - Activity Description Pre Mitigation Of Impacts Post  Any existing and new alien species must be removed as soon as possible after emergence. An alien vegetation management plan must be applied to the site to maintain the site free of alien invasions throughout the construction and operational phase of the development.

8.4.1.2 Impact assessment findings (with and without mitigation): Transmission Line Alternatives 1 and 2: Operation Phase In the operational phase, the impact of the loss of the Saldanha Flats Strandveld will be short-term, within the site extent with a significant severity resulting in a High negative significance. With mitigation measures, this impact can be reduced to a probable small impact over the short term, with a significance of Low negative. With regards to the loss of transition vegetation, the impact will be short-term, within the site extent and with a small severity resulting in a Medium-High negative significance. With mitigation measures, this impact can be reduced to a probable insignificant impact over the short term, with a significance of Low negative. The loss of Species of Conservation Concern will be permanent, of national extent with a significant severity resulting in a High negative significance. With mitigation measures, this impact can be reduced to an improbable insignificant impact over the short term, with a significance of Low negative. The loss of biodiversity in general will be permanent, within the site extent and with an insignificant severity resulting in a Low negative significance. With mitigation measures, this impact can be reduced to a significance of Low negative. Fragmentation will be permanent, of national extent and probable, with a significant severity resulting in a Medium negative significance. With mitigation measures, this impact can be reduced to an improbable insignificant impact over the short term, with a significance of Low negative. The invasion of alien species will be permanent, of national extent and with a significant severity resulting in a Medium-Low negative significance. With mitigation measures, this impact can be reduced to an insignificant impact over the short term, with a significance of Very Low negative.

Overall Overall Risk/ Aspect Significance - Significance - Activity Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Construction of Loss of Saldanha Medium-High  No construction or storing of materials should be located Low transmission line and Flats Strandveld outside of the defined construction area. These areas should be laydown areas demarcated prior to any activities commencing and personnel instructed of the rules to stay out of these areas (unless clearing alien invasive plants).

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Risk/ Aspect Significance - Significance - Activity Description Pre Mitigation Of Impacts Post  Development and implementation of an alien invasive plant species management plan, which would remove and control the alien vegetation within and bordering the site.  Keep the construction footprint as small as possible.  No use of the surrounding vegetation should be allowed. This includes use as a toilet facility, for hunting, harvesting of indigenous plants, making fires etc.  Construction of the proposed monopole structures should be executed using the least impactful methods as far as is practicable. Ideally, this should be the avoidance of clearing of servitudes, but rather the erection of each individual pole, reducing the footprint as far as possible. Construction of third Loss of transition Medium-High  No construction or storing of materials should be located Low section of transmission vegetation outside of the defined construction area. These areas should be line demarcated prior to any activities commencing and personnel instructed of the rules to stay out of these areas (unless clearing alien invasive plants).  Development and implementation of an alien invasive plant species management plan, which would remove and control the alien vegetation within and bordering the site. Keep the construction footprint as small as possible. No use of the surrounding vegetation should be allowed. This includes use as a toilet facility, for hunting, harvesting of indigenous plants, making fires etc.  Construction of the proposed monopole structures should be executed using the least impactful methods as far as is practicable. Ideally, this should be the avoidance of clearing of servitudes, but rather the erection of each individual pole, reducing the footprint as far as possible. Page 137

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Risk/ Aspect Significance - Significance - Activity Description Pre Mitigation Of Impacts Post Construction of the Loss of Species of High  Construction measures must consist of the least impactful Low transmission line, Conservation individual erection of monopole structures and all protected laydown area and Concern species avoided where possible. switching station  Micro siting of the monopole structures and construction footprint should be done to ensure no protected species are affected wherever practicable.  No use of the surrounding vegetation should be allowed. This includes use as a toilet facility, for hunting, harvesting of indigenous plants, making fires etc.  A full site walk-through should be conducted in the summer prior to any construction activities to list all SSC and associated permits should be obtained for their removal or transplantation. All SCC must be compensated for at a ratio of at least 3:1 either in gardens or as part of restoration and conservation efforts within the Saldanha Bay IDZ. INDIRECT IMPACTS Construction of the Loss of biodiversity Low  Boundaries should be strictly maintained, and impacts retained Low transmission line, in general within the boundary of the site. laydown area and  Development and implementation of an alien invasive plant switching station species management plan, which would remove and control the alien vegetation within and bordering the site.  Restoration of areas utilized during construction, but not operation, should be considered in conjunction with the IDZ. Loss of dispersal, Fragmentation Medium  The majority of the indigenous vegetation should be maintained Low pollination and gene as a part of the open space and managed for conservation if issues during possible, in partnership with Transnet and the IDZ. construction  Boundaries of the site should be adhered to, and no additional loss of vegetation should occur.

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Overall Overall Risk/ Aspect Significance - Significance - Activity Description Pre Mitigation Of Impacts Post  Development and implementation of an alien invasive plant species management plan, which would remove and control the alien vegetation within and bordering the site. The land beneath the transmission line, and any other areas required for construction, but not for the operational phase, should be rehabilitated with indigenous species to retain connectivity within the system. Construction of Invasion of alien Medium-Low  The area of construction and operation should be demarcated, Very Low transmission line, species and personnel not allowed to use the surrounding natural laydown area and vegetation. switching station  Any existing and new alien species must be removed as soon as possible after emergence.  An alien vegetation management plan must be applied to the site to maintain the site free of alien invasions throughout the construction and operational phase of the development.

Avifaunal Impacts No high-risk or medium-risk areas were found along the walked power lines that parallel the proposed transmission line route alternatives. This was based on both the low frequency of live birds in flight (comprising some Yellow-billed Kites, Sacred Ibis and little else in the farmland), and the low number of bird carcasses found under nine kilometres of the existing power line.

The transmission line alternatives were assessed in the same impact assessment tables for the construction and operation phases as the minor differences in the route alignments posed no significant changes in the scoring of the impacts.

8.4.2.1 Impact assessment findings (with and without mitigation): Transmission Line Alternatives 1 and 2: Construction Phase There will be a Low negative impact of small severity due to avoidance of the area (due to human activity, noise, predation threat, iron ore dust) due to construction of the new power line for the Red-listed bird groups. The shorebirds, ibises, kites and other collision-prone species may be disturbed due to

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. anthropogenic activity caused on the ground during the construction phase of the grid infrastructure. This can be mitigated by reducing the extent of construction disturbance in the areas at times of highest shorebird density (September-April), resulting in a Low negative significance.

Overall Overall Risk/ Aspect Significance - Significance - Activity Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Construction of Avoidance of the Low Reduce the extent of human disturbance to around the line itself Low transmission line area (due to human (i). within the 300-m corridor allocated); activity, noise, (ii) avoid any active nests (some ground-nesters may be found on predation threat, the beach); iron ore dust) due to (iii) avoid polluting the area with plastics or human waste – all construction of the material to be disposed of in suitable sites. new power line for the Red-listed bird groups

8.4.2.2 Impact assessment findings (with and without mitigation): Transmission Line Alternatives 1 and 2: Operational Phase There will be a Low negative impact of small severity due to direct impact mortality (or avoidance of area) around any new power line for the Red-listed bird groups identified as at risk above. Migratory shorebirds or terms are the most likely to be impacted by overhead power lines. They are more likely to be due to the disturbance caused on the ground during the construction phase of the grid infrastructure. These impacts can be mitigated to a Low negative significance by staggering the pylons of the proposed line adjacent to the existing Eskom 132 kV to make all lines more visible, and installing bird diverters along all sections, and by marking all future lines as they are constructed.

Overall Overall Risk/ Aspect Significance - Significance - Activity Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Operation of Mortality from Low (i) Micro-adjust the 132 kV line route alongside the existing Low transmission line collision with Aurora-Blouwater line and stagger the pylons to increase visibility transmission line for all birds on site; (ii) add bird diverters or spirals (diurnal and nocturnal) to all new

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Overall Overall Risk/ Aspect Significance - Significance - Activity Description Pre Mitigation Of Impacts Post lines, to reduce fatality rates by 50% (iii) ensure all electrical infrastructure is bird-friendly to avoid electrocutions

Wetland Impacts No impacts to wetlands were identified. It was determined during the initial risk screening that no watercourse (wetland/riverine) system will be at risk as a result of the proposed development.

The Estuary/Port will most probably be at risk due to certain activities associated with the proposed development occurring within these waters, however, impacts related to this watercourse is out of the ambient of the Wetland Specialist knowledge set and will have to be assessed further by an Estuarine Ecologist/Marine Specialist.

The specialist further recommends that all construction activities of the proposed development can occur but must take into cognizance the surrounding biodiversity in the area that was regarded as sensitive by the Terrestrial Ecologist. Furthermore, the mitigation measures outlined in this report are to be included in the EMPr, and must be followed.

Hydropedological Impacts Several hydropedological risks were identified for the construction and operational phase of the transmission line. The risk associated with the construction and operational phase is estimated to be Medium-Low to Low and decrease to Very Low after consideration of proposed mitigation measures.

Due to the project type (i.e. linear development over a large area, where only a small soil area will be disturbed) no impacts on the suppression of hydropedological flow drivers are anticipated. No wetland areas were identified in the vicinity of the proposed development. Based on the project type, no hydropedological flow buffers will be required.

The transmission line alternatives were assessed in the same impact assessment tables for the construction and operation phases as the minor differences in the route alignments posed no significant changes in the scoring of the impacts.

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8.4.4.1 Impact assessment findings (with and without mitigation): Transmission Line Alternatives 1 and 2: Construction Phase Construction phase impacts will occur as a result of site preparation, including placement of contractor laydown areas and storage (i.e. temporary stockpiles, bunded areas etc.) facilities. This will have a Low impact on the hydropedology but can be mitigated to Very Low by keeping a small footprint of disturbance. Soil excavations / infilling activities will have a Medium-Low impact on the vadose zone. The in-situ placement of new soils will alter existing soil-flow processes (i.e. infilling of wetlands and cut-and-fill areas) and cause the compaction of soil resulting in a Low negative significance. Soil contamination will occur from leakages from vehicles and machines, and building materials and will also result in a Low negative significance. Vegetation loss could decrease soil infiltration and increase runoff, with Low negative significance. All pre-mitigation impacts were rated between Medium-Low and Low, and can all be mitigated to Very Low by implementing the mitigation measures outlined by the Hydropedologist.

Overall Overall Significance - Significance - Activity Risk/ Aspect Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Soil excavations /  Disturbing vadose zone. Medium-Low  Only excavate areas applicable to the Very Low infilling activities  Alteration to natural hydropedological project area. flow paths. Backfill the material in the same order  Impacts on macro-soil structure. it was excavated to reduce Impacts on the hydropedological contamination of deeper soils with processes supporting the watercourses. shallow oxidised soils;  Cover excavated soils with a temporary liner to prevent contamination. In-situ placement of Altering existing soil-flow processes. Low  Only excavate areas applicable to the Very Low new soils Compaction of soil. project area. Backfill the material in the same order it was excavated to reduce contamination of deeper soils with shallow oxidised soils.  Cover excavated soils with a temporary liner to prevent contamination. Keep the site clean of all general and domestic wastes.

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Overall Overall Significance - Significance - Activity Risk/ Aspect Description Pre Mitigation Of Impacts Post Oil & fuel spills from Poor soil quality or contamination of soil Low  Visual soil assessment for signs of Very Low vehicles installing the contamination at vehicle holding, transmission line parking and activity areas.  Have emergency fuel & oil spill kits on site. INDIRECT IMPACTS Site preparation,  Exposure of soils, leading to increased Low All development footprint areas to remain Very Low including placement of runoff from cleared areas and erosion of as small as possible and vegetation contractor laydown the watercourses, and thus increased clearing to be limited to what is essential. areas and storage (i.e. the potential for sedimentation of the Exposed soils to be protected using a temporary stockpiles, watercourses suitable covering or re-vegetating. Have bunded areas etc.)  Loss of vegetation. emergency fuel & oil spill kits on site. facilities  Compaction of soils; Vegetation clearing &  Natural nutrient content decreases due Low All development footprint areas to remain Very Low soil stockpiling to soil exposure. as small as possible and vegetation  Loss of natural bio-organisms essential clearing to be limited to what is essential. to soil processes. Retain as much indigenous vegetation as possible.

8.4.4.2 Impact assessment findings (with and without mitigation): Transmission Line Alternatives 1 and 2: Operational Phase Disturbing the inner-soil architecture of the original soil profile will have harmful severity by infilling wetlands, altering natural hydropedological flow paths, soil structure leading to a Medium-Low negative impact significance. Implementing mitigation measure will reduce inter alia the severity to potentially harmful and thereby reducing the impact significance to Low negative. Alterations to natural soil flow processes will result from excavations and soil stockpiling during any maintenance work being undertaken on the transmission line. Soil & surface water contamination as well as sedimentation can result from oil & fuel leakages from maintenance and service vehicles, and/or spillages from transformers. Similar to the construction phase, all pre- mitigation impacts were rated between Medium-Low and Low, and can all be mitigated to Low and Very Low by implementing the mitigation measures outlined by the Hydropedologist.

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Overall Overall Significance - Significance - Activity Risk/ Aspect Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Disturbing the inner-  Infilling of wetlands and watercourses Low Revegetate areas (with vegetation growing Low soil architecture of the inducing alternative flow paths. at the site) where heavy machinery was original soil profile Alteration to natural hydropedological used to excavate the soils to prevent flow paths. erosion. Cover excavated soils to be  Impacts on macro-soil structure. protected using a suitable covering.  Impacts on the hydropedological processes supporting the watercourses Oil & fuel spills from Poor soil quality Very Low Have emergency fuel & oil spill kits on Very Low vehicles conducting site. maintenance of the transmission lines INDIRECT IMPACTS Excavated soil will be This will have an impact on the flow Low Cover excavated soils to be protected Very Low placed in other areas dynamics of the soil it is dumped on top of, using a suitable covering. (i.e. on top of other and may reduce rainfall infiltration and soils) induce runoff.

River and Riparian (Aquatic) Impacts The quality of the instream and riparian habitat has a direct influence on the aquatic community. Evaluating the structure and functioning of an aquatic ecosystem must therefore take into account the physical habitat to assess the ecological integrity. Considering the absence of any surface watercourses near the proposed transmission line alternatives and the linear nature of the project, the in situ Water Quality, Integrated Habitat Assessment Index, and SASS5 results could not be obtained. It was therefore concluded that there will not be any impacts on the aquatic environment.

Surface Water (Hydrology) Impacts Since there are no nearby surface water bodies at the proposed Saldanha Bay development site, it can be concluded that there is no risk posed to surface water in the area (i.e. no recognized water bodies exist). For a limited time during the year, during the rainy season, limited runoff from the site will occur that may transport sediment and contaminants to the soils, aquifers and regional areas. A Stormwater Management Plan will be required for the main Page 144

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. construction to mitigate the impact of this runoff. There will be other risks associated with this development that have been assessed in the Geohydrology and Hydropedology sections.

Groundwater Impacts The risk and impact assessment undertaken suggest that the potential geohydrological impact at the site (quantity and quality) is low-marginal. Risks during the construction phase is low and can be considered reversible impacts. Marginal impacts are anticipated for the operational phase of the transmission lines, pylons, and subsequent transforms connecting the Karpowership to the electricity grid. No decommissioning phase is anticipated for this project. However, similar risks as for the construction phase are anticipated if the facilities at the site are ever decommissioned; or if additional facilities are constructed.

The transmission line alternatives were assessed in the same impact assessment tables for the construction and operation phases as the minor differences in the route alignments posed no significant changes in the scoring of the impacts.

8.4.7.1 Impact assessment findings (with and without mitigation): Transmission Line Alternatives 1 and 2: Construction Phase Impacts to groundwater will primarily occur as a result of earthworks. Impacts expected are waste pollution, excavation of parts of the vadose zone, and seepage and overland runoff from oil/fuel spills from construction vehicles. These Medium to Medium-High impacts can all be mitigated to Low.

Overall Overall Risk/ Aspect Significance Significance Aspect: Description -Pre Mitigation Of Impacts - Post DIRECT IMPACTS

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Risk/ Aspect Significance Significance Aspect: Description -Pre Mitigation Of Impacts - Post Earthworks Disturbing vadose zone Medium  Only excavate areas applicable to the project area. Low during soil  Backfill the material in the same order it was excavated to reduce excavations/construction contamination of deeper soils with shallow oxidised soils. activities.  Cover excavated soils with a temporary liner to prevent contamination.  Retain as much indigenous vegetation as possible. Exposed soils to be protected using a suitable covering or re- vegetating.

Earthworks Temporary dewatering of Low  Have appropriate dewatering systems in place. Low perched groundwater (if it  Dewater all groundwater to the nearest surface drain/watercourse. occurs) INDIRECT IMPACTS Earthworks Poor quality seepage from Medium  Park heavy machinery in lined areas and place drip trays under Low machinery used to vehicles at the site. excavate soils. Oil, grease  Visual soil assessments for signs of contamination, with collection and fuel leaks could lead and disposal of contaminated soil to hazardous waste disposal site. to hydrocarbon contamination of the vadose zone which could percolate to the shallow aquifer. OPERATIONAL PHASE DIRECT IMPACTS

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Risk/ Aspect Significance Significance Aspect: Description -Pre Mitigation Of Impacts - Post Operation of Poor quality seepage from Medium Installation of piezometric seepage boreholes if pollution is evident. The Low the sub-stations associated boreholes can be positioned downstream of the transmission lines. transmission with the transmission line Park service vehicles in lined areas and place drip trays under vehicles line and parking of service at the site. vehicles. Seepage may Visual soil assessments for signs of contamination. percolate into the shallow aquifer zone.

8.4.7.2 Impact assessment findings (with and without mitigation): Transmission Line Alternatives 1 and 2: Operational Phase The main impact during the operational phase is poor quality seepage from sub-stations and from parked vehicles servicing the sub-stations. This seepage may percolate into the shallow aquifer zone having a Medium impact. Visual soil assessments and installation of piezometric boreholes can mitigate this to a Low impact.

Overall Overall Risk/ Aspect Significance Significance Aspect: Description -Pre Mitigation Of Impacts - Post DIRECT IMPACTS Operation of Poor quality seepage from Medium Installation of piezometric seepage boreholes if pollution is evident. The Low the sub-stations associated boreholes can be positioned downstream of the transmission lines. transmission with the transmission line Park service vehicles in lined areas and place drip trays under vehicles line and parking of service at the site. vehicles. Seepage may Visual soil assessments for signs of contamination. percolate into the shallow aquifer zone.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Climate Change Impacts Climate changes that can negatively impact the proposed Powership at Saldanha Bay and its associated infrastructure will likely be those associated with extreme events. For permanently-moored infrastructure such as the Powership and FSRU, impacts from events such as extreme storms and coastal surges are of lower significance given their sheltered location within the port. The FSRU, located in Big Bay, is considered to be at marginally higher risk to damage from extreme events since it is located outside the breakwater of the main terminal. The LNGC vessel, which will transport fuel for the Powership via the FSRU, will likely be exposed to greater levels of risk from extreme events on the high seas. Mitigation measures that will lower the significance of the above-mentioned impacts for mobile vessels (i.e., the LNGC) include the proactive use of existing early-warning systems and international standard operating procedures for vessels operating in inclement weather, including evasive action where appropriate. The permanently-moored FSRU and Powership are less exposed to this risk, and consequently mitigation for these project components entails compliance with existing emergency protocols and disaster risk reduction procedures at the Port of Saldanha. Impacts relating to sea-level rise were not considered significant because most of the floating infrastructure associated with the project is not susceptible to changes in sea-level or coastal erosion; and ii) the location of the proposed activities within the heavily defended port will further mute the increasingly dynamic coastal processes expected with elevated sea-levels.

Current climate models show consensus on the increased incidence of extreme heat days, heat waves, extreme rainfall events and dry spells. Consequently, conditions which are favourable to the development and spread of wildfires will become more frequent during the lifespan of the project. In this regard, linear electrical infrastructure associated with the Powership is potentially at risk during the operation phase where climate change-induced extreme events such as droughts raise the risk of wildfires, particularly if a severe storm damages the towers and/or the transmission lines. The anticipated drier conditions and subsequent changes in vegetation combustibility could raise the risk of ignition further in this scenario.

The provision of reliable additional baseload capacity to the national grid and the Saldanha Special Economic Zone (SEZ) is likely to impact gross geographic product (GGP) directly and positively, and, to a lesser extent, gross domestic product (GDP) at a national level. Similarly, the proposed project will contribute to the realization of several identified adaptation needs as defined in the National Climate Change Response Policy (NNCRP) as well as South Africa’s Integrated Resource Plan (IRP) promulgated in 2019. Both policies promote the use of lower-carbon energy sources and the diversification of the national energy mix.

An indirect positive impact of the proposed project is that the adaptive capacity of local communities may be enhanced through more reliable electricity supply (with a lower carbon footprint than most of the national grid’s electricity sources), as well as the potential for improved economic and employment opportunities that are driven by the efficiency and growth of the SEZ.

8.4.8.1 Impact assessment findings (with and without mitigation): Powership and Transmission Line Alternatives 1 and 2: Construction Phase

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

The Liquefied Natural Gas Carrier (LNGC) is potentially physically at-risk during transportation and mooring/operation from a climate change perspective concerning the anticipated increase in frequency and intensity of extreme weather events such as hurricanes and tropical storms. Depending on the location of the LNG source, the LNGC vessel may suffer damage in the event of a severe storm en route to the Port of Saldanha, or — to a lesser degree — within the port. Physical climate change risk to the LNGC is therefore considered of Medium-low significance without mitigation, and of Low significance with mitigation.

During installation of the gas pipeline, a potential direct impact relates to infrastructural and/or equipment damage or failure in the event of a severe storm. The significance of this impact is, however, Low, since it is relatively easily mitigated to a significance rating of Very Low by restricting installation to suitable weather conditions.

Overall Overall Significance - Significance - Aspect: Risk/ Aspect Description Pre Mitigation Of Impacts Post DIRECT AND INDIRECT IMPACTS LNG CARRIER Damage to equipment and Use of early warning systems and infrastructure from extreme international standard operating procedures Physical climatic/weather events for vessels operating in inclement weather, Transportation Medium Low Low risk (direct) and/or long-term climate including evasive action trends during transportation (direct)

GAS PIPELINE FROM FSRU TO POWERSHIP - SUB-SEA Damage to equipment and Adherence to port safety regulations and infrastructure from extreme emergency procedures, account for extreme Physical Installation/ climatic/weather events Low events in pipeline design and location Very Low risk construction and/or long-term climate trends

8.4.8.2 Impact assessment findings (with and without mitigation): Powership and Transmission Line Alternatives 1 and 2: Operational Phase

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Given the proposed location of the LNGC adjacent to the main port, the vessel is slightly more exposed to extreme wind and wave conditions of marine origin than the Powership, but marginally so given the inherently sheltered character of the Saldanha Bay-Langebaan Lagoon complex. Physical climate change risk to the LNGC is therefore considered of Low significance without mitigation, and of Very Low significance with mitigation.

Much like the LNGC, the FSRU is potentially at-risk from the expected increase in frequency and intensity of extreme weather events such as hurricanes and coastal storm surges, i.e., physical risks. The proposed location for the FSRU, which is understood to be permanently moored, is alongside the LNGC, i.e., adjacent to the main port. Consequently, the FSRU is also somewhat more exposed to extreme wind and wave conditions of marine origin than the Powership, but marginally so given the inherently sheltered character of the Saldanha Bay-Langebaan Lagoon complex. Physical climate change risk to the FSRU is therefore considered to be of Medium-low significance without mitigation, and of Low significance with mitigation.

During operation of the gas pipeline from the FSRU to the Powership, a Medium-rated impact may occur if a sufficiently severe storm of marine origin impacts the port and lagoon, possibly damaging the pipeline and resulting in fugitive GHG emissions. Under storm conditions, it is possible that the structures may lead to localised erosion and accretion on opposite sides of the pipeline fixtures which may endanger the pipeline by undercutting. Similarly, to the construction phase, this impact can be mitigated to a Low significance using the precautionary principle in design and installation of the pipeline.

Operation of the Powership is likely to result in impacts during mooring and operation, as well as activities related to connection to the FSRU and gas pipeline. Much like the LNGC and the FSRU, the Powership is potentially exposed to the expected increase in frequency and intensity of extreme weather events and the subsequent physical risks. Given the location of the Powership within the main port area, this impact is rated as Very Low with mitigation measures applied. Similarly, impacts concerning connection with the FSRU and pipeline are also rated Very Low with mitigation. A positive impact — rated High — of the Powership operations is the addition of 415MW of baseload electricity to the national grid.

Direct climate change impacts concerning the transmission line project component include increased fire risk due to more arid conditions and potential changes in vegetation type/climate zone, as well as increased intensity and frequency of extreme weather events. These impacts are expected during the operational phase and can be mitigated to a Low significance relatively easily.

During operation, climate change-induced extreme weather events such as droughts are likely to raise the risk of wildfires, particularly if a severe storm damages the steel lattice towers and/or the transmission lines. Drier conditions and subsequent changes in vegetation combustibility could raise the risk of ignition further in this scenario. Nonetheless, the significance rating of the abovementioned impact is Low without mitigation, and Very Low with mitigation.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Significance - Aspect: Risk/ Aspect Description Significance -Pre Mitigation Of Impacts Post LNG CARRIER Mooring/operation Damage to equipment and Adherence to port safety regulations and infrastructure from extreme emergency procedures Physical climatic/weather events Very Low Very Low risk and/or long-term climate trends in-port (direct) FSRU Damage to equipment and Adherence to port safety regulations and infrastructure from extreme emergency procedures Physical Mooring/operation climatic/weather events Medium Low Low risk and/or long-term climate trends GAS PIPELINE FROM FSRU TO POWERSHIP - SUB-SEA Operation Damage to equipment and Implement quality, maintenance and infrastructure from extreme environmental controls. Physical climatic/weather events Medium Low risk and/or long-term climate trends POWERSHIP Damage to equipment and Low Adherence to port safety regulations and infrastructure from extreme emergency procedures Mooring/operation climatic/weather events Very Low Physical and/or long-term climate risk trends Damage to equipment and Adherence to port safety regulations and Connection to infrastructure from extreme Low emergency procedures Very Low FSRU climatic/weather events

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Significance - Aspect: Risk/ Aspect Description Significance -Pre Mitigation Of Impacts Post and/or long-term climate trends

Generation of electricity and Positive impact on regional and national Electricity provision of 415MW into the economy and community from reliable and generation: national grid. High (Positive) continuous electricity flow from the High (Positive) 415MW (direct) Powership.

Positive Increased local adaptive Community benefits from stable elctrical impacts Increased capacity through more supply and local economic growth community reliable electricity for the High (Positive) High (Positive) adaptation/resilien SEZ and resultant growth in ce (indirect) gross geographic product (GGP)

132KV TRANSMISSION LINES TO SUBSTATION Operation Increased fire risk due to Low Ongoing maintenance of servitude and more arid conditions and clearing of alien vegetation as per safety potential changes in protocols Physical vegetation type/climate Very Low risk zone, as well as increased intensity and frequency of extreme weather events 132kV STEEL LATTICE TOWERS

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Significance - Aspect: Risk/ Aspect Description Significance -Pre Mitigation Of Impacts Post Increased fire risk due to Low Ongoing maintenance of servitude and more arid conditions and clearing of alien vegetation as per safety potential changes in protocols Physical Operation vegetation type/climate Very Low risk zone, as well as increased intensity and frquency of extreme weather events

Estuarine Impacts The majority of the potential impacts associated with the project are likely to be highly localised, that is, in situ of the project components within the Port of Saldanha, and not anticipated to have a direct effect on the integrity and ecology of the lagoon. The inclusion of Big Bay as an alternative, while increasing the risk to the Langebaan Lagoon and MPA due to its closer proximity, is still a significant distance away. It also increases the risk to the berthed/moored powership by being outside of the relative protection of the enclosed harbour. As such this alternative is not recommended.

8.4.9.1 Impact assessment findings (with and without mitigation): Preferred Powership and Transmission Line Alternative: Construction Phase The coastal location of the proposed activity within a Port and linking via transmission line to Saldanha Bay Steel means that these activities will be inherently exposed to risks associated with natural and dynamic coastal processes that continually reshape the coastal zone, such as wind, waves and sediment movement. Potential impact on the dune systems along the beach to the southeast of the Sishen pier during the transmission line installation is deemed to be of Low negative significance with impacts limited to the construction area. Any increase in wind-blown sand, as a result of construction, can be mitigated through best practice methods maintaining the Low negative impact significance.

With regard to restriction of access, the majority of the infrastructure will be installed within the access-controlled Sishen pier and immediate operational area, so no change in coastal access is expected, as access is already restricted. The only potential access restriction would be in the vicinity of the portion of the proposed gas pipeline that lies on the beach west of the Sishen pier. Although the pipeline itself will not physically restrict access, it is assumed that this portion of the beach would be closed to the public during construction due to safety as well as security concerns. From a mitigation perspective, while access to the coast is considered a right in terms of the ICM Act, restriction of such access in the public interest (for safety and security reasons) and the availability of alternate access to the beach mitigates any impact on coastal users.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Solid waste is also anticipated to be generated by the construction of the transmission lines. If not properly managed and contained, these items will find their way onto the beach and into the surf zone resulting in a High negative impact. Any waste materials must be transported to appropriate disposal facilities in order to be mitigated to a Low negative impact significance.

Overall Overall Significance - Aspect: Risk/ Aspect Description Significance -Pre Mitigation Of Impacts Post DIRECT IMPACTS Construction activities Coastal pollution High Construction must be undertaken Low according to a site-specific approved Environmental Management Programme (EMPr) and must be monitored by an on- site environmental officer. All solid waste must be removed to an appropriate disposal facility. INDIRECT IMPACTS Coastal location of the proposed Impact of dynamic coastal Low  During the construction of the Very Low activity within a Port, and the link processes transmission lines, the removal of into the existing Dedisa endemic vegetation should be limited, Substation located however, invasive alien vegetation approximately 6 km inland from invasion in respect to disturbed areas the Port must be removed and controlled  Dust or sand suppression should be undertaken by watering down and limiting activity in windy conditions.

8.4.9.2 Impact assessment findings (with and without mitigation): Transmission Line Alternative 2: Construction Phase The coastal location of the proposed activity within a Port and linking via transmission line to Saldanha Bay Steel means that these activities will be inherently exposed to risks associated with natural and dynamic coastal processes that continually reshape the coastal zone, such as wind, waves and sediment movement. Potential impact on the dune systems along the beach to the southeast of the Sishen pier during the transmission line installation is Page 154

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. deemed to be of Low negative significance with impacts limited to the construction area. Any increase in wind-blown sand, as a result of construction, can be mitigated through best practice methods to Very Low negative impact significance.

With regard to restriction of access, the majority of the infrastructure will be installed within the access-controlled Sishen pier and immediate operational area, so no change in coastal access is expected, as access is already restricted. From a mitigation perspective, while access to the coast is considered a right in terms of the ICM Act, restriction of such access in the public interest (for safety and security reasons) and the availability of alternate access to the beach mitigates any impact on coastal users.

Solid waste is also anticipated to be generated by the construction of the transmission lines. If not properly managed and contained, these items will find their way onto the beach and into the surf zone resulting in a High negative impact. Any waste materials must be transported to appropriate disposal facilities in order to be mitigated to a Low negative impact significance. Overall Overall Significance - Aspect: Risk/ Aspect Description Significance -Pre Mitigation Of Impacts Post DIRECT IMPACTS Construction activities Coastal pollution High Construction must be undertaken Low according to a site-specific approved Environmental Management Programme (EMPr) and must be monitored by an on- site environmental officer. All solid waste must be removed to an appropriate disposal facility. INDIRECT IMPACTS Coastal location of the proposed Impact of dynamic coastal Low  During the construction of the Very Low activity within a Port processes transmission lines, the removal of endemic vegetation should be limited, however, invasive alien vegetation invasion in respect to disturbed areas must be removed and controlled

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Significance - Aspect: Risk/ Aspect Description Significance -Pre Mitigation Of Impacts Post  Dust or sand suppression should be undertaken by watering down and limiting activity in windy conditions.

8.4.9.3 Impact assessment findings (with and without mitigation): Powership Alternative 2 (Big Bay): Construction Phase The coastal location of the proposed activity within a Port and linking via transmission line to Saldanha Bay Steel means that these activities will be inherently exposed to risks associated with natural and dynamic coastal processes that continually reshape the coastal zone, such as wind, waves and sediment movement. Potential impact on the dune systems along the beach to the southeast of the Sishen pier is deemed to be of Low negative significance with impacts limited to the construction area. Any increase in wind-blown sand, as a result of construction, can be mitigated through best practice methods to a Very Low negative impact significance.

With regard to restriction of access, the majority of the infrastructure will be installed within the access-controlled Sishen pier and immediate operational area, so no change in coastal access is expected, as access is already restricted. The only potential access restriction would be in the vicinity of the portion of the proposed gas pipeline that lies on the beach west of the Sishen pier. Although the pipeline itself will not physically restrict access, it is assumed that this portion of the beach would be closed to the public during construction due to safety as well as security concerns. From a mitigation perspective, while access to the coast is considered a right in terms of the ICM Act, restriction of such access in the public interest (for safety and security reasons) and the availability of alternate access to the beach mitigates any impact on coastal users.

Solid waste is also anticipated to be generated by the construction of the gas lines. If not properly managed and contained, these items will find their way onto the beach and into the surf zone resulting in a High negative impact. Any waste materials must be transported to appropriate disposal facilities in order to be mitigated to a Low negative impact significance.

Overall Overall Significance - Aspect: Risk/ Aspect Description Significance -Pre Mitigation Of Impacts Post DIRECT IMPACTS

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Significance - Aspect: Risk/ Aspect Description Significance -Pre Mitigation Of Impacts Post Construction activities Coastal pollution High Construction must be undertaken Low according to a site-specific approved Environmental Management Programme (EMPr) and must be monitored by an on- site environmental officer. All solid waste must be removed to an appropriate disposal facility. INDIRECT IMPACTS Coastal location of the proposed Impact of dynamic coastal Low  During the construction of the Very Low activity within a Port processes transmission lines, the removal of endemic vegetation should be limited, however, invasive alien vegetation invasion in respect to disturbed areas must be removed and controlled  Dust or sand suppression should be undertaken by watering down and limiting activity in windy conditions.

8.4.9.4 Impact assessment findings (with and without mitigation): Preferred Powership and Transmission Line Alternative: Operational Phase The proposed location of the Karpowership west of the ore jetty within the existing and protected inner Port of Saldanha (safe haven), with its lack of wave action and currents, implies that any impact will be addressed as part of the Environmental Management / Climate Change mitigation planning undertaken by the Transnet Ports Authority, in respect to all shipping activities associated with the Port. The proposed location of the Karpowership west of the ore jetty within the existing inner Port of Saldanha negates any additional impact to the historic processes of sediment movement, which have occurred / continue to occur as a result of the construction of the Port and its piers. Due to the largely vegetated and immobile state, any impact of sand blown sand on the gas to power process is also deemed largely non-existent. The operational activities will have a Low negative impact on dynamic coastal processes and any mitigation measures that are implemented will maintain the Low negative significance.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

The proposed location of the transmission lines does not restrict access to the coast and access routes to the coastline will still continue under the overhead lines. The only potential access restriction would be in the vicinity of the portion of the proposed gas pipeline that lies on the beach west of the Sishen pier. Although the pipeline itself will not physically restrict access, it is assumed that this portion of the beach would be closed to the public during operation due to safety as well as security concerns. From a mitigation perspective, while access to the coast is considered a right in terms of the ICM Act, restriction of such access in the public interest (for safety and security reasons) and the availability of alternate access to the beach mitigates any impact on coastal users.

The potential for pollution from shipping (including spent oil and lubricants, paint, solvents and waste detergents, waste from ship maintenance activities, sewage, galley waste, sweepings from hatches and engine rooms, slops from holds and tanks, ballast water, general domestic waste, medicinal/medical waste, spent batteries, discharge of heated water etc.) as a result of the proposed gas to power process is considered to have High negative significance and the specific controls will need to be incorporated into the environmental authorisation in order to mitigate it to Low negative significance.

Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Operation of Powership Coastal pollution High Shipping: Low  Provide an inventory of waste produced and the nature of waste being produced and cooperate with the Transnet National Ports Authority in every way.  A requirement to report environmental accidents and emergencies immediately they occur, to the port captain.  A Formal Failure Analysis (FFA) must be conducted to conclude each incident investigation in order to inform preventative measures to be taken in future.  Training of emergency response teams to deal with environmental implications of an emergency in addition to the safety implications. All solid waste must be removed to an appropriate disposal facility.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post In the event of a large-scale marine pollution event, every effort must be made to prevent it reaching and negatively impacting the MPA and the Langebaan lagoon.

INDIRECT IMPACTS Coastal location of the Impact of dynamic Low The Gas to Power operation must be aware of Transnet Very Low proposed activity within a coastal processes National Ports Authority Environmental Management Port Systems as well as emergency preparedness and response procedures and apply such on an ongoing basis and in the event of emergencies, for example, tidal surge, dust storms and other extreme events.

8.4.9.5 Impact assessment findings (with and without mitigation): Transmission Line Alternative 2: Operational Phase Due to the largely vegetated and immobile state, any impact of sand blown sand on the gas to power process is also deemed largely non-existent. The operational activities will have a Low negative impact on dynamic coastal processes and any mitigation measures that are implemented will result in a Very Low negative significance.

The proposed location of the transmission lines does not restrict access to the coast and access routes to the coastline will still continue under the overhead lines. From a mitigation perspective, while access to the coast is considered a right in terms of the ICM Act, restriction of such access in the public interest (for safety and security reasons) and the availability of alternate access to the beach mitigates any impact on coastal users.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

The potential for pollution from maintenance of the transmission lines and towers are considered to have High negative significance and the specific controls will need to be incorporated into the environmental authorisation in order to mitigate it to Low negative significance. Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Operation of Powership Coastal pollution High Shipping: Low  Provide an inventory of waste produced and the nature of waste being produced and cooperate with the Transnet National Ports Authority in every way.  A requirement to report environmental accidents and emergencies immediately they occur, to the port captain.  A Formal Failure Analysis (FFA) must be conducted to conclude each incident investigation in order to inform preventative measures to be taken in future.  Training of emergency response teams to deal with environmental implications of an emergency in addition to the safety implications. All solid waste must be removed to an appropriate disposal facility. In the event of a large-scale marine pollution event, every effort must be made to prevent it reaching and negatively impacting the MPA and the Langebaan lagoon. INDIRECT IMPACTS Coastal location of the Impact of dynamic Low The Gas to Power operation must be aware of Transnet Very Low proposed activity within a coastal processes National Ports Authority Environmental Management Port Systems as well as emergency preparedness and response procedures and apply such on an ongoing

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post basis and in the event of emergencies, for example, tidal surge, dust storms and other extreme events.

8.4.9.6 Impact assessment findings (with and without mitigation): Powership Alternative 2 (Big Bay): Operational Phase The proposed location of the Karpowership within the existing and protected inner Port of Saldanha (safe haven), with its lack of wave action and currents, implies that any impact will be addressed as part of the Environmental Management / Climate Change mitigation planning undertaken by the Transnet Ports Authority, in respect to all shipping activities associated with the Port. The proposed location of the Karpowership within the existing inner Port of Saldanha negates any additional impact to the historic processes of sediment movement, which have occurred / continue to occur as a result of the construction of the Port and its piers. Due to the largely vegetated and immobile state, any impact of sand blown sand on the gas to power process is also deemed largely non-existent. The operational activities will have a Low negative impact on dynamic coastal processes and any mitigation measures that are implemented will result in a Very Low negative significance.

The proposed location of the transmission lines does not restrict access to the coast and access routes to the coastline will still continue under the overhead lines. The only potential access restriction would be in the vicinity of the portion of the proposed gas pipeline that lies on the beach west of the Sishen pier. Although the pipeline itself will not physically restrict access, it is assumed that this portion of the beach would be closed to the public during operation due to safety as well as security concerns. From a mitigation perspective, while access to the coast is considered a right in terms of the ICM Act, restriction of such access in the public interest (for safety and security reasons) and the availability of alternate access to the beach mitigates any impact on coastal users.

The potential for pollution from shipping (including spent oil and lubricants, paint, solvents and waste detergents, waste from ship maintenance activities, sewage, galley waste, sweepings from hatches and engine rooms, slops from holds and tanks, ballast water, general domestic waste, medicinal/medical waste, spent batteries, discharge of heated water etc.) as a result of the proposed gas to power process is considered to have High negative significance and the specific controls will need to be incorporated into the environmental authorisation in order to mitigate it to Low negative significance.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Operation of Powership Coastal pollution High Shipping: Low  Provide an inventory of waste produced and the nature of waste being produced and cooperate with the Transnet National Ports Authority in every way.  A requirement to report environmental accidents and emergencies immediately they occur, to the port captain.  A Formal Failure Analysis (FFA) must be conducted to conclude each incident investigation in order to inform preventative measures to be taken in future.  Training of emergency response teams to deal with environmental implications of an emergency in addition to the safety implications. All solid waste must be removed to an appropriate disposal facility. In the event of a large-scale marine pollution event, every effort must be made to prevent it reaching and negatively impacting the MPA and the Langebaan lagoon. INDIRECT IMPACTS Coastal location of the Impact of dynamic Low The Gas to Power operation must be aware of Transnet Very Low proposed activity within a coastal processes National Ports Authority Environmental Management Port Systems as well as emergency preparedness and response procedures and apply such on an ongoing basis and in the event of emergencies, for example, tidal surge, dust storms and other extreme events.

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Marine Impacts

8.4.10.1 Impact assessment findings (with and without mitigation): Powership Alternative 1 (Small Bay) and Alternative 2 (Big Bay): Operational Phase Four potentially significant impacts of the proposed FPP facility on the surrounding marine ecology at the Port of Ngqura are identified, and three of them assessed thus far. In this assessment, no mitigation measures beyond those built into the project design are required, and so the ratings would remain unchanged. The three assessed impacts will have a Low to Very Low impact on the marine ecology. It was also concluded that the effects of underwater noise from the Powership operations on marine ecology are unlikely.

Aspect: Risk/ Aspect Description Mitigation Of Impacts Overall Significance - Post CONSTRUCTION PHASE DIRECT IMPACTS Gas pipeline construction and Disturbance of benthic and fish No mitigation proposed. Very Low installation and vessel mooring nursery habitat and modification of the community structure OPERATIONAL PHASE DIRECT IMPACTS Uptake of cooling water Ecological damage caused by No mitigation proposed. Low entrainment

Discharge of cooling water Raised water temperatures could No mitigation proposed. Low affect benthic crustacean families, and fish larvae and juveniles that could not move away from the affected area

Air Quality Impacts The powership alternatives were assessed in the same impact assessment table for the operation phase as the only differences are in the location of the powership. Given that the same Powership are proposed for both alternatives, the scoring of the impacts will be identical for both alternatives.

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8.4.11.1 Impact assessment findings (with and without mitigation): Powership Alternatives 1 and 2: Operational Phase

With low predicted ambient concentrations for SO2, NO2 and PM10 the consequence of impacts is very low. The likelihood of occurrence of impacts associated with SO2, NO2 and PM10 is also very low. Therefore, the significance of impacts resulting from the Karpowership Project is predicted to be Very Low.

Overall Overall Significance - Significance - Aspect: Risk/ Aspect Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Operation of powership, the FSRU Increase in ambient concentration of Very Low No mitigation proposed. Very Low

and the LNG supply vesel. SO2

Operation of powership, the FSRU Increase in ambient concentration of Very Low No mitigation proposed. Very Low

and the LNG supply vessel. NO2

Operation of powership, the FSRU Increase in ambient concentration of Very Low No mitigation proposed. Very Low

and the LNG supply vessel. PM10

Heritage, Archaeology and Palaeontological Impacts The transmission line alternatives were assessed in the same impact assessment tables for the construction and operation phases as the minor differences in the route alignments posed no significant changes in the scoring of the impacts.

8.4.12.1 Impact assessment findings (with and without mitigation): Transmission Line Alternatives 1 and 2: Construction Phase Buried archaeological material, such as artefacts, shell, and bone scatters, could be uncovered in the loose coversands of the Springfontyn Formation, but the overall palaeontological sensitivity of the coversand deposits in the area is classified as Low. The Langebaan Formation is classified to be of high sensitivity, due to previous fossil finds of significant scientific value. Most of the pylon foundations will be embedded in the compact upper Langebaan Formation, calcrete and aeolianite. This shallow depth of the excavations (between 2.0 & 2.6m) will reduce the impact, as fossil bones are overall sparse in the upper calcreted Langebaan Formation. Test pits along the powerline traverse could also unearth fossil bones. The potential for destroying fossils will have significant severity over the short term construction phase resulting in a Medium-Low negative impact significance. By implementing the mitigation

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. measures the severity will decrease to small, with a concurrent decrease in the overall likelihood and extent to the surrounding area, resulting in a Low negative impact significance.

Close to the coast, the surface has been much disturbed and no impact on the loose Witsand Formation is expected. Along the initial ~1.5 km of the route, it is however, possible that shelly beds of the Velddrif Formation may be intersected, although this is considered to be unlikely in shallow excavations envisaged. Buried Pleistocene archaeological remains such as stone tools, bone and shell may be uncovered during excavations for powerline footings, but overall, the archaeological risk sources are rated as being Low. The potential to destroy stone tools, bone and shell will have a harmful severity with Medium negative significance. Applying mitigation measures will reduce severity to small with a resultant Low negative impact significance.

Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post

DIRECT IMPACTS Earthworks Test pits and Medium - Low  Ideally restrict excavations and foundations to a shallow depth not Low excavations for exceeding 2.6m. This will reduce the impact, as fossil bones are overall foundations can sparse in the upper calcreted Langebaan Formation. destroy fossils  The Environmental Control Officer (ECO) and contractor must inform staff of the need to watch for potential fossil occurrences.  A Fossil Finds Procedure is included in the PIA report and provides guidelines to be followed in the event of fossil finds in the excavations. Contractors and workers involved in excavating footings for example, must be informed of the need to watch for fossils and archaeological material, and the procedure to follow in the event of any fossils being found.  If a significant occurrence of fossil bones or shells is discovered a professional palaeontologist must be appointed to collect them and to record their contexts. The above recommendation must be included in the Environmental Management Plan (EMP) for the proposed development.

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Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post

DIRECT IMPACTS Earthworks Test pits and Medium  No archaeological mitigation is required prior to construction operations Low excavations for commencing. foundations can  If any human burials/remains or ostrich eggshell water containers, for destroy stone tools, example are uncovered during excavations, work must immediately stop, bone and shell and the finds reported to Heritage Western Cape.  The above recommendations must be included in the Environmental Management Plan for the proposed development.

8.4.12.2 Impact assessment findings (with and without mitigation): Transmission Line Alternatives 1 and 2: Operational Phase The operational phase impacts will be the same as the construction phase and will be applicable during maintenance and/or if excavation work is required to be undertaken on the foundations. The Medium-Low negative impact potential for destroying fossils can be mitigated to a Low negative impact significance. Similarly, the Medium negative impact potential to destroy stone tools, bone and shell can be mitigated to a Low negative impact significance.

Overall Overall Risk/ Aspect Significance - Significance Aspect: Description Pre Mitigation Of Impacts - Post

DIRECT IMPACTS

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Earthworks Test pits and Medium - Low  Ideally restrict excavations and foundations to a shallow depth not Low excavations for exceeding 2.6m. This will reduce the impact, as fossil bones are overall foundations can sparse in the upper calcreted Langebaan Formation. destroy fossils  The Environmental Control Officer (ECO) and contractor must inform staff of the need to watch for potential fossil occurrences. A Fossil Finds Procedure is included in the PIA report and provides guidelines to be followed in the event of fossil finds in the excavations. Contractors and workers involved in excavating footings for example, must be informed of the need to watch for fossils and archaeological material, and the procedure to follow in the event of any fossils being found.  If a significant occurrence of fossil bones or shells is discovered a professional palaeontologist must be appointed to collect them and to record their contexts. The above recommendation must be included in the Environmental Management Plan (EMP) for the proposed development.

Earthworks Test pits and Medium  No archaeological mitigation is required prior to construction operations Low excavations for commencing. foundations can  If any human burials/remains or ostrich eggshell water containers, for destroy stone tools, example are uncovered during excavations, work must immediately stop, bone and shell and the finds reported to Heritage Western Cape.  The above recommendations must be included in the Environmental Management Plan for the proposed development.

Major Hazards Impacts The proposed LNG operations were modelled for this Risk Assessment. The results were as follows: Page 167

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

- The 1.0e-5 (one in a hundred thousand) red contour is confined to the two ships around the hose connections; - The 1.0e-6 (one-in-a-million) yellow contour stretches for a maximum distance of 190m from the ships and 15m around the generator barge hose connection; - The 3.0e-7 (one-in-thirty million) yellow contour does not reach any sensitive populations. The contour stretches for a maximum distance of 600m from the ships and 25m around the generator barge hose connection.

For the alternative Powership and FSRU location the risks remain the same but in the new location.

The Major Hazards Risk Assessment established that an incident involving the Gas to Power Project at the Port of Saldanha Bay could impact on the neighbouring berths. The risks associated with this MHI were found to be acceptable.

8.4.13.1 Impact assessment findings (with and without mitigation): Powership Alternatives 1 and 2: Operational Phase The main risk contributing part of the operation is the possible rupture of one of the transfer hoses. This may result in a discharge of LNG into the marine environment due to pipeline bursting leading to a flash and pool fire, a High impact. An accredited installer conducting a pressure test and providing the relevant compliance certificates, as well as inspections on the quality and integrity of the pipeline can mitigate this to a Medium impact. The risks were found to be acceptable for the Gas to Power Operations.

Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post INDIRECT IMPACTS Rupture of one of the Discharge of LNG Very Low  Inspection on the quality and integrity of the pipeline; Good Very Low transfer hoses into the marine housekeeping must always be observed on site; environment leading  Only suitably qualified people must be used for all installation to a flash or jet fire work;  An accredited installer must conduct a pressure test and provide the relevant compliance certificates.  There must be an operational manual for each operation.

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Socio-Economic Impacts The proposed Powership and their associated infrastructure will generate both positive and negative impacts for the construction period and operational phases. The assessment of the Powership and their associated infrastructure, from a socio-economic perspective, indicates that the development would generate greater socio-economic benefits during both the construction and operational phases than the potential losses that could occur as a result of their establishment.

Stimulation of production, employment, government revenue, skills development, household income, increased electricity supply, and socio-economic and enterprise development as a result of the investment in the project and its subsequent operations will outweigh possible production, employment and household income losses that could potentially be experienced by local businesses affected by changes in the areas sense of place, social conflicts and deterioration in economic and social infrastructure. Adherence to the proposed mitigation measures, however, would ensure that the offset of impacts is more balanced and that it also takes into account communities and businesses that will be negatively affected.

The positive effects generated by the project will not entirely offset all the negative impacts. These include impacts on the sense of place, and economic infrastructure that could occur during both construction and operational phases. These impacts though will affect local communities either temporarily or over the long term. These impacts are not highly significant and can be traded off for the net positive impact created by the project in terms of production, employment, government revenue, community benefits and households’ earnings.

8.4.14.1 Impact assessment findings (with and without mitigation): Powership and Transmission Line Alternatives 1 and 2: Construction Phase During the construction phase, the proposed Powership and their associated infrastructure will have both positive and negative effects on the socio- economic environment. The project is anticipated to make a notable contribution towards the national and local economy. It is estimated that a total of R154.7 million of new business sales, R324.3 million of GDP and 1 525 FTE employment positions will be generated by the project in the national economy through multiplier effects, all High positive impact significances. In addition to the above positive effects, the project will have Medium-High positive significances by contributing to skills development in the country, increasing government revenue, as well as raising household earnings. The increase in household earnings is also likely to improve the standards of living of the affected households albeit temporarily.

Aside from the positive impacts though, the project will be creating negative direct, secondary and cumulative impacts on the local communities, specifically areas surrounding the site where the proposed facility is to be built. The main factors that will cause this negative impact are (1) Low negative impact from the influx of workers and job seekers from outside of the local community, (2) the Low negative impact on the surrounding economic and social infrastructure and (3) the Very Low impact from limited visual and noise disturbances that could be created by the construction activities as the footprint of the facility grows. Potential negative impacts can largely be mitigated, and their significance reduced. The minimal visual impacts anticipated, however, cannot be fully eliminated although it is also possible to reduce their significance. Page 169

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Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post

DIRECT IMPACTS Direct spend within Temporary High (Positive)  The developer should encourage the EPC contractor to High (Positive) local economies such stimulation in the increase the local procurement practices and promote the as trade, economy employment of people from local communities, as far as accommodation, feasible, to maximise the benefits to the local economies. transport services,  The developer should engage with local authorities and personal services, real business organisations to investigate the possibility of estate, and insurance procuring construction materials, goods and products from local suppliers where feasible. Employment during Temporary increase High (Positive)  Organise local community meetings to advise the local labour High (Positive) construction of the in employment force about the project that is planned to be established and transmission line the jobs that can potentially be applied for.  Establish a local skills desk (in WCDM) to determine the potential skills that could be sourced in the area. Recruit local labour as far as feasible.  Employment of labour-intensive methods in construction where feasible.  Sub-contract to local construction companies particularly SMME’s and BBBEE compliant and women-owned enterprises where possible.  Use local suppliers where feasible and arrange with the local SMME’s to provide transport, catering and other services to the construction crews.

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Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post

DIRECT IMPACTS Skills Development Skills development Medium - High  Facilitate knowledge and skills transfer between foreign Medium-High during construction of (Positive) technical experts and South African professionals during the (Positive) the transmission line pre-establishment and construction phases.  Set up apprenticeship programmes to build onto existing skill levels or develop new skills amongst construction workers especially those from local communities. Employment during Temporary Improved Medium - High  Recruit local labour as far as feasible to increase the benefits Medium-High construction of the standard of living (Positive) to the local households. (Positive) transmission line  Employ labour intensive methods in construction where feasible.  Sub-contract to local construction companies where possible.  Use local suppliers where feasible and arrange with local SMME’s and BBBEE compliant enterprises to provide transport, catering and other services to the construction crews. Combination of Temporary Increase Medium - High None suggested. Medium-High personal income tax, in government (Positive) (Positive) VAT, companies’ tax, revenue etc. by companies and employees during construction of the transmission line

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Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post

DIRECT IMPACTS Influx of construction Temporary increase Medium-Low  Set up a recruitment office in the nearby towns and adhere to Low workers into the area in social disruptions strict labour recruitment practices that would reduce the desire of potential job seekers to loiter around the properties in the hope of finding temporary employment.  Control the movement of workers between the site and areas of residence to minimise loitering around the site. This should be achieved through the provision of scheduled transportation services between the construction site and area of residence.  Employ locals as far as feasible through the creation of a local skills database.  Establish a management forum comprising key stakeholders to monitor and identify potential problems that may arise due to the influx of job seekers to the area.  Ensure that any damages or losses to nearby buildings that can be linked to the conduct of construction workers are adequately reimbursed.  Assign a dedicated person to deal with complaints and concerns of affected parties.

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Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post

DIRECT IMPACTS Influx of worker during Added pressure on Medium  Provide adequate signage along relevant road networks to Low construction of the economic and social warn the motorists of the construction activities taking place transmission line infrastructure on the site.  Engage with local authorities and inform them of the development as well as discuss with them their ability to meet the additional demands on social and basic services created by the in migration of workers.  Where feasible, assist the municipality in ensuring that the quality of the local social and economic infrastructure does not deteriorate through the use of social responsibility allocations. Increase in local traffic Change in sense of Low  The mitigation measures proposed by the visual and noise Very Low and in migration of place specialists should be adhered to construction workers  Efforts should also be made to avoid disturbing such sites during construction. During Construction the small fishermen operators should be engaged to reduce possible .negative impacts on their operations.

8.4.14.2 Impact assessment findings (with and without mitigation): Powership and Transmission Line Alternatives 1 and 2: Operational Phase During the operation of the proposed Powership and their associated infrastructure the socio-economic impacts are likely to last longer when compared to those observed during the construction phase. This is the case for both positive and negative effects. The operation of the proposed Powership and their associated infrastructure will generate R88.6 million of new business sales, contribute R254.9.0 million to GDP and create 240 sustainable FTE employment positions, all High positive impacts. In addition, government revenue will rise (Medium-High positive), electricity supply will be increased (High positive), and various socio-economic and enterprise development initiatives (Medium-High positive) will be undertaken from the revenue generated by the development. These funds will be allocated towards socio-economic development in the area and are expected to bring a significant benefit to local communities.

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Low negative impacts include the potential changes in the sense of place. These potential losses, if they do occur, are likely to be small, given the industrial nature of the proposed development area. As in the case with the impacts observed during construction, negative effects can be mitigated, and positive impacts enhanced. Mitigation of the negative impacts though will not result in their complete elimination as visual disturbance of the nature inherent to the project are difficult to eradicate entirely. Nevertheless, the significance ratings of the negative impacts are expected to be reduced.

Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Spending on labour Sustainable increase High (Positive)  The operator of the Powership and related infrastructure High (Positive) and procurement of in production and should be encouraged to, as far as possible, procure local goods and GDP nationally and materials, goods and products required for the operation of the services locally facility from local suppliers to increase the positive impact in the local economy. Creation of FTE Creation of High (Positive)  Where possible, local labour should be considered for High (Positive) employment positions sustainable employment to increase the positive impact on the local employment economy. positions nationally  As far as possible, local small and medium enterprises should and locally be approached to investigate the opportunities for supply inputs required for the maintenance and operation of the Powership and related infrastructure. Skills development Skills development of Medium - Low  The developer should consider establishing vocational Medium-High contributions by permanently (Positive) training programmes for the local labour force to promote the (Positive) Karpowership employed workers development and transfer of skills required by the Powership and their related infrastructure and thus provide for the opportunities for these people to be employed in other similar facilities elsewhere. Salaries and wages Sustainable increase Medium - High None suggested. Medium - High payments in national and local (Positive) (Positive) government revenue

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Overall Overall Risk/ Aspect Significance - Significance - Aspect: Description Pre Mitigation Of Impacts Post DIRECT IMPACTS Increasing of the Provision of electricity High (Positive) None suggested. High (Positive) electricity supply for future development Karpowership's Local economic and Medium  A three-year social development and economic development Medium - High involvement in social development programme should be devised by the developer throughout (Positive) programmes that seek benefits derived from the project’s lifespan. to address the local the project’s  The plan should be developed in consultation with local communities social operations authorities and local communities to identify community and economic needs projects that would result in the greatest social benefits.  These plans should be reviewed on an annual basis and, where necessary, updated.  When identifying enterprise development initiatives, the focus should be on creating sustainable and self-sufficient enterprises.  In devising the programmes to be implemented, the developer should take into account the priorities set out in the local IDP. Increase in local traffic Negative changes to Low  The mitigation measures proposed by the visual and noise Low and new workers the sense of place specialists should be adhered to  Efforts should also be made to avoid disturbing such sites during operation. Additional personal Improved standards Medium - High  Where possible, the local labour supply should be considered Medium - High income for FTE of living for benefiting (Positive) for employment opportunities to increase the positive impact (Positive) employment positions households on the area’s economy.  As far as feasible, local small and medium enterprises should be approached to investigate the opportunities for supply inputs required for the maintenance and operation of the Powership and their related infrastructure. Page 175

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Visual Impacts The two elements that potentially could have visual implications include the introduction of the proposed Powership and the FSRU into the port as well as the development of grid connection infrastructure. The specialist concluded that the identified visual impacts are all likely to be insignificant.

8.4.15.1 Impact assessment findings (with and without mitigation): Powership and Transmission Line Alternatives 1 and 2: Construction Phase No construction phase impacts have been identified.

8.4.15.2 Impact assessment findings (with and without mitigation): Powership and Transmission Line Alternatives 1 and 2: Operational Phase In terms of the potential to bring industrial / port elements closer to the settlements, beach areas on the eastern side of the Bay including Langebaan and Mykonos, both alternatives will see the FSRU storage ship being located significantly closer to the settlements of Langebaan and Mykonos. Mykonos is considered the worst case as it will be 4.1km from the FSRU while Langebaan will be approximately 5.3 km from the ship. Currently shipping on the Iron Ore and Oil Jetty is approximately 5.5km from Mykonos. The proposed location for the FSRU is approximately 4.1 km from Mykonos. This distance is considered a reasonable visual buffer that should ensure that the landscape / seascape as viewed from these areas will not be significantly influenced by this industrial nature of the ship. This impact was rated as having a Very Low negative significance for the potential to bring industrial / port elements closer to the settlements, beach areas on the eastern side of the Bay including Langebaan and Mykonos.

With regard to intensifying visual impacts associated with industrial / port elements on the Saldanha beach and adjacent residential area, Alternative 1 ship locations would see the Powership being located marginally closer to Saldanha than current shipping on the Iron Ore and Oil Jetty. The jetty is approximately 3.6km from VP1 on Saldanha Beach, the proposed ship location is 3.2km from the viewpoint. All other ship locations for both Alternative 1 and Alternative 2 are located on the eastern side of the jetty and will therefore be less obvious. This reduction in distance between the Alternative 1 Powership and the Saldanha Beach is considered unlikely to create a significantly greater visual impact than other shipping including oil / gas exploration vessels alongside the western side of the jetty. Intensifying visual impacts associated with industrial / port elements will have a Very Low negative significance on the Saldanha beach and adjacent residential area

In terms of intensifying the visual impact of infrastructure in close proximity to the existing infrastructure corridor between the Iron Ore and Oil Jetty and the Blouwater Substation, the proposed 132kV overhead power line will add to the mass of infrastructure within the corridor between the Port, Saldanha Steel and the Blouwater Substation. However locating it in close proximity to this existing infrastructure will ensure that it does not extend the visual influence of power lines into additional landscape areas. It is also highly likely that the existing infrastructure and industrial elements will be visible for a significantly greater distance than the proposed 132kV overhead line. Any additional impact is therefore only likely to be experienced from a relatively close distance. It is suggested that existing items such as ore trains, and railway gantries are likely to have a significantly greater visual impact. The alternative overhead power line alternatives within the Port are highly unlikely to be visually obvious from outside the Port. The additional impact is therefore Page 176

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. considered likely to be insignificant. Intensifying the visual impact of infrastructure in close proximity to the existing infrastructure corridor between the Iron Ore and Oil Jetty and the Blouwater Substation will have a Very Low negative significance.

Overall Overall Significance Significance Aspect: Risk/ Aspect Description -Pre Mitigation Of Impacts - Post DIRECT IMPACTS Viewing from Obstruction of view - potential to bring Very Low No mitigation proposed. Very Low settlements and beach industrial / port elements closer areas on the eastern side of the Bay including Langebaan and Mykonos Viewing from Saldanha Obstruction of view - intensifying visual Very Low No mitigation proposed. Very Low beach and adjacent impacts associated with industrial / port residential area elements Viewing from Iron Ore Obstruction of view - intensifying the visual Very Low No mitigation proposed. Very Low and Oil Jetty and the impact of infrastructure in close proximity to Blouwater Substation the existing infrastructure corridor

Noise Impacts

8.4.16.1 Impact assessment findings (with and without mitigation): Transmission Line Alternatives 1 and 2: Construction Phase The ambient noise levels in the area of the proposed development were 54.9 dB(A). Noise Sensitive Area 2 (a residential area) is approximately 1280m away from the nearest pipeline location and will experience noise levels of approximately 49 dB(A). This is a Medium-Low negative impact significance that can be mitigated to a Very Low negative impact significance by implementing the mitigation measures.

Overall Overall Risk/ Aspect Significance Significance Aspect: Description -Pre Mitigation Of Impacts - Post

DIRECT IMPACTS Page 177

Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape.

Construction of Nuisance to Medium-Low  All construction operations should only occur during daylight hours Very Low Transmission Line surrounding if possible operations or  No construction piling should occur at night where possible. Piling landowners should only occur during the day to take advantage of unstable atmospheric conditions.  Construction staff should receive “noise sensitivity” training such as switching off vehicles when not in use, location of NSA’s etc.  An ambient noise survey should be conducted at the noise sensitive receptors during the construction phase.

8.4.16.2 Impact assessment findings (with and without mitigation): Powership Alternatives 1 and 2: Operational Phase The operational noise levels of the proposed project exceed the SANS 10103:2008 rating limits for a number of the human receptors resulting in a High negative significance. The noise impacts associated with the operational activities can be mitigated to be of Medium-Low negative significance after mitigation. Overall Overall Risk/ Aspect Significance Significance Aspect: Description -Pre Mitigation Of Impacts - Post DIRECT IMPACTS Operation of Nuisance disturbance High • The noise impact from the proposed project should be measured Medium-Low powership, FSRU to operations within during the operational phase, to ensure that the impact is within the and LNG carrier the port required legal limit. • A marine specialist should be consulted to study the effects of underwater noise emanating from the hull of the ship to determine the noise levels and how the impact on marine life in the Port of Saldanha. • Install acoustic enclosures around all major noise emitting components to supress the noise emissions from equipment such as engines. • Install Silencers on equipment such as exhaust stacks and turbo chargers.

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NO-GO ALTERNATIVE

If the Karpowership gas-to-energy project is not implemented, the benefits of the proposed activity will not be realised (with the status quo remaining) and neither will the associated negative impacts/risks. This means that the supply of additional electricity to the national grid will not be supplemented by an IPP. The status quo with regard to the national supplier will remain, i.e. the national grid will continue to be strained as a result of aging and failing systems within the fleet. This will be exacerbated by the time taken for the national supplier to design, assess, receive authorisation, construct and bring online any new power generation facilities. The negative impacts on the physical and social environmental will also not occur. In contrast, any positive impacts or opportunities that will be created by the proposed development, such as job creation or social upliftment, will not be realised.

Table 8-5 Impact of the No-Go Alternative Aspect Impact Significance Terrestrial ecology No loss of Saldanha Flats Strandveld, vegetation or Medium (Positive) Species of Concern. Avifauna No mortality from collision with transmission line Low (Positive) Wetlands No impacts N/A Hydropedology No impacts on hydropedological flow drivers, soil Medium-Low (Positive) quality or potential to compromise surface water quality in the nearby watercourse. River and riparian (aquatic) No impacts N/A Hydrology No impacts N/A Geohydrology No impacts to the vadose zone or quality of the Medium (Positive) groundwater resources Climate Change Supplementary baseload will have to be sought High (Negative) elsewhere, possibly from sources with higher GHG emissions than LNG. Estuarine No impacts to dynamic coastal processes or potential High (Positive) for pollution from shipping. Marine Ecology No impacts to the benthic community, the marine Low (Positive) ecology or marine organisms. Air quality No change to ambient air quality in respect of Very Low (Positive)

pollutants SO2, NOx and PM10 health risks through inhalation of air pollutants Heritage, archaeology and No destruction of fossils, stone tools, bone and shell. Medium (Positive) palaeontology Major Hazard Risks No risks of major hazards such as flash and pool fires Medium (Positive) Socio-economic No influx of workers and job seekers from outside of Medium-Low (Positive) the local community, no increase in impact on the surrounding economic and social infrastructure, no limited visual and noise disturbances

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No contribution towards the national and local High (Negative) economy through new business sales, contribution to GDP or employment. Visual No obstruction of views. Very Low (Positive) Noise Ambient noise levels both above ground and Medium-Low (Positive) underwater will remain the same and not cause a nuisance or any adverse impacts on sensitive receptors.

The specific positive impacts that inform the above assessment findings of the no-go alternative are as follows: - No impacts on hydropedological flow drivers, soil quality or potential to compromise surface water quality in the nearby watercourse. - There will be no impacts to the vadose zone or quality of the groundwater resources. - The primary direct impact of not implementing the proposed project relates to a missed opportunity to align with South Africa’s prevailing energy policy, the Integrated Resource Plan which calls for diversification of electricity supply sources, including natural gas in the transition to an energy mix dominated by renewables in the long-term. The result is likely to be that the electricity baseload which would have been provided by the Powership will be procured elsewhere to stabilize the national grid, potentially from a higher-emitting fuel source such as coal or heavy fuel oil (HFO). - No impacts to dynamic coastal processes or potential for pollution from shipping (including spent oil and lubricants, paint, solvents and waste detergents, waste from ship maintenance activities, sewage, galley waste, sweepings from hatches and engine rooms, slops from holds and tanks, ballast water, general domestic waste, medicinal/medical waste, spent batteries, discharge of heated water etc.). - No impacts to the benthic community, the marine ecology or marine organisms.

- No increase in ambient concentration of SO2, NO2 and PM10, resulting in no health risks through inhalation of air pollutants. - No risks of major hazards such as flash and pool fires. - No influx of workers and job seekers from outside of the local community, no impact on the surrounding economic and social infrastructure, no limited visual and noise disturbances that could be created by the construction activities as the footprint of the facility grows and no potential changes in the sense of place. - The ambient noise levels both above ground and underwater will remain the same and not cause a nuisance or any adverse impacts on sensitive receptors.

In contrast to the above, the following negative implications will occur if the no-go alternative is implemented: - Supplementary baseload will have to be sought elsewhere, possibly from sources with higher emissions than LNG, contributing to climate change. - There will be no notable contribution towards the national and local economy during the construction phase. The estimated total of R154 million of new business sales, contribute R324.3 million to GDP and create 1525 sustainable FTE employment positions will not be generated by the project in the national economy through multiplier effects. Aside from the above positive effects, the project will not contribute to skills development in the country, increase government revenue, or raise household earnings by R154.7 million. The no increase in household earnings is also likely to not improve the standards of living of the affected households temporarily during the construction phase.

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- The non-operation of the proposed Powership and their associated infrastructure will not generate R88.6 million of new business sales, contribute R254.9 million to GDP or create 240 sustainable FTE employment positions. In addition, government revenue will not rise, electricity supply will not be increased, and various socio-economic and enterprise development initiatives will not be undertaken from the revenue generated by the development. These funds will not be allocated towards socio-economic development in the area and will not bring a significant benefit to local communities.

While the no-go alternative will not result in any negative environmental impacts, it will also not result in any positive socio-economic benefits. It will also not assist government in addressing its set target for a sustainable energy supply mix, nor will it assist in supplying the increasing electricity demand within the country. Hence the “no-go” alternative is not the preferred alternative.

CUMULATIVE IMPACTS The preceding impact assessment assessed the impacts associated with the proposed project largely in isolation. As per the legislated requirements, cumulative impacts associated with a proposed development must be assessed.

A cumulative impact, in relation to an activity, is the incremental impact of the past, current and reasonably foreseeable future impact of an activity, considered together with the impact of activities associated with that activity that in itself may not be significant, but may become significant when added to the existing and reasonably foreseeable impacts from similar or diverse activities. Cumulative impacts can take place frequently and over a period of time that the effects cannot be assimilated by the environment over time.

The cumulative impacts have been assessed by identifying other similar project proposals and other applicable projects, such as gas-to-energy or electricity generation, and transmission or distribution facilities within 10 km of the proposed Karpowership gas-to-power project that have either been approved or are currently underway.

Given the similar proposed projects and current operations within close proximity to the study area, cumulative impacts can potentially occur. Anticipated cumulative impacts, based on information available at the time of the assessment, and as relevant to this powership project, were assessed and included in the EIA report.

Regarding other proposed projects in the area, it must be noted that limited information was available. At this stage, the approach of the Independent Power Producer (IPP) Procurement Programme is not clear, and it will have to be further confirmed whether only one bidder or more will be selected for the programme, and as such, will affect the potential cumulative impacts. Furthermore, at this stage, only the proposed scope of projects that are currently underway can be assessed (based on information available), and any changes to the scope as a result of the permitting process and the final project outcome (e.g. authorised alternatives) are unknown and thus cannot be assessed.

8.4.18.1 Identification of Similar Developments The project site is located within the existing and operational port of Richards Bay, adjacent to the Richards Bay Industrial Development Zone (RBIDZ). This area is characterised by light and heavy industrial operations, with further planning to expand the port and the operations at the RBIDZ.

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Other proposed gas to power projects identified within the area include – 1. The Vortum (CCGT) Thermal Power Plant situated on Portion 6 of the Farm Langeberg 188, Malmesbury

Road. The plant consists of gas turbine units and/or gas engine units with a capacity up to 400 MW el each

and an overall capacity of 800MWel; Heat Recovery Steam Generators (HRSG) to generate steam; steam

turbine units with an overall capacity of up to 400 MWel; and electrical generators which convert the energy of the gas and steam turbine units to electricity. 2. 2 X 132 kV Power Lines (Double Circuits) for the connection of the Vortum Thermal Power Plant to the Eskom “Aurora – Saldanha Steel” 2 X 132 kV Power Lines (Double Circuits), located in the Saldanha Bay Local Municipality. 3. Proposed Combined Cycle Gas Turbine (CCGT) Power Plant on a Portion (±59 Ha) of Portion 6 of the Farm Langeberg 188, Malmesbury Rd, Saldanha Bay Local Municipality. The energy generation facility will

be a thermal power plant with a maximum generation capacity up to 1200 MWel (electrical rated power). The proposed thermal power plant will be a Combined Cycle Gas Turbine (CCGT) power plant and/or a Gas Engine power plant, to be fuelled with natural gas imported by means of one or more gas import facilities (e.g., LNG Import Terminal(s) and/or new gas pipeline(s)). 4. Liquid Petroleum Gas (LPG) Import Facility, Pipeline and Handling Facility in the Port of Saldanha within Saldanha Bay Local Municipality. The project and associated infrastructure will comprise LPG pipeline (approx. 8.3km), LPG handling facility (approx.. 3ha) and modification on the existing jetty. 5. Gas-To-Power (GTP) project on a 50 hectare development area located on a section of the Remainder (a portion of Portion 1) of the Farm Uyekraal 189, approximately 15 km north-east of Saldanha, Western Cape Province. The proposed development will consist of the construction and operation of a 900 MW Open Cycle Gas Turbine Plant (OCGT), transmission lines to the Blouwater and/or Aurora Substations, electrical infrastructure required for the GTP project and other associated infrastructure. The project developer is Mulilo Thermal Project Developments (Pty) Ltd.

Existing and operational facilities in proximity to the study area include LPG MBM facility in Big, Sunrise LPG MBM facility, Saldanha Steel, Saldanha Bay Iron Ore terminal and Oil Jetty, Sishen Pier, Sea Harvest, Oyster Dam.

Cumulative effects associated with these similar types of projects include inter alia:  Marine vessel traffic;  Avifaunal collisions and mortalities;  Increase in GHG emissions;  Estuarine pollution;  Increased air emissions;  Loss of fossils;  Increased noise disturbance;  Social upliftment; and  Upgrade of infrastructure and contribution of energy into the National Grid.

From a cumulative impacts perspective, it is not anticipated that the Karpowership gas-to-energy project will result in unacceptable risks or loss to the environment. This is supported by the fact that the proposed project will be located within the port and properties currently used for industry. This means that the site, will at some point be

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. used for an industrial purpose. Furthermore, the location of the Powership and FSRU are within the existing port limits and will integrate into the daily port operations.

The cumulative impacts have been further separated according to the aspects and are discussed in detail in the subsequent sections.

8.4.18.2 Potential Cumulative Impacts on Terrestrial Ecology No cumulative impacts were identified for terrestrial ecology.

8.4.18.3 Potential Cumulative Impacts on Avifauna Cumulative impacts are defined as “impacts that result from incremental changes caused by either past, present or reasonably foreseeable actions together with the project” (Hyder, 1999, in Masden et al. 2010).

Thus, in this context, cumulative impacts are those that will impact the general avian communities in and around the 132kV Gas to Power development and the associated grid infrastructure. This will happen via the same factors identified here viz: collision, avoidance, and displacement.

Given the general assumption that power line length and bird impacts are linearly related, a starting point in determining cumulative impacts is to determine: - the number of birds killed by collision with the new power lines surrounding the site; and - the length and size of the existing power lines within 30-km.

Given that: - transmission lines (> 220kV) kill ~1.05 birds/km/yr (Shaw 2013); and - distribution lines of 66kV kill ~0.37 birds /km/yr (Shaw 2013); - the Aurora-Blouwater 132kV line kills an estimated 0.33 birds/km (this study),

A cumulative total of 57 priority birds per year are expected to be killed by these 66kV, 132kV and 400kV lines per year.

The impact of the grid infrastructure power line and switching station, in the Saldanha habitat is expected to be generally negative and arise from disturbance, and collision for birds around the power lines. The associated infrastructure (Powership) may also affect species in the form of noise pollution. However, it will simultaneously provide nesting sites and perch sites for some avian species (gulls, cormorants, kestrels, and kites), and the warmth may attract these species to roost on the lines and or Powership.

The direct cumulative impact of the 6-km of new proposed lines was gauged using empirical data from the existing Aurora-Blouwater 132kV lines themselves and from Shaw (2015) on bustard mortalities on South African power lines of different sizes. An estimated 57 birds are expected to be killed annually on the lines (mainly ibises, gulls, crows and other non-priority species).

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Careful mitigation through marked lines and staggered pylons (on shore) along adjacent lines can reduce this low mortality to lower levels. By implementing these measures to mitigate possible impacts for these collision-prone species, risks and mortality can be reduced to acceptable levels.

8.4.18.4 Potential Cumulative Impacts on Wetlands No cumulative impacts were identified for wetlands.

8.4.18.5 Potential Cumulative Impacts on Hydropedology No cumulative impacts were identified for hydropedology.

8.4.18.6 Potential Cumulative Impacts on River and Riparian (Aquatic) Resources No cumulative impacts were identified for river and riparian (aquatic) resources.

8.4.18.7 Potential Cumulative Impacts on Hydrology No cumulative impacts were identified for hydrology.

8.4.18.8 Potential Cumulative Impacts on Geohydrology No cumulative impacts were identified for geohydrology.

8.4.18.9 Potential Cumulative Impacts on Climate Change Cumulative climate change impacts for the LNGC project component relate to the emission of greenhouse gases (GHGs) with varying levels of global warming potential. While the emissions from operation of the Powership have been quantified and are known, emissions from the extraction and transport (i.e., the logistics and value chain) of the LNG used to fuel the Powership are not known. The significance rating of cumulative GHG emissions from the LNGC component is therefore an estimate only and may need to be refined based on new information. Emission of greenhouse gases with global warming potential will have a High negative cumulative impact on climate change, but this can be reduced to a Medium negative cumulative impact by implementing technical measures to reduce fugitive emissions at source and during transfer to FSRU as well as considering contributions to appropriate carbon offset/drawdown initiatives.

Cumulative climate change impacts for the FSRU project component relate to the emissions of greenhouse gases (GHGs) with varying levels of global warming potential. There is potential for fugitive emissions during the transfer of LNG between the LNGC and FSRU, as well as during transfer from the FSRU to the Powership via the undersea gas pipeline. Given the localized nature of this impact (i.e., at source/site), emission-related risk is lower since fugitive emissions from a leak in the transfer process will likely be quickly identified and rectified as they will directly impact performance and efficiency of the Powership. The impact is also offset to a certain extent by the design specifications of the gas pipeline and hose, particularly related to its diameter. The overall emissions impact of the FSRU project component is consequently of Medium and Medium-Low significance with and without mitigation, respectively.

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Operation of the gas pipeline may result in emissions of greenhouse gases with global warming potential from potential leaks. This impact is described and assessed under the FSRU sub-heading above, and the impact scores are consequently the same, i.e. Medium and Medium-Low significance with and without mitigation. It is important to note that the cumulative impact of fugitive GHG emissions should be considered as part of the entire Powership operation since vessels are connected by linear infrastructure to each other.

The operation of the Powership at Saldanha Bay will emit ~15.6 MT CO2e over its 20-year lifespan. This impact is potentially significant and needs to be considered cumulatively alongside the emissions from Powership operations at Ngqura and Richards Bay which will each generate 20.27 MT C02e in their operational lifetimes. This means that total emissions for the 20-year lifespan of all three proposed Powership will be ~56 MT C02e. The average annual emissions for all three Powership will therefore be ~18.7 MT C02e, roughly 0.16% of South Africa’s annual GHG emissions in 2017. Technological measures to reduce emissions at source as well as potential contributions to appropriate carbon offset, storage or drawdown initiatives can reduce the impact significance from High to Medium- High.

Contributions of the 132kV transmission lines and steel lattice towers to overall project emissions from the construction phase are both rated as Very Low and easily mitigated.

8.4.18.10 Potential Cumulative Impacts on Estuaries The ICM Act is clear in its directive to not view development activities in isolation from their local and regional contexts, but rather to consider direct and indirect impacts as well as potential cumulative and synergistic impacts of proposed activities in the coastal zone. Assessing cumulative impacts involves examining the impacts of a proposed activity at a coarser scale, and in relation to adjacent and regional activities.

Cumulative impacts that may arise include, but are not limited to:  The project will positively impact on the Port and the economic activities related thereto by providing for short term provision of power to the SEZ when the country is experiencing power shortages. The increased electricity generation capacity, when considered as part of the national Integrated Resources Plan (IRP), from the project will contribute to an enabling environment for economic growth.  The project might add to the potential polluting activities in the bay and Port, especially when combined with other shipping and heavy industrial activities, but such events will be controlled collectively by the Transnet Ports Authority.  While issues relating to pollution are not considered to be of greater threat or significance to the Langebaan Lagoon than current port activities, the risk of cumulative impacts to the sensitive marine and estuarine environments increases as activities within the Port increases.

All efforts should be made to mitigate potential negative cumulative impacts identified by considering the proposed development in both a local and regional context in terms of other current and proposed coastal activities.

8.4.18.11 Potential Cumulative Impacts on Marine Ecology No cumulative impacts were identified for marine ecology.

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8.4.18.12 Potential Cumulative Impacts on Air Quality Ambient SO2 concentrations in Saldanha Bay are low relative to the NAAQS and exceedances have not occurred.

The cumulative effect of the emissions from the Karpowership Project on current ambient SO2 concentrations is predicted to be very small and will therefore not result in a significant increase in ambient SO2 concentrations in Saldanha Bay or in exceedances of the NAAQS.

The proposed 315 MW Frontier Power LPG power plant is situated in the Saldanha Bay industrial area between

Aurora Saldanha Steel and the Port of Saldanha Bay. The maximum predicted SO2 concentrations are very low relative to the NAAQS and will not result in a significant increase in ambient SO2 concentrations in Saldanha Bay. The cumulative effect of these two gas-to-power projects is therefore predicted to be very small.

Ambient NO2 concentrations in Saldanha Bay are relative low and generally less than 25% of the limit value of the NAAQS and exceedances have not occurred. The cumulative effect of the emissions from the Karpowership Project on ambient NO2 concentrations is predicted to be very small and will therefore not result in a significant increase in ambient NO2 concentrations in Saldanha Bay or in exceedances of the NAAQS.

The proposed 315 MW Frontier Power LPG power plant is situated in the Saldanha Bay industrial area between

Aurora Saldanha Steel and the Port of Saldanha Bay. The maximum predicted NO2 concentrations are very low relative to the NAAQS and will not result in a significant increase in ambient NO2 concentrations in Saldanha Bay. The cumulative effect of these two gas-to-power projects is therefore predicted to be very small.

Monitored PM10 concentrations are elevated year-round with limited exceedances of NAAQS in January 2017. An estimated background concentration of 5 to 10 μg/m3 is observed. At the point of maximum predicted ambient concentrations, the Karpowership Project will add less than 1 μg/m3 to the existing annual ambient concentrations and will add a maximum of 1.55 μg/m3 to the 24-hour concentrations. The cumulative effect will be less than this elsewhere in the Port of Saldanha Bay and in the remainder of the modelling domain where predicted ambient concentrations are lower.

The cumulative effect of the emissions from the Karpowership Project on ambient PM10 concentrations is predicted to be small and will not result in a significant increase in ambient PM10 concentrations in Saldanha Bay, or in exceedances of the NAAQS.

The proposed 315 MW Frontier Power LPG power plant is situated in the Saldanha Bay industrial area between

Aurora Saldanha Steel and the Port of Saldanha Bay. The maximum predicted PM10 concentrations are very low relative to the NAAQS and will not result in a significant increase in ambient SO2 concentrations in Saldanha Bay. The cumulative effect of these two gas-to-power projects is therefore predicted to be very small.

8.4.18.13 Potential Cumulative Impacts on Heritage, Archaeology and Palaeontology The cumulative impact of coastal developments and coastal mining is the inevitable and permanent loss of fossils and the associated scientific implications. As mentioned, the impact of both the finding or the loss of fossils is permanent. Diligent and successful mitigation contributes to a positive cumulative impact as the rescued fossils are preserved and accumulated for scientific study. Even though just a very minor portion of the bone fossils exposed

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. in coastal excavations has been seen and saved, the rescued fossils have proved to be of fundamental scientific value.

8.4.18.14 Potential Cumulative Impacts on Material Hazards Identification No cumulative impacts were identified for Material Hazards Identification.

8.4.18.15 Potential Cumulative Impacts on Socio-Economy Potential Positive Cumulative Impacts during the Construction Phase With reference to the temporary increase in employment in local and national economies, there might be limited cumulative construction jobs with skilled employees given the focus on oil and gas related projects planned for the area.

With regard to the contribution to skills development in the country and in the local economy, there will be improved labour productivity and employability of construction workers for similar projects as well as possible development of local skills and expertise related to the gas industry.

There will be an improved standard of living of the positively affected households. The temporary increase in government revenue will result in lower government debt and servicing costs.

Potential Negative Cumulative Impacts during the Construction Phase Change in perception of the area due to the construction of the infrastructure linked to similar developments albeit temporarily due to the impact on the sense of place experienced by the local community as a result of visual and noise effects that appear during the operational phase.

Potential Positive Cumulative Impacts during the Operational Phase Temporary increase in the GDP and production of the national and local economies during construction will result in improved energy supply in the country; reduced carbon emissions in generation of electricity; and sufficient economies of scale could be created to establish new businesses in the local economies. These businesses could then supply the goods and services required for the operation and maintenance of the facility than cannot currently be procured in the area. This would contribute to the local economies’ growth and development. Increased economic activity will require a stable power supply, of which the proposed Powership will be providing and will also benefit businesses in the long term.

The creation of sustainable employment positions nationally and locally will improve living standards of the directly and indirectly affected households. Development of new skills and expertise in the country to support the development of the gas industry, as well as the industry which has been prioritised by the municipality, for permanently employed workers.

The improved standard of living for benefitting households will have a knock-on effect of improving the productivity of workers and improving the health and living conditions of the affected households.

The resultant sustainable increase in national and local government revenue will result in a possible improvement in service delivery.

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The provision of electricity for future development will increase volume and certainty of the energy supply.

Local community and social development benefits derived from the project’s operations will include declining levels of poverty in WCDM, and Western Cape, improved standards of living of the members of the community and households that benefit from the various programmes, and possible improvements in access to services and status of local infrastructure.

Potential Negative Cumulative Impacts during the Operational Phase There will be a change in perception of the area due to the Powership presence in the port over the operating timeframe due to the impact on the sense of place experienced by the local community as a result of visual and noise effects that appear during the operational phase.

8.4.18.16 Potential Cumulative Impacts on Visual Aesthetics No cumulative visual impacts were identified.

8.4.18.17 Potential Cumulative Impacts on Noise The cumulative impact from the other noise sources in the Port of Saldanha is extremely difficult to predict. As the noise level at a receptor increases, the “loudest noise” will generally be heard. Therefore, if in future another noise source e.g., a power plant, is located closer to the receptor and it is generating more noise energy, the new noise source will be perceived above the other noise sources.

8.4.18.18 Potential Cumulative Impacts on Marine Traffic A marine traffic analysis is being undertaken to ascertain the effect of LNG vessels calling at the proposed FSRU spread mooring in the port. The effect will be ascertained on both the current and future vessel traffic of the Port of Saldanha. The FSRU will be refuelled by LNG carriers (LNGC) that will moor to the vessel in a Ship-To-Ship (STS) configuration. The powership and FSRU will be moored on independent spread-moorings. LNG delivery will consider LNGC vessels, with a capacity of 218 000 m3 shall be considered. The marine traffic analysis is based on the upper LNG demand estimate of 24 vessel calls per annum.

The average number of traffic vessels calling at the Port of Saldanha Bay for a typical calendar year is 600 vessels. The largest number of vessel calls are in the Cape Size range, with the majority being for iron ore export. The existing traffic in the port considers MPT vessels of 60 000 DWT manoeuvring to and from berths 201 to 204, oil tankers of 200 000 DWT and bulk carriers of 150 000 DWT manoeuvring to and from the iron ore and oil jetty respectively. Other traffic in the port considers rig moves and ship repair vessel moves past the proposed FPP site towards the Rock Quay or Mossgas Quay. This traffic may impact the FPP site, but the assumed frequency of this traffic will be low, and it is further assumed that operational procedures in the port would only allow this traffic when environmental conditions are favourable.

The impact on existing total port vessel traffic because of the LNG demand estimate of 24 vessel calls per annum is an increase in vessel traffic by 4%. The vessel call estimate for the short term is being carried out to determine the trends in the increase in vessel traffic over the next seven years and to assess the associated implications for navigational safety. The annual percentage growth in demand is being used to estimate the future vessel traffic for

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Draft EIR for the Proposed Gas to Power Project at Port of Saldanha, Saldanha Bay Municipality Western Cape. the various cargo handled within the port for the years 2021 to 2028. The effect on future port operations of the LNGC traffic combined with the forecasted future port traffic will then be assessed. Additionally, the effect on current and future port operations with respect to navigation of traffic vessels past the FPP site and the FSRU mooring is being assessed.

Table ???. Significance of Potential Cumulative Impacts: Aspect Cumulative Impact Cumulative Impact Significance Terrestrial ecology No cumulative impacts identified. N/A Avifauna An estimated 57 birds are expected to be killed Medium-Low (Negative) annually on the lines (mainly ibises, gulls, crows and other non-priority species) Wetlands No cumulative impacts identified. N/A Hydropedology No cumulative impacts identified. N/A River and riparian (aquatic) No cumulative impacts identified. N/A Hydrology No cumulative impacts identified. N/A Geohydrology No cumulative impacts identified. N/A Climate Change The cumulative GHG emissions from the LNGC Medium (Negative) component is therefore an estimate only and may need to be refined based on new information. There is potential for fugitive emissions during the Medium-Low (Negative) transfer of LNG between the LNGC and FSRU, as well as during transfer from the FSRU to the Powership via the undersea gas pipeline. The operation of the Powership at Richards Bay will Medium-High (Negative)

emit ~15.6 MT CO2e over its 20-year lifespan. When considered cumulatively with the emissions from the Powership proposed at the Ports of Saldanha and Ngqura, total emissions for the 20-year lifespan of all

three proposed Powership will be ~56 MT C02e. Estuarine Increase in economic activities related to the port and High (Positive) providing for short term provision of power to the SEZ when the country is experiencing power shortages. Addition to the potential polluting activities in the Algoa High (Negative) bay and Port, especially when combined with other shipping and heavy industrial activities, with resultant negative impacts on the Marine Protected Area, conflict with marine mammals and birds as well as the potential introduction of pathogens which could affect mariculture facilities and operations. Marine Ecology No cumulative impacts identified. N/A

Air quality Increase in ambient concentrations of SO2, NO2 and Very Low (Negative)

PM10

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Heritage, archaeology and No cumulative impacts identified. N/A palaeontology Major Hazard Risks No cumulative impacts identified. N/A Socio-economic Change in perception of the area. Low (Negative) Increase in the GDP and production of the national High (Positive) and local economies as well as Visual No cumulative impacts identified. N/A Noise Cumulative impact from the other noise sources in the N/A Port of Ngqura is extremely difficult to predict. As the noise level at a receptor increases, the “loudest noise” will generally be heard. Therefore, if in future another noise source e.g., a power plant, is located closer to the receptor and it is generating more noise energy, the new noise source will be perceived above the other noise sources Marine Traffic Increase in marine traffic. Low (Negative)

DECOMMISSIONING PHASE IMPACTS The Karpowership project has a potential lifetime of approximately 20 years. At the end of the Power Purchase Agreement (PPA), the ship will depart the harbour and all pipelines and grid connections which are classified as own built will be decommissioned and the infrastructure subsequently removed. The decommissioning process will begin at the end of the PPA. Prior to commencing decommissioning, the Project will be shut down, de-energised and disconnected from the national grid. The Applicant will give landowners sufficient notice prior to the commencement of the decommissioned activities.

It is not anticipated that the proposed Karpowership project will be decommissioned in the foreseeable future. When decommissioning takes place, the legislation applicable at that time should be complied with, and relevant environmental processes and practices implemented. Therefore, an assessment of impacts for this phase is not applicable at this stage.

In the unlikely event that decommissioning occurs in the foreseeable future, the impacts and associated mitigation measures are expected to be similar to those that take place during the construction phase.

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ENVIRONMENTAL IMPACT STATEMENT

2014 NEMA EIA Regulations (as amended), Appendix 3 (1) (l) an environmental impact statement which contains- (i) a summary of the key findings of the environmental impact assessment: (iii) a summary of the positive and negative impacts and risks of the proposed activity and identified alternatives.

Summary of Findings of Environmental Impact Assessment During the EIA, the impact of the Proposed Gas to Power via Powership Development on the biophysical and socio- economic environments were assessed. Below is a summary of the main findings for the proposed project, following proposed mitigation:

Aspect Finding Terrestrial Ecological The site is mostly of low sensitivity due to the wide distribution of modified and degraded habitats and the alignment of the transmission line route with existing infrastructure.

It is the opinion of the specialist that the proposed development go ahead, provided the mitigation measures are put into place. Avifaunal Despite the line’s close proximity to two internationally significant Important Bird Areas there was little evidence that the development will cause an impact to the avifauna based on few power line fatalities.

The specialist recommended that the routing for the proposed 132kV line should be given authorisation provided all proposed mitigations are in place to allow for the project to proceed with a systematic post-construction monitoring programme in place. Vegetation The proposed routes are primarily within transformed or modified habitat, resulting in little overall loss of indigenous vegetation.

It is the opinion of the specialist that the proposed development go ahead, provided the mitigation measures are put into place Wetlands Due to no watercourses being at risk, no further assessments were required.

The specialist further recommends that all construction activities of the proposed development can occur but must take into cognisance the surrounding biodiversity in the area that was regarded as sensitive by the Terrestrial Ecologist. River Riparian (Aquatic) No aquatic assessment could be conducted in accordance with the SASS5 protocol as no water flow was present within the study site.

Mitigation measures as included in the Department of Environmental Affairs (DEA) generic Environmental Management Plan were recommended.

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Aspect Finding Surface Water (Hydrology) Since there are no nearby surface water bodies at the proposed Saldanha Bay development site, the specialist indicated there is no risk posed to surface water in the area. Groundwater (Geohydrology) The risk and impact assessment undertaken suggest that the potential geohydrological impact at the site (quantity and quality) is low-marginal Estuary There are no immediate points of impact within the EFZ relative the project activity. A full estuarine impact assessment for the Langebaan Lagoon is not deemed necessary.

The specialist indicated the proposed activity is considered acceptable and that the project should be authorised taking due consideration of the mitigation measures included. Coastal The majority of the potential impacts associated with the project are likely to be highly localised, that is, in situ of the project components within the Port of Saldanha, and not anticipated to have a direct effect on the integrity and ecology of the lagoon. Marine Ecology The effects of increased noise and vibration levels on the surrounding marine ecology could not be assessed due to the lack of underwater noise and vibration levels data pertaining to floating power plant ships.

However, it is the specialist’s opinion that operations will probably be below source levels from large vessels, and this is lower than the SPL thresholds listed above for the protection of marine fauna. Therefore, the effects of underwater noise from FPP operations on marine ecology are unlikely. Noise The noise impact associated with the operational activities of the proposed project is predicted to be of Medium-Low significance after mitigation at the Port of Saldanha. The construction related noise impacts will be of Very- Low significance. Sites of Archaeological, Excavations for powerline footings may uncover buried Pleistocene Historical and Cultural archaeological remains such as stone artefacts, bone, and shell. Larger concentrations of bone, shell and stone tools may be recovered which Significance would elevate the significance of the finds, but this is, considered to be unlikely. Visual Aspects Identified visual impacts are all likely to be insignificant.

There is no reason from a landscape and visual impact perspective why the proposed project should not proceed. Climate Change The specialist concluded that the significant climate change impacts that have been identified can be offset to acceptable levels through proactive implementation of appropriate mitigation measures. The extent to which the project proponent contributes to carbon capture, storage or offset initiatives will depend on what offset ration is considered acceptable to both proponent and competent authorities.

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Aspect Finding Risk A potential incident involving the Gas to Power Project at the Port of Saldanha Bay could impact on the neighbouring berths. The risks associated with this MHI were found to be acceptable.

The main risk attributed to the operation of the Powership is the possible rupture of one of the gas transfer hoses. This may result in a discharge of LNG into the marine environment due to pipeline bursting, leading to a flash and pool fire, considered as a High impact which can be mitigated to a Medium impact. The risks were found to be acceptable for the Gas to Power Operations.

PROPOSED IMPACT MANAGEMENT OUTCOMES

2014 NEMA EIA Regulations (as amended), Appendix 3 (1) (m) based on the assessment, and where applicable, recommendations from specialist reports, the recording of proposed impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation;

The following outcomes must be considered for this project: o Impacts relating to site establishment are managed and minimised; o Impacts on flora and fauna are managed and minimised; o Impacts on heritage resources are managed and minimised; o Construction vehicle movement are restricted to approved footprint; o Construction of fencing and gate of the construction camp / laydown area are managed within sensitive environments; o Water for construction is compliant with the requirements of the National Water Act (Act No. 36 of 1998); o Impacts related to storm and waste water are avoided, prevented and managed; o Impact to watercourses and estuaries are managed in adherence to legislation and specialist recommendations; o Impacts to marine environment are managed in adherence to legislation and specialist recommendations; o Vegetation clearance and associated impacts are minimised and managed; o All precautions are taken to minimise the risk of injury, harm or complaints; o No pollution or disease arises in terms of poorly maintained ablution / sanitation facilities or lack thereof; o All necessary precautions linked to the spread of disease are taken; o Emergency procedures are in place to enable a rapid and effective response to all types of environmental emergencies; o Safe storage, handling, use and disposal of hazardous substances; o Spillages and contamination of soil, surface water and groundwater are avoided, minimised and managed; o Dust prevention measures are applied to minimise the generation of dust; o Noise management is undertaken in accordance with SANS 10103 and the Occupational Health and Safety Act (Act No. 85 of 1993). o Fire prevention measures are carried out in accordance with the relevant legislation. o Erosion and sedimentation as a result of stockpiling are reduced.

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o Minimise the risk of environmental impact during periods of site closure; o Post-construction and rehabilitation activities are undertaken in accordance with EMPR requirements as well as Rehabilitation Plans; o Socio-economic development is enhanced and job creation and economics in the area are improved; o Effective awareness and training for all construction staff to minimise environmental impacts; o Ensuring social and ecological well-being of the site and community; o Impact on No-Go areas are avoided through effective demarcation and management of these areas; o Impacts resulting from earthworks are managed and guided by specifications; o Construction materials are sourced from authorised sites; o Potential impacts to the environment caused by waste (general and hazardous) are avoided or managed; o All onsite staff are aware and understands the individual responsibilities in terms of this EMPr. o Stormwater related impacts are avoided, minimised and managed; o Dust, emissions and odour impacts are minimised and managed; o Impact to heritage and palaeontological resources are managed in terms of the National Heritage Act. o Compliance with all environmental legislative requirements during the operational phase of the project is implemented and managed; and o Environmental impacts during the Operation and Maintenance Phase are managed in terms of Operational Maintenance Management Plan requirements.

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SCOPING REPORT AND PLAN OF STUDY DEVIATIONS

All deviations from the Scoping Phase have been identified and included in this EIA Report.

The list of deviations include: 1. Some Specialists have adopted the Triplo4 impact assessment methodology, others have maintained their own methodologies that were relevant to their specialist fields, to ensure an accurate representation of the significance of the environmental impacts assessed. Where possible and with the approval of the Specialists, Triplo4 have transferred the assessment information to be in accordance with the approved PoS impact assessment methodology. Triplo4 have endeavoured to ensure that our impact ratings are a true reflection of those assessed by the Specialists. The marine ecology assessment was utilised directly, as the Specialist’s selected methodology was more appropriate to determine the impacts on marine ecology. 2. A new Powership position within Big Bay was included based on TNPA’s preference (Figure 8-1); 3. A 132KV line connection to the Aurora – Saldanha Steel network via a new 132 KV switching station as requested by Eskom(Figure 8-2 and 8-3); 4. Connections to the main transmission line to National Grid (route to Blouwater or route to Aurora-Saldanha Steel) based on position of the Powership;

Figure 8-1: Powership Deviation – New position in Big Bay.

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Figure 8-2: Transmission Line Deviation – Connection to Aurora – Saldanha Steel Network

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Figure 8-3: Deviation – New Switching Station

Figure 8-4 Transmission Line Deviations – Connection from New Big Bay Position to either Transmission Line Alternative 1 or 2

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ASSUMPTIONS, UNCERTANITIES AND GAPS IN KNOWLEDGE RELATING TO THE ASSESSMENT AND MITIGATION PROPOSED

The information in this report is based on findings of several specialists’ studies. The layouts and engineering drawings of the proposed Gas to Power Project at Port of Saldanha, have been provided to the EAP by the engineer and planner respectfully. During the compilation of this EIA Report, the following assumptions and limitations relating to this assessment were identified by the EAP and specialists:  The scope of this report is limited to assessing the environmental impacts of the proposed Karpowership gas-to-energy project and its associated infrastructure.  The information provided by the applicant and specialists are accurate and unbiased.  Information from secondary sources and I&APs is accurate.  Assessments of impact significance for social impact often need to be made without quantification. These are based on a consideration of the likely severity of impacts and/or expert judgements, unless otherwise specified or quantified.  The assessment only considers the impacts of the proposed project and the no-go and does not make comparisons with or assessments of other gas-to-energy projects as there are currently none in the area. Proposed Risk Mitigation IPP Procurement Programme projects have been considered under the cumulative impacts section.  There will be a temporary Right of Way (RoW) of 30m (15m either side of the centre line) of the pipeline during the construction and operational phase of the transmission line.

Specialists: Some Specialists have adopted the Triplo4 impact assessment methodology, whereas others have maintained their own methodologies that were relevant to their specialist fields, to ensure an accurate representation of the significance of the environmental impacts assessed. Where possible and with the approval of the Specialists, Triplo4 have transferred the assessment information to be in accordance with the approved POS impact assessment methodology. Triplo4 have endeavoured to ensure that our impact ratings are a true reflection of those assessed by the Specialists. The marine ecology assessment was utilised directly, as the Specialist’s selected methodology was more appropriate to determine the impacts on marine ecology.

Wetland Ecologist  According to the SANBI guidelines, specialist assessments should be performed during the rainfall season of assessed area. In this case, Western Cape is a winter rainfall area and therefore assessments should be performed between May to August. Fieldwork for this project was done at the at end of September 2020, a month after the rainy season, however the area where the study was conducted, experienced rainfall for the last two days before the site assessment was conducted.  Accessibility to certain portions of the landscape where watercourses were present was difficult due to the dense vegetation in the area and erected fences which made these areas inaccessible.

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 A construction method statement was not provided by the engineer and therefore the potential impacts on the watercourses that may arise as a result of the construction activities were determined using the specialist’s knowledge and experience with similar projects.  Only those wetland/riverine habitats which will be significantly impacted by the proposed development were accurately delineated in the field. The remaining watercourses within a 500m assessment radius were delineated at a desktop level and broadly verified in the field to obtain an extent of the wetland/riverine areas, and to facilitate an understanding of the dynamics of the systems.  This is a once off assessment which can only take into consideration the current condition with some speculation of historical events based on evidence observed in the area and satellite imagery. As vegetation and habitats may vary both temporally and spatially, there must be recognition of fact that certain aspects or features may be missed if they do not present themselves on the day.  All delineation verification is done using a GPS system. The precision of such systems is generally limited to 5m and therefore this error must be taken into account when utilising the GPS coordinates.  Only vegetation which was present within at risk watercourses were assessed in the field, all other systems were assessed at desktop level and visually confirmed on site.  While the assessment techniques utilised in this report are used in order to standardise and ‘objectify’ the assessment of the systems’ function, potential impacts and services, it must be noted that much of the information is subjectively collected based on the assessor’s previous experience and training. The assessor will, if additional information or counter arguments are provided and verified, hold the right to amend the report if need be.  The assessment of impacts and recommendation of mitigation measures was informed by the site- specific ecological issues identified during the infield assessment and based on the assessor’s working knowledge and experience with similar development projects.  Evaluation of the significance of impacts with mitigation takes into account mitigation measures provided in this report and standard mitigation measures are to be included in the project-specific Environmental Management Programme report (EMPr).

Terrestrial Ecologist  The field work was conducted over one day on the 2nd of October 2020.  The site assessment was conducted in spring (October) during the usual flowering season for the region.  The route options were surveyed in a vegetation sampling approach and limited to sites that were accessible. Vegetation communities were extrapolated for the routes based on field data.  This report serves as a preliminary investigation. Site data analyses and full plant identification, along with vegetation community and sensitivity mapping and impact rating will be done in the final report.

Heritage Specialist  Except for in the Port area, the proposed route options are mostly covered in natural vegetation, grass, and weeds, resulting in low archaeological visibility. However, it is felt that this did not materially affect the findings made during the study.  The assumption is that the fossil potential of a formation in the Project Area will be typical of that found in the region and more specifically, similar to that already observed in the surrounds of the Project Area.

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In many cases the information on fossil content is limited to the basics, such as in the case of geological mapping when the fossils are not the immediate focus. Scientifically important fossil shell and bone material is expected to be sparsely scattered in these coastal-plain deposits, but unless large and obvious, is not generally seen, under-estimating the fossil prevalence. Much depends on careful scrutiny of exposures and on spotting fossils as they are uncovered during digging i.e. by monitoring excavations. A limitation on predictive capacity exists in that it is not possible to predict the buried fossil content of an area or formation other than in general terms.

Geohydrologist  No exploratory drilling or fieldwork was conducted as part of this study. Although data in this assessment is extracted from reliable data sources, the risk assessment is considered preliminary until groundwater data is verified with intrusive site work (i.e. drilling of onsite boreholes, on-site water quality and quantity testing).  Limited groundwater quality and quantity data are available for the project area. Available groundwater data was extrapolated to conceptualise the best-case hydrochemistry and groundwater conditions of the site.

Aquatic Specialist  Analysis of the ecological state of selected aquatic assessment sites potentially affected by the proposed transmission lines at Saldanha Bay Port was undertaken using aquatic macroinvertebrates (adapted from Dickens & Graham, 2002) as a response indicator;  The SASS5 biomonitoring protocol should be limited to appropriate sites, that being, in flowing rivers (except in flood conditions) and where suitable habitats are present (Dickens & Graham, 2002). Strictly speaking, the SASS protocol and several supporting tools cannot be applied where stagnant conditions prevail;  The findings and recommendations of this report are based on site characteristics results, and also on the data and resources available at the time of the survey;  This report is based on a single site assessment, therefore temporal trends could not be calculated;  The report is based on a single survey and assessment methods, that are limited by time relevant to the type and level of investigation undertaken; and  Recommendations are based on professional opinion.

Water Balance  Due to the complex interconnectivity of the cooling system, the water balance focuses on conceptualising the distribution of losses as specified by the client (refer to Table 2-1).  It is assumed that the Khan vessels operate as independent systems.  The water balance is static and provides and average case water balance, based on information supplied by the client (refer to Table 2-1).  Due to the nature of this project (i.e. a ship where nearly 100% of precipitation on the vessel will turn into runoff and flow to the ocean), no precipitation runoff and evaporation is incorporated into the balance.

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 The balance does not consider water use for emergency application (i.e. fire water and foam extinguisher water).  Freshwater and saline water usage for known systems were applied, and estimates were made in terms of evaporation losses. The cooling tower evaporative and blowdown losses are estimated at 60 to 90% (DOE USA, 2005) for the cooling units (i.e. freshwater and seawater systems). Recirculation water (water recovery) is assumed to be in the order of 20% for cooling systems.  The average daily domestic water demand was calculated from the supplied approximate monthly average sewage. It is assumed that 70% of the sewage will come from toilets (blackwater); and the remainder will be from greywater (30%) and the bilge separators (20%) – know to range from 1.5% for fuel systems and may increase to 30% depending on vessel water usage (Agarwal, 2020).  A 15% contingency is allocated to technical water use.  It is assumed that the bilge separator does not form part of the estimated monthly sewage and is operational dependant (i.e. higher power demand may mean more sludge from engines etc.). It is assumed that approximately 40% of the total cooling system water will remain “dirty” and will go to the WWTP and storage tank.  It is assumed that tanks are operating at full capacity, and that water is available for immediate distribution into the reticulation system.  The maximum capacity of the storage tanks were used to estimate initial water demand.  The water balance does not consider or represent the maximum design operational capacity flow quantities (i.e. engineering specified flow rates). Instead, data supplied by the client in Table 2-1 was applied and trial and error calibration based on the above-mentioned assumptions were made (i.e. inverse modelling from available data).

Hydropedology Assessment  This study is desktop-based, and hence no intrusive work was undertaken. It is assumed that literature data evaluated accurately describes the soil and hydropedological occurrences.  The concepts presented are simplifications of the temporal variability of water transfer functions. Realistically, water transfer functions, such as throughflow and groundwater sources, may take a few months up to several years to recharge streams (Le Roux, et al., 2011) However, hydropedology hillslopes have been effectively applied to simulate runoff response mechanisms (Van Tol, Le Roux, & Lorentz, 2013).

Air Quality Assessment  No ambient monitoring is done for this assessment, rather available ambient air quality data is used.  The Model Plan of Study (uMoya-NILU, 2020) describes the dispersion modelling methodology has been accepted by the Licensing Authority.  The assessment of potential human health impacts is based on predicted (modelled) ambient concentrations of SO2, NO2, and PM10 and the health-based National Ambient Air Quality Standards (NAAQS).

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Socio-economic Impact Assessment Construction phase assumptions:

 The construction of Powership related infrastructure is planned to commence in 2021 contingent on project approval.  The total investment is valued at R494.1 million in 2020 prices, of which R278.7 million will be spent within the South African economy with the rest on imported goods and services.  Only local expenditure is considered in this analysis.  The construction of the related infrastructure will create an estimated 333 project specific personnel over the period of construction of which 283 employment positions will be created for South African citizens.  Approximately 37.8% of the total employment positions for South African citizens will be from local communities.

Operational phase assumptions:  The Powership are anticipated to begin operating once construction is completed  The operations and maintenance cost of the Powership will be valued at, on average, R238.9 million per annum over the 20-year operational life of the project.  The greatest share (52.5%) of operational local spending will be directed at covering labour costs associated with the employment of 142 workers, 87 skilled workers and 55 unskilled workers.  During its operation, the Powership and related infrastructure will employ approximately 142 project specific personnel of which approximately 102 employment positions will be created for South African citizens.  Approximately 44% of the total employment positions for South African citizens will be from local communities.

Landscape & Visual Impact Assessment  Level of Assessment: Because the project is proposed within an active port and an area that is highly industrialised and because the main visible elements of the proposed project include the mooring of ships within a port environment as well as the construction of a 132kV overhead power line adjacent to existing power lines a Level 2 Assessment in accordance with the Western Cape Guidelines has been undertaken.  A Level 2 Assessment requires the following input: - Identification of issues raised in scoping phase and site visit - Description of the receiving environment and the proposed project - Establishment of view catchment area and receptors - Brief indication of potential visual impacts, and possible mitigation measures.  In accordance with the Western Cape Guidelines, a Level 2 Assessment should be undertaken when minimal visual impact is expected. Should un-anticipated impacts be found, the level of assessment may be elevated accordingly.  Assessment Subjectivity: The assessment requires a subjective judgement as to whether an impact is negative or positive is based on the assumption that the majority of people are likely to prefer to view a natural or a rural landscape / seascape rather than an industrial landscape / seascape.

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 Site Visit: A site visit was undertaken on a single day (1st February 2021) to verify the likely visibility of the proposed project. Information collected during this site visit has been used in the preparation of this report.  Visibility Assessment: Visibility of the proposed elements has been assessed using the viewshed tool in the Global Mapper GIS program. The visibility assessment is based on terrain data that has been derived from satellite imagery. This data was originally prepared by NASA and is freely available on the CIAT-CCAFS website (http://www.cgiar-csi.org). This data has been ground truthed using a GPS as well as online mapping; and calculation of visibility is based purely on the Digital Elevation Model and does not take into account the screening potential of vegetation.  Extent of Development Visible: The approximate extent of the development visible from each viewpoint as indicated in Section 4 has been approximated by measuring on plan the angle of the view that the development occupies given that each view was taken with a 28mm lens which has an approximate angle of vision of just over 74°. This has been cross referenced with known land marks.

Avian Assessment  Inaccuracies in the above sources of information can limit this study. The SABAP1 national data set is now over 20-years old (Harrison et al. 1997) and it is likely that bird distributions have since altered under the effects of climate change in South Africa (Simmons et al. 2004). Therefore, we have used only the more recent SABAP2 data set. This has a higher spatial resolution and is up to date (2007 to 2019).  Any site visits to survey avifauna, even over a 12-month period, may not provide a complete picture of all species likely to occur in an arid region. This may arise because of drought and rainfall is the chief limiting factor as it dictates if birds occur, the species diversity and when, and if they breed (Lloyd 1999, Dean 2004, Seymour et al. 2015). Our site visit encompassed only three days at Vantage Points and a walking survey along the existing power lines. This is too brief a visit to determine the full number and identity of all birds likely to be impacted by the power lines throughout the year.

Major Hazard Risk Assessment  Events Following a Loss of Containment:

- Where no Boiling Liquid Expanding Vapour Explosion (BLEVE) and fireball occur following an instantaneous release with direct ignition, a liquid pool is formed, and a vapour cloud will expand to atmospheric pressure. The direct ignition of the vapour cloud is modelled as a flash fire (probability 0.6) and explosion (probability 0.4). - For an above-ground storage vessel (or road tanker), a BLEVE or fireball may occur. A BLEVE can occur when a flame impinges on a vessel containing a material that is a gas at atmospheric pressure and temperature but is a liquid at storage temperature and pressure. It is assumed that a BLEVE occurs when the vessel or road/ rail tanker is full. While BLEVEs are possible because of catastrophic vessel failure and localised vessel failure, they typically occur outside of these two events. Should this not occur, a vapour cloud may form. The ignition of the vapour cloud is modelled as a flash fire and explosion. - The flash fire is modelled through simulating the expansion of the initial cloud to the lower flammability limit (LFL) with air entrainment. The damage area then corresponds to the LFL cloud

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footprint. The explosion is modelled using the total mass subject to the lower flammability limit (LFL). - Accidental high velocity releases of ignited flashing liquids of pressurised flammable material at ambient temperature are classed as liquid jet fires. Jet fires occur when the jet of hydrocarbon can entrain air and burn at its edge. The jet remains ignited because the burning of the flame is greater than the velocity of the hydrocarbon jet, i.e. the flame can burn back towards the source of the jet. As a worst-case scenario, it is assumed that all failures occur in a horizontal position, i.e. the flame is orientated horizontally.  Scenarios Modelled: This report was done in terms of SANS 1461 and this standard refers to ‘BEVI’ as the preferred reference to be used. All modelling was conducted according to Bevi and stipulates the following: - There are no scenarios for intrinsic failure for ships. It is assumed that loading takes place for most of the time that a ship is present, and the loading scenarios are dominant compared to intrinsic failure. - The only scenarios that are relevant in addition to loading, are external damage as a result of ship collisions. These are very much determined by the local situation. In the case that a ship is in a port outside the transport routes, the probability of a collision that leads to an outflow is so small that it does not need to be taken into consideration.

 Jet Fires: - Jet fires occur when flammable material of a high exit velocity ignites. Ejection of flammable material from a vessel, pipe or pipe flange may give rise to a jet fire and in some instances the jet flame could have substantial ‘reach’. Depending on wind speed, the flame may tilt and impinge on pipelines, equipment or structures. The thermal radiation from these fires may cause injury to people or damage equipment some distance from the source of the flame. - For this Assessment, jet fires from a 1-inch leak in a transfer hose was assumed. The worst-case scenario of the jet fire being horizontal and in the same direction of the wind was assumed. - The flame length for a 1-inch hole in the transfer hose was calculated at 68.689m with a wind speed of 1.5m/s. The effects from the jet fire could not extend beyond the ships. The jet fire could not reach and impact on other activities at any of the berths.

 Flash Fires: - A loss of containment of flammable materials if not immediately ignited, would mix with air and form a flammable cloud. This cloud could drift and if ignited could result in a flash fire or vapour cloud explosion. - The cloud of flammable material would be defined by the lower flammable limit (LFL) and the upper flammable limit (UFL). An ignition within a flammable cloud can result in an explosion if the front is propagated by pressure. If the front is propagated by heat, the fire moves across the flammable cloud at the flame velocity and is called a flash fire. In some instances, pockets of flammable clouds may extend beyond the LFL due to localised conditions. The ½ LFL endpoint assumes there are no isolated pockets and that ignition would not occur beyond this point. - A flash fire from a catastrophic leak (Hose shear and overfill) from the ship is shown below. Flash fires could have impacts beyond the berths. - The flammable cloud will extend past the berth for a distance for about 350m. This release can also extend onto the next berth depending on angle of release and wind direction. Page 204

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 Confined Gas Explosions: - Vapour cloud explosions are one of the most devastating events which can occur in the process industries. It was recognised that a facility design should include limiting explosion damage. The determination of peak overpressures from gas explosions and development of design criteria for structural support become more complex due to high pressure inventories in congested areas. - There are four key factors in an explosion. These are related to the overpressure which is the pressure rise above normal atmospheric pressure, the positive phase duration which is the time during which the pressure is above atmospheric pressure, the degree of confinement of the flammable mixture which causes turbulence and acceleration of the flame front and influences the overpressure, and the impulse (area under the pressure-time profile). - It is well established that it is not the size of the vapour cloud that matters when it comes to blast strength, but the degree of confinement of the vapour cloud and congestion in the path of the flame front. The energy of ignition source (e.g. naked flame) plays a dominant role in determining the blast strength, although a well-designed facility with strict implementation of hazardous area classification requirements in terms of hardware and safety management system can reduce the strength of a potential ignition source significantly. - The Multi-Energy Model (MEM) for rapid assessment of explosion overpressure has been developed by TNO (1997). It is based on the concept that significant overpressures can be generated by the ignition of a vapour cloud only in the presence of partial confinement or obstacles in the path of the flame front. This model, however, requires assumptions on the initial blast strength, which significantly influences the predictions. CFD models used in offshore modules have shown that rapid assessment models can underestimate the blast overpressures. - There are confined areas at the Port such as the service chambers and buildings.

 Delayed Ignition: - The probability of delayed ignition depends on the end of the calculation. In the calculation of the location-specific risk only ignition sources on the site of the establishment are considered. Ignition sources outside the establishment are ignored: it is assumed that if the cloud does not ignite on site and a flammable cloud forms outside the establishment, ignition always occurs at the biggest cloud size. In the calculation of societal risk, all ignition sources are considered, including population. If ignition sources are absent, it is possible in the societal risk calculation that the flammable cloud does not ignite.

 Marine Ecologist and Noise - Underwater noise was identified as a gap in knowledge, as there is currently no baseline as no precedent done in South Africa. It is concluded that there is not enough information about underwater noise and vibration levels from floating power plant ships to conduct an assessment. Therefore, general sound levels from commercial vessels were presented and the biological thresholds of sensitive receptors, and the marine ecologist indicated that impacts on marine ecology are unlikely.

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Climate Change Impact Assessment

 A maximum of 3723 operational hours per year was assumed for the calculations for the CO2e emissions of the Powership.  With regard to the IRP’s intention to commission ~8000MW from gas-to-power technology between 2026 and 2029, it is assumed that the diesel component — a high-emitting, heavy fuel oil — of the gas/diesel category will not increase post-2018, and that the remaining ~8000MW are consequently earmarked for gas-to-energy infrastructure.

Coastal and Estuarine Impact Assessment Report  Having been provided with all the relevant information required;  Only readily available data and information was used; and  No physical, chemical or biological sampling was undertaken during this assessment.

Greenhouse Gas Emissions Report  Total emissions calculated are based on site reference conditions 1013.25 mbar and 25°C.  Total emissions calculated are based on Plant operation at 100% contracted capacity.  Total emissions calculated are based on 3723 hours per annum operation.  Engine degradation allowed for 1.5% over 18,000 hrs (Wartsila 18V50SG degradation curve, Appendix B of the Greenhouse Gas Emissions Report)

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9 CONCLUDING STATEMENT RECOMMENDED ALTERNATIVES

Both the alternative locations assessed for the Powership i.e. in Big Bay and in Small Bay are acceptable from an environmental and socio-economic perspective. The associated environmental and socio-economic impacts at both locations can be mitigated to acceptable risk levels - either low or very low and thus, no fatal flaws have been identified for either location. The avian, noise, visual and socio-economic specialists have expressed a slight preference for the Powership to be moored in Big Bay as the associated impacts are marginally less negative. Transnet National Port Authority (TNPA) has also indicated that it has a preference for the Powership to be located in Big Bay due to recent updates to its Port planning. As TNPA’s approval of the exact layout still needs to be finalised, it is the EAP’s recommendation that both alternative locations for the Powership be authorised, with the final selection dependant on TNPA’s planning adjustments

The alternative routes proposed for the gas pipeline (including subsea and land-based portions) linking the FSRU in Big Bay to the Powership depend on the Powership’s location in either Big Bay or Small Bay. Both alternative routes for the gas pipeline are supported by all the Specialists and the EAP. Thus, it is also recommended that the alternative layout of the pipeline be authorised, with the choice of route depending on TNPA’s preference for the location of the Powership.

The transmission line alternatives for distribution to the National grid, largely follow a similar route and are considered the main routes. The connection of the transmission line from the Powership to the main route depend on the position of the Powership. As motivated by Eskom, the power from the Powership is evacuated by means of a double circuit twin Chicadee conductor 132kV line The proposed line, approximately 5,7km, will interconnect the Powership to the National Grid utilising the existing Aurora- Saldanha Steel network via a new 132kV on shore switching station. Alternatively,

In summary, as none of the alternatives are constrained by environmental and/or socio-economic impacts, it is recommended that all three sets of alternative layouts are authorised i.e. the two Powership positions, the two gas pipeline routes and the two transmission routes, with the preferred alternatives selected according to TNPA’s and Eskom’s detailed planning and technical requirements. These entities are instrumental in determining the technical feasibility of each option in line with their requirements and future plans. Preliminary discussions were undertaken as part of the EIA process however extensive engagements with TNPA, Eskom and Karpowership SA will be required once preferred bidder status is confirmed

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Figure 8-6 Proposed Gas to Powership Project Alternatives

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Table 9.1: Details of the Proposed Alternatives for the Proposed Gas to Power Powership Project at Saldanha Bay POWERSHIP ALTERNATIVES, FSRU AND TEMPORARY LNG CARRIER Alternative Coordinates Khan Class Powership (Small Bay Side) 33° 0'20.42"S 17°59'24.20"E Khan Class Powership (Big Bay Side) 33° 0'44.39"S 17°59'46.72"E Floating Storage Regasification Unit (FSRU) 33° 2'30.39"S 17°59'55.11"E LNGC 33° 2'32.20"S 17°59'56.10"E GAS PIPELINES Gas Pipeline Alternative 1 (Powership at Small Bay) Subsea (FSRU – Onshore Pipeline) Start 33° 2'29.16"S 17°59'55.29"E End 33° 0'34.16"S 18° 0'43.22"E Onshore to Subsea Start 33° 0'34.16"S 18° 0'43.22"E End 33° 0'42.17"S 17°59'32.02"E Subsea to Powership Start 33° 0'42.17"S 17°59'32.02"E End 33° 0'20.42"S 17°59'24.62"E Gas Pipeline Alternative 1 (Powership at Small Bay) Bend 1 33° 0'34.09"S 18° 0'43.13"E Gas Pipeline Alternative 1 (Powership at Small Bay) Bend 2 33° 0'23.97"S 18° 0'31.96"E Gas Pipeline Alternative 1 (Powership at Small Bay) Bend 3 33° 0'35.41"S 18° 0'17.98"E Gas Pipeline Alternative 1 (Powership at Small Bay) Bend 4 33° 0'26.28"S 17°59'49.67"E Gas Pipeline Alternative 1 (Powership at Small Bay) Bend 5 33° 0'29.46"S 17°59'40.60"E Gas Pipeline Alternative 1 (Powership at Small Bay) Bend 6 33° 0'40.36"S 17°59'35.43"E Gas Pipeline Alternative 1 (Powership at Small Bay) Bend 7 33° 0'39.84"S 17°59'33.67"E Gas Pipeline Alternative 1 (Powership at Small Bay) Bend 8 33° 0'42.39"S 17°59'32.53"E Gas Pipeline Alternative 1 (Powership at Small Bay) Bend 9 33° 0'41.37"S 17°59'30.01"E Gas Pipeline Alternative 1 (Powership at Small Bay) Bend 33° 0'24.60"S 17°59'37.93"E 10 Gas Pipeline Alternative 2 (Powership at Big Bay) Subsea (FSRU – Onshore Pipeline) Start 33° 2'29.06"S 17°59'55.50"E End 33° 0'34.04"S 18° 0'44.19"E Onshore to Subsea Start 33° 0'34.04"S 18° 0'44.19"E End 33° 0'41.07"S 17°59'38.40"E Subsea to Powership Start 33° 0'41.07"S 17°59'38.40"E End 33° 0'43.69"S 17°59'45.97"E

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Gas Pipeline Alternative 2 (Powership at Big Bay) Bend 1 33° 0'34.09"S 18° 0'43.13"E Gas Pipeline Alternative 2 (Powership at Big Bay) Bend 2 33° 0'23.97"S 18° 0'31.96"E Gas Pipeline Alternative 2 (Powership at Big Bay) Bend 3 33° 0'35.41"S 18° 0'17.98"E Gas Pipeline Alternative 2 (Powership at Big Bay) Bend 4 33° 0'26.28"S 17°59'49.67"E Gas Pipeline Alternative 2 (Powership at Big Bay) Bend 5 33° 0'29.46"S 17°59'40.60"E Gas Pipeline Alternative 2 (Powership at Big Bay) Bend 6 33° 0'40.36"S 17°59'36.87"E TEMPORARY LAYDOWN

Temporary laydown area 1 (central point) 33° 0'35.31"S 18° 0'41.72"E Temporary laydown area 2 (central point) 32°59'41.76"S 18° 0'19.79"E SWITCHING STATION Switching station (Alternative 1 only) 32°59'53.56"S 17°59'50.61"E TRANSMISSION LINE Alternative 1 –Tower 1 – 25 to Aurora-Saldanha Steel Start - 33° 0'3.29"S 17°59'47.34"E network End - 32°58'36.83"S 18° 1'39.22"E Alternative 1 – Mid point 32°58'48.68"S 18° 0'21.73"E Alternative 1 - Bend 1 32°58'48.16"S 18° 0'21.72"E Alternative 1 - Bend 2 32°58'28.79"S 18° 0'51.65"E Alternative 1 - Bend 3 32°58'21.27"S 18° 1'22.82"E Alternative 1 - Bend 4 32°58'23.27"S 18° 1'35.16"E Alternative 2 – Tower 1 – 35 to Blouwater Substation Start 33° 0'3.29"S 17°59'47.34"E End 32°58'53.42"S 18° 3'3.87"E Alternative 2 – Mid point 32°58'27.94"S 18° 0'55.03"E Alternative 2 - Bend 1 32°58'48.08"S 18° 0'21.49"E Alternative 2 - Bend 2 32°58'28.50"S 18° 0'51.86"E Alternative 2 - Bend 3 32°58'21.10"S 18° 1'22.82"E Alternative 2 - Bend 4 32°58'26.36"S 18° 1'52.70"E Alternative 2 - Bend 5 32°58'25.05"S 18° 1'57.68"E Alternative 2 - Bend 6 32°58'37.72"S 18° 2'32.65"E Alternative 2 - Bend 7 32°58'49.58"S 18° 2'50.72"E Alternative 2 – Bend 8 32°58'48.91"S 18° 2'54.90"E A1 – A5 Start 33° 0'41.56"S 17°59'33.71"E End 33° 0'5.15"S 17°59'50.13"E A1 – A5 Bend 1 33° 0'5.15"S 17°59'50.13"E B1 – B7 Start 33° 0'30.65"S 18° 0'3.79"E End 33° 0'0.46"S 18° 0'0.34"E B1 – B7 Bend 1 33° 0'8.30"S 18° 0'15.95"E

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EAP’S OPINION AND RECOMMENDED CONDITIONS OF AUTHORISATION Based on the findings of the independent specialist studies, the proposed project will not result in highly sensitive environmental or social impacts, given that all standards be adhered to and mitigation measures as well as specialist recommendations be implemented. It is the reasoned opinion of the EAP that the proposed 415MW Gas to Power Powership Project, should be authorised. This is however, subject to the implementation of the mitigation measures and monitoring for potential environmental and socio-economic impacts as outlined in the EIA Report and EMPr being implemented by Karpowership South Africa (Pty) Ltd.

The authorisation would include the following key infrastructure and components:  Powership;  FSRU;  Gas pipeline;  132 kV Transmission Lines;  Switching Station; and  Temporary laydown areas and stringing yard

It is the recommendation of the EAP that the following key management and mitigation conditions must be incorporated into the authorisation for the project:  All mitigation measures specified within this EIA Report, EMPr (Appendix G), as well as the specialist reports contained in Appendix I, are to be implemented.  The EMPr (Appendix G and its appendices) for this EIA Report must be a binding document between Karpowership South Africa (Pty) Ltd and the appointed contactor for construction and maintenance, in order to ensure compliance with environmental specifications and management measures.  It is recommended that external EMPr monitoring takes place by an independent Environmental Control Officer (ECO) to ensure that the requirements of the EMPr are being correctly implemented, thus ensuring the protection of the surrounding environment.  Permits from relevant provincial authorities, i.e. Biodiversity Permits from Cape Nature, must be obtained prior to the removal or relocation of those species of Conversation Concern.

Obtain all other mandatory and environmental permits for the project, as required.

PLEASE NOTE:  This is the Draft Environmental Impact Assessment Report that has been prepared by the EAP with input from the applicant and specialists in accordance with the prescribed requirements in the EIA Regulations, 2014 and guidance from the competent authority.  The EIA process provides for a second round of public participation after the Scoping Phase and this draft EIA Report, inclusive of specialist reports and the Environmental Management Programme (EMPr) will be made available for public comment.  Only then can the final EIA report be submitted to the competent authority and a decision made as to whether the application for environmental authorisation can be granted or refused.  If granted, the application for an atmospheric emission licence under the National Environmental Management: Air Quality Act of 2004 will be undertaken. Page 211

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Kaplan, J. 1998. Archaeological Study Proposed Public Access Road to the Port of Saldanha. Report prepared for Crowther Campbell and Associates. ACRM. Riebeek West

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