765Kv Eskom Powerlines Western Cape

PROPOSED KAPPA OMEGA 2ND 765KV ESKOM POWERLINES WESTERN CAPE

Heritage Impact Assessment component: Built Environment, Spatial History and Cultural Landscape

SCOPING AND ASSESSMENT REPORT

NOVEMBER 2014

HERITAGE WESTERN CAPE CASE NO: 121004JL09E Prepared For

Nzumbululo Heritage Solutions South Africa 4 Berger Road, Vorna Valley, Midrand 1686, South Africa Tel: +27 11 021 4937, +27 15 291 3661

SALLY TITLESTAD

HERITAGE CONSULTANTS IN ASSOCIATION

Mobile: 071 1090 900 Tel: +27 21 683 7085 Fax: 086 511 0389 Mobile: 072 212 8246 Tel 021 686 8124

Email: [email protected] Web: www.bridgetodonoghue.com Email: [email protected]

4 OAKDALE ROAD NEWLANDS 7708 CAPE TOWN SOUTH AFRICA 22 BIRKETT ROAD RONDEBOSCH 7700 CAPE TOWN SOUTH AFRICA

ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT

TABLE OF CONTENTS

EXECUTIVE SUMMARY VI GLOSSARY AND DEFINITIONS VII SECTION 1 INTRODUCTION 1

1.1 INTRODUCTION 1 1.2 LEGAL REQUIREMENTS 1 1.3 TERMS OF REFERENCE 2 1.4 PROPOSED POWERLINES AND ASSOCIATED INFRASTRUCTURE 2 1.5 BUILT ENVIRONMENT AND CULTURAL LANDSCAPE SCOPE OF WORK 3 1.6 APPROACH TO THE SPECIALIST STUDY 4 1.7 STUDY METHODOLOGY 5 1.8 ASSUMPTIONS AND LIMITATIONS 9 1.8.1 Assumptions 9 1.8.2 Limitations 9

1.9 SPECIALIST TEAM AND DETAILS 10 1.10 DECLARATION OF INDEPENDENCE 11 1.11 REPORT STRUCTURE 11

SECTION 2 PROJECT DESCRIPTION 12

2.1 INTRODUCTION 12 2.2 ALTERNATIVE ROUTES OPTIONS 13 2.3 PYLON TOWERS 14

SECTION 3 REGION AND SITES DESCRIPTION 16

3.1 INTRODUCTION 16 3.2 HISTORICAL OVERVIEW 16 3.3 CULTURAL LANDSCAPE 19 3.3.1 The Term ‘Cultural Landscape’ 19 3.3.2 Cultural Landscapes Occurring along Powerline Route Alternatives 20 3.3.2.3 The Swartland 23

3.4 BUILT ENVIRONMENT 26

SECTION 4 HERITAGE LEGISLATION & ASSESSMENT CRITERIA 27

4.1 INTRODUCTION 27 4.2 ADMINISTRATIVE CONTEXT AND STATUTORY FRAMEWORK 27 4.2.1 Overview 27 4.2.2 National Heritage Resources Act No. 25 of 1999 (NHRA) 27 4.2.3 Existing Heritage Studies 28

4.3 HERITAGE ASSESSMENT CRITERIA 29 4.3.1 Definition of Cultural Significance and Criteria for the Assessment of Cultural Significance 29 4.3.2 Contextual/Experiential Significance 30

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4.3.3 Assessments of Impacts 31

4.4 HERITAGE DESIGN INDICATORS 32 4.4.1 Scoping Phase Guidelines 32 4.4.3 Assessment Phase Local Scale Heritage Design Indicators 34 4.4.4 Assessment Phase Micro Scale Heritage Design Indicators 36

4.5 IMAGES AND DEPICTIONS OF ROUTE ALTERNATIVES 37

SECTION 5 IDENTIFIED HERITAGE RESOURCES & STATEMENTS OF HERITAGE SIGNIFICANCE 57

5.1 INTRODUCTION 57 5.2 ROUTE OPTION 1 57

SECTION 6 IMPACT ASSESSMENT 71

6.1 INTRODUCTION 71 6.2 SCOPING PHASE ASSESSMENT 71 6.3 ASSESSMENT PHASE 71 6.4 ZONES AND ROUTE OPTIONS 72 Table 6.1 Impact Assessment Route Option 1 Zone 1 73 Table 6.2 Impact Assessment Route Option 1 Zone 2 74 Table 6.3 Impact Assessment Route Option 1 Zone 3 85 Table 6.4 Impact Assessment Route Option 1A Zone 3 97 Table 6.5 Impact Assessment Route Option 2 Zone 3 98 Table 6.6 Impact Assessment Route Option 1b Zone 3 106 6.5 SUMMARY OF IMPACT ASSESSMENT 106

SECTION 7 RECOMMENDATIONS 109 SECTION 8 BIBLIOGRAPHY OF SOURCES 110

ANNEXURE 1: RECORDS OF DECISION APPLICABLE TO THE STUDY 115 ANNEXURE 2.1: BRIEF HISTORICAL TIMELINE FOR THE WARM AND KOUE BOKKEVELD AND TULBAGH VALLEY 119 ANNEXURE 2.2: BRIEF HISTORICAL TIMELINE FOR THE SWARTLAND 126

ANNEXURE 3: MAPS 139

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TABLE OF FIGURES:

Figure 1: Location of proposed new 765kV transmission line within South Africa, powerline corridors located within red circle (Metro GIS, 2013) 12

Figure 2: Kappa Gamma 2nd 765kV powerlines, Metro GIS 2013 13

Figure 3: Pylons for 765kV powerlines (ESKOM Line Engineering services, ESKOM 400kV and 765kV Tower Guide May 2013) 14

Figure 4: Existing powerlines immediately south of Gamma substation, iillustrating the difference in height between 400kV self supporting suspension pylons and the 765kV Guyed-V suspension pylons (765kV powerline right), BOD/ST 2013 15

Figure 5: Diagram showing three cultural landscape zones. For the purpose of historical depiction, the Mountainous region and the entrance into the Ceres Karoo are dealt with jointly (adapted from MetroGIS, 2013) 16

Figure 6: Diagram showing cultural landscape zones in relation to the proposed powerline routes (MetroGIS, 2013) 21

Figure 7: Ceres Valley from Gydo Pass (photograph Judelle Drake) 22

Figure 8: Agricultural patterning of the Swartland and the visual connections between settlements nestled into the foothills of mountains (photograph Kay McCormick, 2014) 23

Figure 9: Cultural landscape elements and context of heritage resources in the context of alternate route Options 1,2 and 3, with emphasis on the route options being considered at impact assessment phase. (adapted from Metro GIS) 25

Figure 10: Images from Kappa Substation to Karoopoort 37

Figure 11: Landscape and approach to the R46 scenic routes from the R355 38

Figure 12: Images Karoopoort Outspan to Ceres including Hottentotskloof and Theronsberg Passes, scenic routes 38

Figure 13: Images Ceres Valley Context 39

Figure 14: Images Wolseley Context 40

Figure 15: Images of Elandsberg Farms and Landscape Context 41

Figure 16: Images of Riebeek Kasteel and Landscape Context 45

Figure 17: Images Saron Mission Settlement and Landscape Context 46

Figure 18: Images Riebeek Valley 47

Figure 19: Images Porterville and Landscape Context 48

Figure 20: Images Proposed Route 3 between Porterville and Piketberg 49 ______iv

Figure 21: IMAGES SWARTLAND PORTERVILLE, PIKETBERG AND KORINGBERG CONTEXT 49

Figure 22: Images Piketberg 50

Figure 23: Images Koringberg 51

Figure 24: Images R45 Roadway 52

Figure 25: Images Approach Darling 53

Figure 26: Images Philadelphia & Context 53

Figure 27: Images Kalkbaskraal 54

Figure 28: Images Abbotsdale 55

Figure 29: Images Klipheuwel 56

Figure 30: Kappa Omega 2nd 765kV powerlines corridors options 1, 1a, 1b (red, orange and yellow lines), Option 2 (blue line, depicted as blue and pink where it coincides with proposals from Option 1), Option 3, 3a, 3b, 3c [purple line with colour variants on the west], Metro GIS 2013 57

Figure 31: Diagram of Cultural Landscape Elements and Informants (adapted from MetroGIS) 71

Figure 32: Kappa Omega Assessment Zones 72

Figure 33 (right): portion of map 29 showing the point at which route option 2 assessment begins in relation to contextual topography (MetroGIS2013) 98

Figure 34: Diagram depicting portion of route option 2 which coincides with route 1a, studied at impact assessment phase. 106

Figure 35: Connection between recomended routes that will require specific and close attention to avoid negative impacts on Heritage Reources 108

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION EXECUTIVE SUMMARY

This assessment constitutes specialist input on spatial history, cultural landscape and the built environment towards the Heritage Impact Assessment component of and EIA conducted in line with the requirements of the National Environmental Management Act (Act 107/1998).

The proposal is for a second 765kV powerline between Koruson (Kappa) substation near Ceres to Sterekus (Omega) substation near Koeberg in Cape Town. Three alternative powerline routes (with variations along their length) identified by ESKOM all start at Kappa and end at Omega. An alternative travels via Aurora substation. This specialist assessment identifies, assesses and maps the heritage resources within the three identified alternative 4km powerline corridors. It also provides heritage design indicators for development and assesses the potential impacts of the proposed powerlines on the identified heritage resources within the corridors. It assesses the impacts of the proposals on spatial history, cultural landscape and the built environment.

The recommendations of the assessment are that the heritage indicators are adopted, and that Option Route 1, 1a and 2, south of Riebeek Kasteel and the R46 Scenic Route, as the preferred route due to the lower impact on settlements and landscapes is endorsed, with the adoption of mitigation measures contained in the Tables 6.1- 6.6.

GLOSSARY AND DEFINITIONS

The approach to the definitions and application of the HIA is extracted from the National Heritage Resources Act, no 25 of 1999 and the ICOMOS Australian Burra Charter, revised in 1999.

Adaptation The process of adaptation introduces a sufficient degree of flexibility to the treatment of a place or resource to enable change to be managed and still fulfil conservation objectives (Kerr, Baumann). Such change should be appropriate and should not affect the cultural significance of a structure or site.

Associations Associations mean the special connections that exist between people and a place. Significant associations between people and a place should be respected, retained and not obscured. Opportunities for the interpretation, commemoration and celebration of these associations should be investigated and implemented.

Archaeological resources Material remains resulting from human activities which are older than 100 years including artefacts, human and hominid remains and artificial features and structures which are in a state of disuse. They may also include rock art, marine shipwrecks and structures associated with military history (NHR Act).

Authenticity That which is genuine or original and not in an altered or modified state. Authenticity may reside in the fabric itself with its evidence of workmanship and age, or in the design and layout of a place or in the integrity of traditions. It may reside in use, customs, appropriate technology and ownership associated most closely with the heritage resource (Kerr, modified).

Compatible use Compatible use means a use that respects the cultural significance of a place. Such a use must have minimal or no impact on cultural significance.

Context The area around a place or heritage resource, which may include the visual catchment (Burra). (May also refer to how a resource is “read” and understood, and as a result may refer to the histories and societal values associated with it.)

Conservation Conservation means all the processes of looking after a place so as to retain its cultural significance.

Contextual value The cumulative value associated with an object or place when read as part of a whole. (MA).

Cultural landscape A physical area with natural features and elements modified due to human activity and resulting in patterns of evidence layered over time in the landscape, which give a place its distinctive spatial, historical, aesthetic, symbolic and memorable character (Lennon, Australia- modified).

ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT

Cultural significance Cultural significance means aesthetic, historical, scientific, social or spiritual value for past, present or future generations. Cultural significance is embodied in the place itself, its fabric, setting, use, associations, meanings, records, related places and related objects. Places may have a range of values for different individuals or groups. The cultural significance of a place and other issues affecting its future are best understood by collecting and analysing the required information before making decisions.

Conservation (of heritage resources) The processes necessary for managing heritage resources so as to retain their cultural significance. These may include protection, maintenance, preservation and sustainable use of resources and adaptive re-use. Conservation requires the retention of an appropriate visual setting and other relationships that contribute to the cultural significance of the place. New construction, demolition, intrusions or other changes which would adversely affect the setting or its relationships are not appropriate.

Cultural heritage What society inherits and attaches sufficient value to, to nurture for future generations, while at the same time recognizing the value of the past.

Development Physical intervention, excavation or action other than those caused by natural forces, which may change the nature or appearance of a place. Those may include construction, alteration, demolition, removal or change of use of a place or structure at a place, the removal or destruction of trees or changes to the natural topography of the land (NHR Act).

Heritage Indicators Using a combination of topography, settlement patterns and the heritage significance of cultural landscapes and built structures, a series of constraints and opportunities for appropriate new development are generated. These are used as the basis for assessing impacts of a proposal.

Heritage resources Places or objects of cultural significance. (NHR Act)

Heritage area Designated area of special architectural historic, social, symbolic, aesthetic/scenic character which are protected by legislative mechanisms either at a provincial or local level.

Heritage management The sensitive and sustainable management of heritage resources and the application of the relevant laws within the context of development and community values (MA).

Heritage Impact Assessment (HIA) A requirement of the National Heritage Resources Act (Section 38) whereby development of a certain magnitude and character require the assessment of the impact of the development on the heritage resources on the site.

Intrinsic value A heritage resource that has value in its own right, either for reasons of aesthetic, architectural and scientific excellence, or the stories and persons associated with the resource. ______viii

Interpretation Interpretation means all the ways of presenting the cultural significance of a place.

Intangible heritage Non-material heritage or non-material culture including traditions, oral history, ritual, ceremonies, language, popular memory and indigenous knowledge systems (NHR Act).

Object Any movable property of cultural significance, which may be protected in terms of the NHR Act.

Place A site area or region, a building or structure, a group of buildings, an open space, including a public square, street or park, and the immediate surroundings of a place (NHR Act). Place means site, area, land, landscape, building or other work, group of buildings or other works, and may include components, contents, spaces and views (Burra Charter). The physical location of a place is part of its cultural significance. A building, work or other component of a place should remain in its historical location. Relocation is generally unacceptable unless this is the sole practical means of ensuring its survival. Meanings denote what a place signifies, indicates, evokes or expresses. Related place means a place that contributes to the cultural significance of another place.

Preservation Preservation is appropriate where the existing fabric or its condition constitutes evidence of cultural significance, or where insufficient evidence is available to allow other conservation processes to be carried out.

Significant meanings Significant meanings including spiritual values, of a place should be respected. Opportunities for the continuation or revival of these meanings should be investigated and implemented.

Setting Setting means the area around a place, which may include the visual catchment.

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SECTION 1 INTRODUCTION

1.1 INTRODUCTION Nzumbululo Sustainable Energy and Environmental Solutions, on contract to ESKOM Holdings Soc Limited, appointed heritage consultants Sally Titlestad and Bridget O’Donoghue in association, for the specialist assessment of the spatial history, cultural landscape and built environment component of the Heritage Impact Assessment (HIA) (Scoping and assessment phases) for the proposed Kappa Omega 2nd 765kV powerlines. This specialist assessment identifies, assesses and maps the heritage resources within the three identified alternative 4km powerline corridors. It also provides heritage design indicators for development and assesses the potential impacts of the proposed powerlines on the identified heritage resources within the corridors. This specialist assessment does not assess impacts of the substations themselves, which are part of separate proposals.

1.2 LEGAL REQUIREMENTS This is a specialist report component of a Heritage Impact Assessment (HIA) being conducted within an Environmental Impact Assessment (EIA). The HIA and EIA are undertaken by Nzumbululo in compliance with the National Environmental Management Act, Act 107/1998 (NEMA), and Environmental Impact Assessment (EIA) regulations No 543 of 2010.

The National Department of Environmental Affairs (DEA) is the decision-making authority for the EIA. The Western Cape Provincial Government (WCPG) Department of Environmental Affairs and Development Planning (DEA&DP) will comment on the EIA to DEA. (NEAS reference: DEA/EIA/0001267/2012 and DEA Reference 14/12/16/3/3/2/353).

Integration of the specialist studies into a Heritage Impact Assessment in terms of Section 38(8) of the National Heritage Resources Act, (Act 25/1999) (NHRA) is undertaken by Nzumbululo Heritage Solutions. Heritage Western Cape (HWC) will be the commenting authority on the HIA to DEA&DP and DEA on resources situated in the Western Cape.

In terms of the NHR Act Section 38 (1) a Notification for Intent to Develop (NID) was submitted to HWC by Nzumbululo in 2012. The NID identified the alternative powerline corridors and the proposed scale of the pylons. The HWC Decision, dated 17 October 2012 on the NID was:

“Since there is reason to believe that heritage resources will be impacted upon, HWC requires an HIA in terms of S. 38(3) (Act 25 of 1999) assessing the impacts to all identified heritage resources within a 10km corridor around the proposed line, including but not limited to mountainscapes, natural and cultural landscapes, declared natural areas and conservancies, agricultural sites, scenic routes, archaeological and paleontological resources. The 4 proposed alternative lines must each be assessed for their relative impact to heritage resources. The outcome of the Public Participation Process must be included in the HIA” .

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT As ESKOM was dissatisfied with the HWC decision that assessment should be conducted across 10km corridors for each alternative corridor, ESKOM officials and Nzumbululo legal representatives discussed the HWC decision at the HWC IACOM meeting on 13 January 2013. HWC adjusted their decision and the final comment on the NID was dated 27 February 2013:

“Heritage Western Cape agreed that the request to reduce the study corridors from 10km to 4km is accepted but reserves the right to require wider corridors in particular areas if necessary on basis of information coming from the EIA process”

(refer Annexure 1: HWC Decision 12 October 2012 and Final Comment 13 February 2013).

1.3 TERMS OF REFERENCE The broad terms of reference for this study are an assessment of the impacts of the proposed transmission lines on the historical built environment and cultural landscape in terms of Section 38(8) of the NHRA. The minimum requirements for HIA’s are set out in section 38 (3) of the NHRA. These are:

 The identification and mapping of heritage resources.  Assessment of the significance of heritage resources in terms of the criteria set down by the Act (refer section 4 and methodology and limitations for detailed application).  Assessment of the impacts of the proposals on resources identified, and evaluation of impact relative to the sustainable social and economic benefits to be derived from the development.  If heritage resources will be adversely impacted, the consideration of alternatives.  Recommendations for mitigation of adverse impacts where these are identified.  As requested by HWC in initial consultation, an evaluation from the specialists on the benefits or otherwise of introducing new infrastructural corridors as opposed to the cumulative impacts of a second 765kV line in the already approved first corridor.

1.4 PROPOSED POWERLINES AND ASSOCIATED INFRASTRUCTURE A second ESKOM 765kV transmission powerline is proposed in the Western Cape, from the Koruson (Kappa) substation near Ceres to Sterekus (Omega) substation near Koeberg in Cape Town. The project motivation is incremental growth in electricity demand in the Western Cape and the limitation of the existing substructure to meet this demand. The provision of additional power to the Western Cape is considered important to meet projected demand and to improve the stability and reliability of the power supply.

The project includes the upgrade of the existing Omega substation in order to accommodate the 765kV transmission line as a separate proposal from the lines themselves. Auxiliary infrastructure includes feeder bays and service roads.

All proposed route alternatives are located within the Western Cape Province of the Republic of South Africa. Due to their linear nature and length, each of the proposed route alternatives traverses a number of Local Municipal level administrative areas located within District Municipalities.

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The three alternative powerline routes identified by ESKOM for assessment all start at Kappa substation and end at Omega substation. The Kappa - Omega 765kV section averages approximately 415km in length but the different routes have markedly different lengths.

The sites proposed for these developments vary in cultural landscape character, spatial history, and to some degree their built environment structures vary: route options traverse mountainous areas, scenic routes, settlements, agricultural lands, nature reserves, and identified sites of heritage significance.

A detailed description of the route alignments for each alternative is provided in Section 2.

1.5 BUILT ENVIRONMENT AND CULTURAL LANDSCAPE SCOPE OF WORK Based on the terms of reference for the study, the scope of work entails the provision of specialist heritage services to the HIA Phase 1 and 2 (Scoping and Assessment Phases) required in terms of section 38 of the NHRA. This specialist assessment is submitted to Nzumbululo for integration with other Heritage Impact Assessment specialists’ reports into a submission to the Impact Assessment Committee (IACOM) of the Provincial Heritage Authority, Heritage Western Cape (HWC) for comment.

The aim of the Scoping Phase was to assess the affected areas within a 4km corridor of eight possible proposed route sections for potential negative impacts. The Scoping Phase identified the routes with the least negative impact on identified significant heritage resources, and excluded the proposed northern route as a possibility. This provided the HIA team with three possible alternatives and factors to study further for impact, and the EIA team with clear information about which routes will have the lowest impact from a heritage (built environment, spatial history and cultural landscape) perspective.

The HIA scoping phase specialist assessment achieved the following scope of work:

 Consultation with heritage authorities has taken place to ensure that all required directives are being followed at the outset of the project.  Research into the history of the settlements, context and specific heritage resources: Collection and review of project information and previous studies conducted within the area of the proposed routes. This has been analysed and mapped to establish the density and significance of the heritage resources and issues along the proposed routes in relation to patterns of human occupation and land use over time;  Site visits of all alternative routes.  Project initiation meetings with Nzumbululo and an integration workshop with all project specialists at Scoping Phase completion.  Identification and mapping of all significant heritage resources on the sites within the 4 km corridors that could be affected by these development proposals.  Assessment of the significance of the identified heritage resources in terms of the NHRA criteria at settlement level (villages and towns).  Identification of relevant heritage design indicators.

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT  As requested by HWC, an evaluation from the specialists on the benefits or otherwise of introducing new infrastructural corridors as opposed to the cumulative impacts of a second 765kV line in the already approved first corridor.  Exclusion of route option 2 and 3 between Kappa and their exit into the Berg River Valley (pristine wilderness and the degrees of impact), coupled with serious concerns about their direct crossing of the valley and the open agricultural plain surrounding Piketberg (a recommended Provincially significant landscape1).  Identification of issues and concerns for further study on the preferred routes (Option 1, 1a and 1b).

All Public Participation Processes (PPP) are undertaken within the EIA. No separate consultation with local conservation civics has been undertaken by the built environment and cultural landscape specialists. The visual impact assessment (VIA) has been undertaken as a specialist study and the integration of this information into the EIA is undertaken by Nzumbululo.

The HIA cultural landscape and built environment Assessment phase study achieved the following scope of work:

 Detailed study of the preferred route and its possible alternatives (options 1, 1a, and 1b), while mapping existing and possible heritage resources for all eight proposed routes.  Assessment of the impacts of the proposals on cultural landscape and built environment resources identified, and evaluation of impact relative to the sustainable social and economic benefits to be derived from the development.  Where heritage resources will be adversely impacted, the consideration of alternatives, and additional site visits where applicable .  Identification of heritage sensitive and no-go areas, and where these are identified recommendations for use of alternate routes.  Recommendations for mitigation of adverse impacts where these are identified on sensitive sections of routes.  As requested by HWC, an evaluation from the specialists on the benefits or otherwise of introducing new infrastructural corridors as opposed to the cumulative impacts of a second 765kV line in the already approved first corridor are assessed at site scale.

The preparation of integrated HIA and EIA reports will be undertaken by the Principal Investigator, Nzumbululo. The report will integrate the heritage specialists’ findings and comment on the potential heritage issues associated with each route and identify potentially suitable powerline routes that can be taken forward and assessed during the walk down and construction phases should the proposal be approved by the relevant authorities.

1.6 APPROACH TO THE SPECIALIST STUDY The proposed approach to this specialist study is based and guided by the following reports, legislation and guidelines:  NHRA.

1 Winter & Oberholzer, 2013. ______4

BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT  Guidelines for Involving Heritage Specialists in EIA processes: Edition 1 CSIR report No. ENV- S-C 2005 053 RSA, Provincial Government of the Western Cape, Department of Environmental Affairs and Planning, Cape Town (DEA&DP). These guidelines are based on accepted international best practice guidelines.  Heritage Western Cape Guidelines for Heritage Grading.  International Council on Monuments and Sites (ICOMOS) Burra Charter (1999).

The specific approach to the assessment is defined by the linear nature of the proposed development and the complexity of heritage factors across the areas covered by the proposals. In this regard linear infrastructure projects, such as powerlines, create unique challenges due to the linear extent of the impact and the large areas whose heritage resources are potentially impacted by the proposed new infrastructure.

This specialist input will form part of an integrated HIA-EIA process for the implementation of the National Environment Management Act and its guidelines through the DEA&DP and the implementation of the NHRA through Heritage Western Cape (responsible for the management of heritage resources in the Western Cape).

The proposed Kappa - Omega powerlines assessment is approached from a macro, regional and micro scale. Consultation with the relevant heritage authority, Heritage Western Cape (HWC) early in the assessment process has ensured that full compliance with their requirements is met.

While the assessment cannot guarantee the successful outcome of the proposed project, the Heritage Assessment Practitioners believe that the integration and the area specific approach present a manner of assessing the degree of impact weighed against the degrees of heritage significance of sites.

1.7 STUDY METHODOLOGY The methodology implemented in this assessment included the following:

 Route alternatives: ESKOM Transmission determined route alternatives before the beginning of the project, based on existing ESKOM lines and servitudes, feedback from the first 765kV line application and the need to extend electrical power supply to the Western Cape. Specialists were not involved in route selection.  Study corridors: The study corridors for the EIA are a 1km buffer zone either side of the proposed route/s. As outlined above, the study corridors for the heritage specialists’ inputs were determined through a process of negotiation between ESKOM Transmission and HWC, for a 4km corridor, with the proposed route marking the central line of that corridor, has been used as definition and assessment. Should the position of the line be moved within the study corridor, it is possible that structures and settlements that have not been assessed may be impacted. For this reason, assessment tables include position of the resource in the corridor, and where known resources of significance close to the edge of the corridor, this has been noted.  Collection of baseline information: Previous studies, most importantly those included in the application for the first 765kV line have been consulted. Baumann and Winter’s scoping report and Jacobs phase 2 assessment have been extensively studied, and the methodology and conceptual frameworks of this report incorporate the guidelines set down in those ______5

BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT studies. Applications submitted to HWC and SAHRA prior to July 2013 that are recorded and publicly accessible and that fall within the corridors of this study have been consulted, and their findings incorporated into the baseline of this report where appropriate.  Historical Overview: Baseline information gathered was combined with historical cartography and published secondary sources, mapped and timelines for the areas created. Themes and patterns relating to historical settlement and periods of change were noted and used to define the assessments of heritage significance and cultural landscape.  Fieldwork: Baseline historical information and mapping provided the basis for fieldwork sessions. An initial five-day field trip covering the entire length of all route alternatives between Gamma and Omega was in undertaken in May 2013 but was limited to those sites accessible by motor vehicle from regional routes. Follow up site visits were made to three sections of line during the process of impact assessment. Not all sites have been physically visited, and in many cases the markers of structures over 60 years have been sufficient from previous projects and mapping assessments to ensure confidence of significance and impact. Further series of fieldwork will be required following the selection of the preferred route and prior to composite team site visits (walk down). This will ensure integration of visual assessment with heritage assessment and will assist with determination of appropriate mitigation.  Establishing Heritage Indicators: Guiding principles relating to the appropriate location of large transmission lines within cultural landscapes of significance and in close proximity to built environments of heritage significance were established by a combination of the above. During the Assessment Phase these were developed into indicators at sub-regional, local and micro (site specific) levels (refer section 4). These informants provided the analytical framework for the assessment process.  Assessment of Impacts, scale of impacts, adverse sections of routes and mitigation measures: Impacts of the proposals on cultural landscapes, settlements and on individual resources have been undertaken in terms of the analytical framework established by Heritage Indicators. Assessment tables identify, describe, assess impacts and their scale, and provide mitigation measures and/or directives for implementation on the preferred route and its linked alternatives.  Specialist assessment Mapping conventions and Map book: The Gamma-Kappa and Kappa- Omega considerations were made as part of an iterative assessment process. They are separated in report form, as they constitute two separate projects. An A3 Map book provides a continuous mapped assessment of built environment and cultural landscape considerations across both projects (refer Annexure 3). Maps included with this Annexure are the Gamma-Kappa-Omega sections of the route options. Mapping of the proposed lines and the associated or affected heritage resources is required by section 38 of the NHRA.

The process of mapping and depiction has been continuous throughout the project as follows:

o Kmz or Google earth compatible files depicting the proposed alternatives were received from ESKOM at the beginning of the study phase. These were transmitted into a Geographical Information Systems (GIS) format and embedded onto 1:50 000 topo-cadastral maps of the entire study area. The topo-cadastral base provides important additional detail including farm names. o Adjustment of the corridors from 2km to 4km was implemented. ______6

BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT o In order to achieve as accurate a depiction as possible of buildings over 60 years the oldest 1:50 000 topo-cadastral maps of the extended area were used. For parts of the affected area, topo-cadastral maps were first drawn fairly recently. In such cases the oldest and closest to 1953 was used, with the date of the map being noted in the naming of places. o Existing covered structures and nodes within the corridors were located and place marked on Google Earth. This was done by cross-referencing Google Earth imagery with recent edition 1: 50 000 topo-cadastral maps. o Identification of existing covered structures/ nodes within identified subject areas on Google Earth, and assigning a place mark to each. This was done by examining the most recent Google Earth satellite imagery, cross-referenced with recent edition 1: 50 000 topo-cadastral maps for each of the relevant search areas; o Demarcation of urban search exclusion zones. Urban edges were drawn in on the basis of the plans/ SDPs for the relevant towns in the SDFs for the relevant areas. Note that the relevant SDFs are all approved/adopted documents, certain of which included in the Land use Planning Ordinance no. 15 of 1985 (LUPO). The relevant SDFs were also used as the basis for drawing in scenic routes; o The 2012-2017 Swartland SDF Heritage Plan for Riebeek Kasteel was used as the basis for defining the Riebeek Kasteel urban heritage area. The demarcated area indicates the outer extent of the area containing identified heritage resources (i.e. not all structures within this area are of heritage significance); o Identification of potential heritage significance of identified existing structures/ nodes, by comparing each place mark against historical 1: 50 000 topo-cadastral maps. Use was made of the nearest historical record to 1953 (not necessarily the oldest). Structures that do not appear on historic maps were screened out (“recent”). For those which do appear, the name and number of structures mapped at the time, as well as the mapping date, were recorded (in the label) - e.g. Vrede (69T – 3) = Farm Vrede (1969 topo-cadastral – 3 structures on 1969 map); o In tandem with the previous step, historic and recent 1: 50 000 topo-cadastral maps for the relevant areas were checked for markers indicating cemeteries, graves, blockhouses and other monuments, and such information recorded. A number of graves indicated on historic maps are no longer indicated on recent maps. In a number of instances, Google Earth imagery indicates still clearly discernible (farm) cemetery footprints, while in others the exact location is no longer describable. o Provincial Heritage Sites were included from the currently accepted list2 provided by Heritage Western Cape. o The draft Provincial Development Framework was consulted and recommended sites, landscapes and scenic routes that were graded in the draft document were included.

2 An undated document entitled ‘National Monuments Council, Western Cape Regional Office Administration of Conservation Register of Specific Cases (e.g. 9/2 files)’ was confirmed by pers. Comm. Christina Jikela, 17.2.2014 to constitute the current list, which is ‘up for review’. ______7

BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT Exclusions: Structures inside currently demarcated urban edges were excluded as settlements were assessed and graded. Uncovered structures, e.g. kraals, weirs, dams were not marked nor counted, but have been noted in assessment. Historic and modern ruins have not been marked unless they are provincial heritage sites, as they form part of the archaeological assessment. San rock art/ Bushman painting sites have not been shown, to protect the sites.

Table 1.1 Mapping Icons for Heritage Assessment

ICON EXPLANATION

Distributions Substation Transmission substation Urban areas

Urban conservation area

Provincial Heritage Sites

Rural node 20+ structures at the time of first topocadastral depiction

Rural node 10+ structures at the time of first topocadastral depiction

Rural node 5-10 structures at the time of first topocadastral depiction

Rural node under 5 structures at the time of first topocadastral depiction

Recent (excluded) white dots without labels

Cemeteries and graves

Railway sidings

Block Houses

Scenic routes (from sources other than those below, detail in assessment tables) Depictions included from the draft Western Cape Spatial Development Framework: Major (provincial) scenic routes Secondary and linking (Local) scenic routes Recommended National Heritage Resource (Landscapes) Recommended Provincial Heritage Resource (Landscapes)

Recommended Local Heritage Resource (Landscapes)

Please note that the 1st 765kV powerline, currently under construction is mapped as an existing powerline in blue. This allows comparison of the current and proposed 765kV line routes.

Naming conventions on the mapping series Note that the name used below is an example  Houmoed (61T – 3) – Main werf.  (Houmoed) (61T – 3) – secondary node on Houmoed.  “Houmoed” (61T – 3) – historic (data record) name (where changed).  ? Grave (69T) – grave indicated on 1969 map (not recent), but location no longer clear.

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT MAPPING LIMITATIONS  The 1: 50 000 data record does not precisely match the 1953 search date. The record for the area covers the period 1941 to 1987, with the bulk of records dating to the 1960’s. Urban areas and areas of dense settlement are generally covered by maps from the 1940’s, the 1950’s, the 1960’s, or a combination thereof.  Historic structure counts indicate the number of structures at a location at the time of the record only. Historic footprints have not been matched up with current ones. Existing structures may therefore not necessarily indicate historic ones.  No information is provided with regard to current sizes of nodes. Primary, secondary and unused structures are not differentiated,  Visual impacts have not been depicted in the mapping exercise as the VIA forms part of a separate study within the EIA.  The status of Provincial Heritage sites remains unclear as the undated record of the National Monuments Council has not been reviewed to date.

1.8 ASSUMPTIONS AND LIMITATIONS 1.8.1 Assumptions The following items are assumed:

 The data on the proposed project provided by Nzumbululo Heritage Solutions is accurate and up to date at the time of finalising the report.  The proposed transmission line routes identified by ESKOM are technically feasible.  The technical data provided by ESKOM is accurate and sufficient for the assessment of the proposed routes.

1.8.2 Limitations The specialist assessments of the HIA have faced the following limitations:

 All corridors were selected by ESKOM prior to the initiation of the HIA.  The exact measurement of the servitude required for construction and maintenance may vary depending on which pylons are implemented in different places. Measurements cited in this report have been provided by ESKOM and the PI team.  The assessment of cultural landscape cannot be determined in absolute terms.  Meetings of the specialists have only occurred twice during the study period, resulting in minimal cross reference of specialist inputs.  Visual impact assessment and public participation are separate specialist studies and have not been available to the built environment and cultural landscape specialists.

The specialist assessments and report have produced the following limitations:

 This assessment does not consider the ancillary project infrastructure required for construction and maintenance (such as access roads, borrow pits, soil dumps, construction worker housing, etc.), nor does it take into account possible impacts of the expansion of existing substations to accommodate the new transmission lines. Expansion of the substations form separate studies. It is envisaged that ancillary infrastructure will be

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT considered once a preferred route has been selected and design and implementation of the project continue.  Applications for projects working on alternative sources of power generation have not been mapped in this assessment. This assessment is aware of a number of wind and solar energy proposals in the Western Cape, but has not assessed the need for transmission lines from those proposals.  Age of buildings older than 60 years cannot be precisely established from topocadastral maps, and are therefore estimates given the data available.  SAHRA and Heritage Western Cape have a memorandum of agreement in place regarding Grade I (National) and II (provincial) heritage sites. It is not clear at the present time which of these sites have been declared and which are ‘regarded’ as sites in the cited category but have not yet been declared.  Public participation and visual assessment has not been integrated at the level of this specialist report as it falls within the scope of work of the Principal Investigator.  Assessments of archaeological and paleontological resources (and impacts thereon) have been undertaken as separate specialist studies, and are not depicted within this report. Integration of archaeological and paleontological impacts with the spatial history, cultural landscape and built environment assessments is therefore not part of this specialist study, and will be addressed by Nazumbululo at the HIA level.  The processes and outcomes of the VIA and public participation will be integrated into the HIA by the Principal Investigator, and have not been accessible to the built environment specialists.

1.9 SPECIALIST TEAM AND DETAILS The Built environment specialist team consists of Bridget O’Donoghue and Sally Titlestad.

Bridget O’Donoghue (B Arch, UCT; M Phil (Environmental Science), (UCT) has extensive heritage experience in public organisations and the private sector. As a registered Architect and accredited Professional Heritage Practitioner, Bridget has the qualifications and the skills to conduct complex heritage impact assessments that deal with the built environmental and cultural landscape issues. During her position within the City of Cape Town, Bridget managed development in sensitive heritage and natural areas in the urban and rural landscape. She has an extremely good practicing understanding and knowledge of national, provincial, and local legislation applicable to development. As a private consultant since 2007, Bridget has completed numerous heritage assessments, audits, and surveys for public and private clients. Work for public clients has included a Heritage Impact assessment for Green Market Square, Bo Kaap Quarries, Relocation of the Cenotaph and Adderley Street IRT Bus Station, and surveys of Sculptures, Monuments, and Memorials within the CCT on public land, heritage surveys and reviews of heritage area boundaries.

Sally Titlestad (B Soc Sci (Social Work)(Hons), UCT; BA (Psych) (Hons), UWC; MPhil Arch (UCT) is a senior independent specialist spatial historian and heritage management consultant on complex projects. She has been part of the PI team for the Department of Public Works (Groote Schuur Presidential Estate) Integrated Conservation and Management Plan, has prepared and presented expert evidence to the Land Claims Court and is the Principal Heritage Consultant to the Lutheran Church in Cape Town. Sally is an accredited Professional Heritage Practitioner.

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT 1.10 DECLARATION OF INDEPENDENCE This is to confirm that Sally Titlestad and Bridget O’Donoghue are responsible for undertaking the above specialist studies and are independent and have no vested or financial interest in the proposed development on the alternative routes being either approved or rejected by the relevant authorities.

1.11 REPORT STRUCTURE The report is divided into 8 Sections, namely:

Section 1: Introduction: Presents the site description, terms of reference and report structure. Section 2: Project Description: includes the powerline routes and infrastructure description. Section 3: Regions and Sites Description: Includes the historical background and physical description of the sites and the context. Section 4: Heritage Legislation and assessment criteria: outlines legislation applied in the assessment, defines cultural landscapes, identifies sensitivities, and provides Heritage Indicators for the proposed project at regional, local and at site specific scales. Section 5: Identified heritage resources and statements of cultural significance/s: Provides a brief definition of settlements and collections of resources, identifying features of heritage significance and providing a recommended grade for settlements and landscape features of significance. Section 6: Assessment of impacts measures the scale, permanence and degree of impact, recommending mitigation where appropriate Section 7: Recommendations: Presents the cultural landscape and built environment recommendations for the preferred route Section 8: Bibliography

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SECTION 2 PROJECT DESCRIPTION

2.1 INTRODUCTION The proposal is to construct a second powerline of approximately 415km carrying 765kV from Kappa substation in the Western Cape near Touws River to Omega substation near Koeberg, Cape Town in the Western Cape. The initial 765kV powerlines from Kappa to Omega has been approved and construction is planned in 2013/2014.

By constructing the powerline, ESKOM wishes to address the existing electricity network constraints and the projected electricity demand within the Western Cape. Koeberg Nuclear Power Station generates the majority of electricity for Cape Town. When the station requires maintenance or a shutdown occurs, a network large enough to provide for the city and province’s demands is required. The proposed powerlines will transmit electricity generated mainly by the Limpopo and Mpumalanga coal power stations.

A new powerline requires auxiliary infrastructures such as roads, and will enter and exit upgraded Gamma and Kappa substations. The upgrading of substations forms part of separate proposals.

Three alternative corridors were selected by ESKOM based on economic and technical feasibility. Once environmental authorisation is approved ESKOM officials consult with the relevant landowners to permit powerlines and pylons on their land.

Heritage specialists’ assessments study resources within a 4km buffer of the proposed lines, while Environmental specialists’ studies address a 2km corridor.

Figure 1: Location of proposed new 765kV transmission line within South Africa, powerline corridors located within red circle (Metro GIS, 2013)

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2.2 ALTERNATIVE ROUTES OPTIONS The three alternative powerline routes identified by ESKOM for assessment all start at Kappa substation and end at Omega substation. The Kappa - Omega 765kV section traverses a distance of approximately 415km and is potentially sensitive from a heritage perspective.

Route Option 1: The most southerly route The route is from Kappa substation to Hottentotskloof, adjacent to Prince Alfred Hamlet, Ceres, Skoonvlei, Soetendal, Dagbreek, Steelwater to the Omega substation. On Option 1 route south of Soetendal, the route has 2 options to connect to Option 2. Option 1a connects Option 1 route to Option 2 route south of Hermon. Option 1b route connects Option 2 route adjacent to the R45 roadway.

Route Option 2: Route Option 2 extends from Kappa to east of Porterville over the Koue Bokkeveld and Winterhoek Mountain ranges. From its position east of Porterville the route travels south west through Saron and adjacent to Riebeek Kasteel. This route incorporates a series of direction changes travelling south to adjacent Abbotsvdale, Kalbaskraal to Omega substation.

Route Option 3: Route Option 3 is the same as Option route 2 on the initial alignment from Kappa traveling north east over the Koue Bokkeveld and Groot Winterhoek Mountain ranges. The route exits the mountains north of Porterville, and extends between Piketberg and Koringberg, north of Hopefield to the Aurora substation. The route travels south to west of Darling to the Omega substation. Option 3b is west of Option 3 adjacent to the R27 roadway connecting to option 3 south of Darling. Option 3a connects Options 3b to 3 west of Darling. Option 3c is from Aurora on the same alignment as Option 3 until it diverts towards the coast west of Mamre, and re-joins Option 3 south west of Atlantis.

Figure 2: Kappa Gamma 2nd 765kV powerlines, Metro GIS 2013

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2.3 PYLON TOWERS Pylons towers for the proposed powerlines will be between 42 – 44m in height and have a footprint of approximately 40 – 50 square meters. The servitude required width for the construction of the pylon towers is 110m.

Three types of pylon towers are proposed for the powerlines:

 Cross Rope Suspension tower.  Guyed Suspension tower.  Self supporting suspension pylons and strain suspension pylons are used at positions where a change of direction takes place in the route or where strain on the lines from wind and other factors requires additional stability.

At each change of direction a self-supporting strain and suspension tower is required. Topography is the determining criteria for choice of pylon.

Figure 3: Pylons for 765kV powerlines (ESKOM Line Engineering services, ESKOM 400kV and 765kV Tower Guide May 2013)

Pylon Name Specifics Notes Image 702B: Guyed-V Max Footprint: Used for altitudes between 1000 and Suspension 39.5 x 53.5m 1200 meters. There is a model pylon modified for altitudes above 1500m, Max tower named 702B-M height: 50m

Average CAH: 36m

703B: Guyed-V Max Footprint: The 703B is an alternative to the Suspension 36.8 x 52.6m 702B to be used at altitudes below pylon 1000m. It also has more compact Max tower phase spacing than the 702B pylon. height: 42.8m

Average CAH: 33m

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Pylon Name Specifics Notes Image 701C: Self Max Footprint: Used in conjunction with the Guyed Supporting 11.625 x 11.625m 702B and 703B towers when the Suspension Guyed-Vs cannot be used pylon Max tower height: 40m

Average CAH: 25m

701 D, E and F: Max Footprint: 701F Self Supporting Strain is the 15 Self Supporting 15.4 x 15.4m – 35 degree angle strain tower Strain commonly used on the 765kV Max tower networks height: 41 - 44m

Average CAH: 25m

705A: Self Max Footprint: 705A is to be a high performance, Supporting 76.6.625 x 43.5m cost saving tower to be used on the Strain 765kV network Max tower height: 53m

Average CAH: 45m

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SECTION 3 REGION AND SITES DESCRIPTION

3.1 INTRODUCTION The 3 alternative routes transverse regions with a few cultural landscapes, historic settlements and built environment structures. Scenic routes are located along the route, and parts of all three alternatives are scenic and have iconic characteristics.

3.2 HISTORICAL OVERVIEW The alternative routes from Kappa to Omega traverse three regions with distinctly different historical markers areas (the Warm and Koue Bokkeveld and Tulbagh Valley, and the Swartland). This has resulted in areas of different historical patterning and significance. This section of the report deals with the evolution of these regions in two sections.

The historical significance of the areas and settlements traversed by the proposed lines can be summarised as follows (for detailed historical assessments and associations see Appendix 2):

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3.2.1 The Bokkeveld and Tulbagh Valley3

 Pre Colonial Settlement, the area served as a hunting area for the San, and later as seasonal grazing grounds for the Khoekoen populations that migrated south and entered the Western Cape region. A number of rock art sites in the region depict early rock art, but also show contact period depictions. Farm and place name along the routes are associated with the use of this region by Khoe and San inhabitants;  During the Dutch Colonial period, this area was first permanently settled as part of the ‘loan farm’ system of land occupation and cadastral control. Several early mountain passes existed between the Swartland and the Tulbagh Valley, originally named “Roodezand”. The first of these was created by the need of the colonists to locate the indigenous people in order to approach them for the purchase of livestock. Recorded expeditions into this area took place as early as 1658. These routes quickly became formalised and the VOC formalised an access route to the Valley. This route and its toll house have been recently located. In 1699 the valley was opened to farming and thereafter became known as the ‘Land van Waveren’. Two ‘buiteposte’ were established to monitor movement of the Khoesan and tighten border controls;  Resistance to the VOC and settler occupation began almost immediately, and the area was characterised by rising stock theft and an increase in military patrols and commandos. By 1740 the KhoeSan had been subdued or driven out of the area. A Church was established in 1743, which became the centre of a new town, Tulbagh. A road linking Waveren and the warm Bokkeveld was established in 1765 and the Karroopoort outspan provided a stopping place en route to and from the hinterland;  The town of Tulbagh was laid out in the late 18th century, and contains 100 provincial heritage sites (PHS). The establishment of towns and agricultural production in surrounding valleys was facilitated by mid to late 19th century road building traditions of using convict labour to establish significant roads and mountain passes, e.g. the Michells’, Theronsberg, Tulbagh and Karoopoort road and passes were developed within this system. The linked valleys (Tulbagh, Ceres) continued to expand incorporating Prince Alfred Hamlet and Wolseley. The region remains characterised by productive agricultural farmland, largely related to the production and processing of deciduous fruit. Rail links to the region allowed easier fruit transportation and later export, and served as a rail link to the expanding diamond fields and later gold reefs;  During the South African war, blockhouses were established at bridges on this important rail link. During the First World War the introduction of refrigeration facilitated intensification of fruit production and transportation;  From 1948 the introduction of a battery of apartheid legislation entrenched already existing segregation policies and created separate township communities on the outskirts of existing settlements;  Capital investments on farms, the widespread use of mechanisation, the entrenchment of selective access to land based opportunity and the government subsidisation of farming development have solidified the historical Warm Bokkeveld and Tulbagh valley region as a central producer of fruit, fruit products and wine.

3 Refer Appendix 2 for detailed histroical outline ______17

3.2.2 The Swartland4

 Pre Colonial Settlement, the area served as a hunting area for the San. The numerous and widespread rock art sites in surrounding shelters of the mountain ranges attest to regular use of the area by the San. Khoekhoen sites of pastoral activity are not easily found in the region, perhaps because of the almost uniform agricultural cultivation of low-lying lands;  Following Dutch East India Company (VOC) settlement at the Cape and expansion of the settlement frontier, the region quickly became a site of conflict between indigenous people and trekboers. In the mid to late 1600s cattle and sheep acquired from the Khoekhoen in Namaqualand and the Roodezand area were driven to Cape Town by the meat pachters (butchers). The area used for driving livestock later became a farm called ‘deurgang’, stretching from Salt River to the east of Riebeek Kasteel;  Trekboers and settlers with licences to sell meat later used loan farms in the area to graze livestock, establishing homesteads in a few well watered areas. The VOC also established four outposts in the area to monitor and control movement of indigenous people across the area, v.i.z. Groene Kloof, Riebeek Kasteel, Sonquas drift and Vogel Vallei. Some remaining Khoe chiefs grazed their cattle close to the outpostsfor protection from the KhoeSan who raided their stock in retaliation for the loss of land. The role of the outposts changed as trade became more open and interaction with the settlers began a process of absorption of Khoe, and they later became farms and villages;  The region was established as an agricultural area in fairly close proximity to Cape Town, and by the early 18th century farmers were settling and creating homesteads in the region. From 1714 crops were allowed to be produced and the farming of wine, wheat, oats and barley became increasingly common. The agricultural expansion across the region was fairly swift. By 1740 the KhoeSan had been subdued or driven out of the region, and its expansion as a region of agricultural production had been established;  In the mid 18th century, two Churches were established, and the growth of settlements around these Churches began;  Along the coastal plain, small fishing villages were established and trade with passing ships continued;  In the early 19th century a mission settlement was established at Groenkloof (later called Mamre), which later expanded to include Louwplaas and a Khoekhoe reserve. The settlement included agricultural allotments on either side of the Louwskloof river;  Difficulty in labour and power relations was illustrated by a rebellion of 340 slaves in the early 19th century. The rebellion was quelled and five of the ring leaders executed. Introduction of the Caledon code (1809) revised labour relations by requiring contracts between owners and labourers, but also introduced the first ‘pass laws’ in the region. This entrenched the power and authority of farmers;  Under British rule, revision of the cadastral system (1813) facilitated the need to keep farms profitable. This caused the expansion of some farms and the withdrawal of some farmers to the northern border lands. The introduction and increase in demand for wool led to widespread production of sheep, which was accompanied by more intense production of

4 Refer Appendix 2 for detailed historical timelines ______18

wheat. The region became characterised by fine grained but intensive agricultural production;  The development of towns began in the 1820s with the layout of Malmesbury and later, Wellington;  The emancipation of slaves in 1834, with a four period of apprenticeship, was paralleled by the expansion of Mamre and the establishment of a second mission station (Saron) in 1846. These communities provided labour to neighbouring farms as well as providing labourers with a semblance of independence from farmers. The reduction in permanent work force that accompanied emancipation soon led to the use of seasonal labour on farms, and the mission stations were a reliable source of seasonal labour;  Church towns began to develop across the region, and examples of these are Darling (1853), Riebeek West (1855), Philadelphia (1858), and Porterville (1863);  The introduction of a rail link to Malmesbury in 1877 and its later extension to Porterville (1905), with a small gauge line between Kalbaskraal and Darling, facilitated the growth of small settlements at rail junctions as well as allowing the expansion and intensification of agricultural production by making the transportation of goods easier. Block houses were built along these lines to protect bridges during the South African War (the Anglo-Boer War). Some commando action during the war was experienced at Darling and at Kalbaskraal;  The introduction, in 1889 of the use of convict labour on farms was expanded in the 1930s and from 1947 prison farms were created, at least one of which lies against the foothills North of Saron;  From 1948 the introduction of a battery of apartheid legislation entrenched already existing segregation policies and created separate township communities on the outskirts of existing settlements;  Capital investments on farms, the widespread use of mechanisation, the entrenchment of selective access to land based opportunity and the government subsidisation of farming development have solidified the historical Swartland region as a central producer of wheat and wine in the Western Cape;

 Post 1994, housing has been expanded and some communities have actively addressed the challenges of democratisation. The expansion of housing settlements and the introduction of farm workers rights have recently renewed tensions that have historically been markers of the use of the area for agricultural production.

3.3 CULTURAL LANDSCAPE

3.3.1 The Term ‘Cultural Landscape’ Cultural landscapes provide the meaningful context for a range of heritage resources that take a variety of forms and constitute heritage resources in their own right. Following the well-established guidelines set by the first 765kV linear assessments, the following cultural landscape understandings and assessment criteria have been utilised5:

5 Baumann and Winter, 2009:14-16 ______19

“It could be regarded as the tapestry within which all other heritage resources are embedded and which gives them their sense of place and meaning. The concept of cultural landscape gives spatial and temporal expression to the processes and products of interaction of people with the environment. It may thus be conceived of as a particular configuration of topography, vegetation cover, land use and settlement pattern that establishes some coherence of natural and cultural processes”6.

UNESCO identifies three broad categories of cultural landscape7

 Designed landscapes are clearly defined and created intentionally by people. These include gardens and parklands, most commonly constructed for aesthetic purposes;  Organically evolved landscapes result from an initial social, economic, administrative and/or religious imperative and develop their form by a combination of these and in response to the natural environment. These landscapes reflect evolutionary processes in their form and in component features. They can be divided into relic landscapes (no longer used) and continuing landscapes, where the organic nature of their form continues to evolve through active contemporary use including the traditional associations;  Associated cultural landscapes are those that have powerful religious, artistic or cultural associations that may not be evidenced in historical fabric;

Natural Landscapes: Distinctive vivid landscapes have qualities that set them apart from their surroundings, a dramatic visual quality which is legible and easily understood. These landscapes do not necessarily appear to have been subject to human intervention;

Representative landscapes are particularly representative of the region of which they form a part; they reveal a combination of characteristics and qualities that may be regarded as reflecting the quintessential character of the region;

In order for landscapes to have significance they should be intact and authentic and relatively undisturbed by visual intrusions.

3.3.2 Cultural Landscapes Occurring along Powerline Route Alternatives Characterisation of landscapes is a fluid and dynamic process. There are no hard edges to the types of landscapes encountered along the route options. The transitions between landscape typologies are zones where there is a blending of typology, but sections of the routes have fairly distinctive general characteristics, differentiated in part by changing morphology. The proposed powerlines corridors traverse three morphological zones: Ceres Karoo, Mountainous region and the Swartland.

In the Scoping Phase, cultural landscapes were differentiated and assessed at sub-regional scale. Scoping Phase recommended the exclusion of the northern parts of route options 2 and 3, leaving route option 1 and the southern part of route option 2 below the Kasteelberg as the preferred routes for detailed assessment (Refer Section 6). The descriptions below provide cultural landscape typologies and an overview of considerations, with detail for the assessment phase of the study.

6 Baumann and Winter, 2009:14 7 adapted from Baumann and Winter, 2009 ______20

Figure 6: Diagram showing cultural landscape zones in relation to the proposed powerline routes (MetroGIS, 2013)

3.3.2.1 The Ceres Karoo Constituting the smallest of the cultural landscape regions in the study area, the Ceres Karoo is characterised by a dramatic change in topography and landscape from the mountainous regions to its southwest, and smaller changes from the vast Karoo landscapes to the northeast. The Ceres Karoo is characterised by vast open spaces, longrange views and low scrub vegetation. The expansiveness of the landscapes are firmly framed by distant mountains. Farm settlements are sparse and typically dispersed single farms practicing stock or game farming and prediminately situated on riverine corridors. The lower border of the Ceres Karoo region lies to the area just northeast of the Karoopoort. Buildings in this region tend to reflect a remote vernacular typology characteristic of Karoo buildings, and settlement has been informed by the location of outspans.

Cultural landscape considerations in this section of the route

This region’s cultural landscape considerations relate to historical routes to the hinterland, the location of 18th and 19th century outspans and the natural wilderness quality of the landscape. In this area the proposed option 1, 2 and 3 traverse an open plain framed by distant mountains with sparse and low vegetation. Powerline route options 2 and 3 would constitute bulk infrastructural interventions into the landscape (there is a single very low impact transmission line along these routes), whereas two existing 400kV lines and the first 765kV transmission line, recently constructed, already significantly disturb the landscape to the south.

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3.3.2.2 The Mountainous Zone This zone is characterised by deep valleys contained within surrounding high mountains (Cape fold belt) and connected by mountain passes, many of which are scenic routes.

The fertile valleys were visited by settlers in the 17th century and were settled and agriculturally productive by the early to mid 18th century. They have remained agriculturally productive as an enduring and significant characteristic, and are associated with changing patterns of labour relations over time. Small settlement nodes occur within the intense coherent intact agricultural landscape along the valley floors, while the mountainsides remain relatively inaccessible and apparently unchanged.

Vegetation is characteristically low (mountain fynbos), except where it has been replaced by agricultural uses – orchards, vineyards, forestry, and certain grazing areas.

The dramatic visual qualities of the valleys, mountain peaks, and connecting mountain passes lend themselves to use of the area as tourist destinations.

Figure 7: Ceres Valley from Gydo Pass (photograph Judelle Drake)

Cultural landscape considerations in this section of the proposed routes

The historical and enduring role of agricultural production and associated rural settlement pattern is representative of the region and is recommended for cultural significance8. There are numerous historical settlements containing PHS in the region. This, coupled with the vivid visual qualities and scenic routes implies that bulk linear interventions are assessed at sub-regional scale.

Historic mountain passes and poorts affected by the powerline route option 1 include Karoopoort, Hotentotskloof pass, Theronsberg pass, Roodezand/ Nuwekloof pass (17th century, Nuwekloof 1968). Options 2 and 3 dissect Piekeneerskloof pass, the Agter-Witzenburg pass (north of Gydo pass) and the Koue Bokkeveld.

Route Options 2 and 3 traverse the wilderness areas north of the Gydo Pass, traversing the Koue Bokkeveld approximately 5km south of Matroosberg9 and the Groot Winterhoek, a provincial wilderness reserve. Despite the valley not containing an historical settlement, the remote agricultural valley floor surrounded by wilderness mountain slopes of almost 1800m high constitutes a first bulk intervention proposal across pristine and coherent wilderness landscape in the mountains, and an historic and intact agricultural valley floor.

8 D-PSDF 2013 9 Matroosberg is the second highest peak in the Western Province ______22

3.3.2.3 The Swartland The Swartland is characterised by its wide agricultural plain, framed by distant mountain peaks to the east and interspersed with regular small historical settlements and farm werfs. The plain is expansive and open with undulating hills contributing to the rural agricultural sense of place. Visual connections exist between a number of settlements situated on mountain foothills, and the scale and evolution of the built form has largely remained in harmony with the contextual landscape over time. There is a rural sense of coherence and the historical associations of the landscape as an area of significant agricultural production is enduring.

The region contains numerous historical routes associated with colonial period expansion of settlement and production, provincial and local heritage sites, and a number of scenic routes linking settlements.

The coastal zone remains rugged and fairly inhospitable and is largely, in the study area, characterised by medium height coastal vegetation, interspersed with small fishing settlements, and containing the West Coast Fossil Park.

The Cape fold belt mountains forming the backdrop to the plain on the east are dramatic and have vivid visual qualities in comparison to the fine grained valleys and open plain with distinctive agricultural field patterning.

Figure 8: Agricultural patterning of the Swartland and the visual connections between settlements nestled into the foothills of mountains (photograph Kay McCormick, 2014)

Cultural historical considerations in this section of the proposed routes

The region contains a number of settlements, farm werfs and routes of aesthetic, architectural, historical, and associational significance in the provincial and local context. Potential negative impacts from bulk infrastructure on identified heritage resources outside of the study corridors are considered due the visual expansiveness of the landscape context and the historic and intangible connections between settlements and their context, as follows:

 Porterville;  Piketberg and Korinberg;  Riebeek-West, Riebeek-Kasteel, the Kasteelberg and the 17th century Botmanskloof Pass;  Malmesbury and the Malmesbury foothills;  The Paardeberg and its slopes and associated historical farms outside of the corridors;  Mamre;  Darling, and  The Swartland plain.

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The detailed impact assessment phase has concentrated on the natural and cultural landscapes within the study corridor of Option 1, 1a and 1b and Route option 2 in the area between the southeast of the Kasteelberg and Omega substation.

Summary:

The majority of landscapes in the assessed area between Kappa and Omega fall within the range of organically evolved landscapes. The following sub-categories for these landscapes are used to further depict the heritage resources potentially affected by the lines10:

 Historical townscape;  Historical farm werf;  Scenic landscapes;  Productive agricultural landscapes, which occur in valleys and on open plains within the study corridors;  Organically developed low density productive agricultural landscapes;  Remote arid landscapes;  Relic landscapes;  Pristine natural landscapes or Wilderness mountainscapes.

10 Adapted from Baumann and Winter, 2009:15 ______24

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3.4 BUILT ENVIRONMENT The alternative powerline corridors predominately transverse undeveloped areas, which are used for agriculture and conservation purposes. However, in certain circumstances, settlements and townscapes fall within the 4 km corridors (refer Table 3.1 and Section 5 for detail on settlements).

Table.3.1 Towns within Route Options 1, 2 and 3

Option Route Town Position within Corridor Alternatives Option 1 Prince Alfred Hamlet Within 1 – 2km of centreline of corridor Ceres/Bella Vista Bella Vista on centre to 1m of corridor, Ceres historic core outside corridor

Wolesely Outside edge of corridor Philadelphia Outside edge of corridor Option 1a No towns Option 1b No towns Option 2 Riebeek Kasteel Within 2- 4km of centreline of corridor Saron On centreline of corridor Kalbaskraal Within 1 km of centreline of corridor Abbotsdale Within Option 3 Piketberg Outside corridor but visually connected to settlement context Porterville Within 1 – 2km of centreline of corridor Darling Within 1 – 2km of centreline of corridor Koringberg Within 1 – 2km of centreline of corridor

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SECTION 4 HERITAGE LEGISLATION & ASSESSMENT CRITERIA

4.1 INTRODUCTION Section 4 provides an overview of the administration context of the sites and the applicable statutory framework. The historical development for the settlement is provided in addition to descriptions of the individual sites and their context, current structures, landscape features and land uses.

4.2 ADMINISTRATIVE CONTEXT AND STATUTORY FRAMEWORK

4.2.1 Overview The corridors are located within multiple districts including Cape Winelands District Municipality, West Coast District Municipality and the Cape Metropolitan Area (City of Cape Town). Municipal areas traversed include Cape Winelands with Breede River, Witzenebrg Drakenstein, West Coast District Municipality with Swartland, Saldahna Bay and Berg River municipalities and the City of Cape Town as the Metro.

For the purposes of this study, the following relevant South African and city policy and planning documents were reviewed:

 National Heritage Resources Act No. 25 of 1999 (NHR Act);  Municipal Zoning Policies, Frameworks and Regulations;  Municipal planning strategy and reports;

4.2.2 National Heritage Resources Act No. 25 of 1999 (NHRA) The NHR Act serves as the controlling legal framework for heritage conservation in South Africa. The Act lays down general principles for governing heritage resources management throughout the republic and provides for the identification, assessment and management of the heritage resources of the country. The Act only applied to “those heritage resources of South Africa, which are of cultural significance or other special value for the community and for future generations”. A heritage resource is described as “any place or object of cultural significance” (NHR Act, Section 26 [xvi]). Heritage resources significant enough to be considered part of the national ‘estate’, may include inter alia (Section 3[2]):

o Places, buildings, structures and equipment of cultural significance; o Places to which oral traditions are attached or which are associated with living heritage; o Historical settlements and townscapes; o Landscapes and natural features of cultural significance; o Geological sites of scientific or cultural importance; o Archaeological sites and objects; o Graves and burial grounds; o Sites of significance relating to the history of slavery in South Africa; o Moveable objects including military objects, fine art, books records, documents, archaeological and paleontological objects and materials.

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Cultural heritage significance means aesthetic, historical, scientific, architectural, scientific, spiritual, technological or social value or significance. The process of deciding why a place is of heritage significance is called heritage assessment. The NHR Act requires the heritage significance of any site or object be assessed so as to ensure the appropriate level of management of the country’s heritage resources. The South African Heritage Resources Authority (SAHRA) has in terms of Section 7 (1) of the NHR Act, published regulations providing for grading systems and heritage resources assessment criteria (Government Gazette No. 24893. Government Notice No. 694 dated 30 May 2003). This criteria is to be applied in assessment the significance of heritage resources for Grade 1, 2 and 3 heritage resources (refer to Annexure 4: Cultural Significance Assessment Criteria).

A culturally significant resource or site is considered part of the national estate if it has cultural significance or any other specials value because of –

 Its importance in the community, or pattern of South Africa’s history;  Its possession of uncommon, rare or endangered aspects of South Africa’s natural or cultural history;  Its potential to yield information that will contribute to an understanding of South Africa natural or cultural heritage;  Its importance in demonstrating the principal characteristics of a particular class of South Africa’s natural or cultural places or objects;  Its importance in exhibiting particular aesthetic characteristics valued by a community or cultural group;  Its importance in demonstrating a high degree of creative or technical achievement at a particular period;  Its strong association with a particular community or cultural group for social, cultural or spiritual reasons;  Its strong and special association with the life or work of a person, group or organisation of importance in the history of south Africa;  Sites of significance in relations to the history of slavery (Section 3[3] NHR Act).

The Act provides formal protections for national and provincial heritage sites in addition to the protection of heritage resources that have not been formally protected. Section 34 requires that “no person may alter of demolish any structure or part of a structure which is older than 60 years without a permit issued by the relevant provincial heritage authority”. Section 38 is intended to ensure that heritage resources that have not been formally identified and protected are not unknowingly damaged or destroyed during development or administration change to site/s.

4.2.3 Existing Heritage Studies The HIA Phases 1 and 2 for the initial 756kV powerlines corridor from Kappa to Omega substations provided baselines for the degree of required assessment for the current study. In addition, site and

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT settlement heritage studies have provided information on the various cultural significances of affected areas within the study corridors11.

4.3 HERITAGE ASSESSMENT CRITERIA

4.3.1 Definition of Cultural Significance and Criteria for the Assessment of Cultural Significance

Cultural significance is defined as “historical, architectural, aesthetic, environmental, social or technological/scientific value or significance” (NHRA 25 of 1999).

The NHRA lists broad criteria for the assessment of cultural significance. This is based on the following:

 Importance in the community or pattern in South African history;  Possession of uncommon, rare or endangered aspects of South African's natural or cultural heritage;  Potential to yield information that will contribute to an understanding of South Africa's natural and cultural heritage;  Importance in exhibiting particular aesthetic characteristics valued by a community or cultural group;  Importance in demonstrating a high degree of creative of technical achievement during a particular period;  Strong or special association with a particular community of cultural group for social, cultural or spiritual reasons;  Strong or special association with the life of work of a person, group or organisation of importance in the history of South Africa.

Such criteria can be categorised, in terms of the NHRA, as follows:

Historical:  Associated with an historic person or group  Associated with a historic event, use or activity  Is representative of a historical period

Architectural:  Significant to architectural or design history  Important example of a building type  Possesses special features, fine details or workmanship  Work of a major architect

Environmental:  Contributes to the character of an area  Part of an important group of heritage resources or features  Landmark quality  Important for reasons of natural environmental considerations

11 Refer Bibliography for list of sources

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Social:  Associated with economic social and religious activity  Significant in terms of social memory  Associated with living heritage and cultural traditions

Technical/Scientific:  Important to industrial technological or engineering development  Important to archaeology, palaeontology, geology and botany.

The following additional criteria are used in understanding cultural landscapes and the cultural significance of a place in terms of its physical evidence and contextual qualities12:

Intrinsic Significance: Ability for physical or material evidence to demonstrate a past design style period technique, philosophy or belief. The degree of heritage significance is determined by:  Age  Scarcity value  Intactness (presence of original features)  Representational value (outstanding, important or typical value)  Evidence of historical layering

Associational Significance: Associational links with past events, activities, persons or social groupings for which there may not be physical evidence. Degree of Significance is determined by:  The significance of past events  Intimacy of the association  Duration of the association  Evocative quality of a place and its stetting relative to the period of association

4.3.2 Contextual/Experiential Significance Qualities that give a place historical character, a sense of continuity with the past, a sense of orientation, and structure within the landscape. It encompasses the physical properties (scale, form edges, alignments, views spaces, orientation) of a place and it's setting. Degree of significance is determined by:  Level of coherence or unity  Level of intactness  Level of interpretive qualities  Level of continuity or historical layering  Level of vividness  Relationship with its setting  Evocative versus disruptive qualities of contrasting elements.  The NHRA grades sites according to their national (Grade 1) provincial (grade 2) or local (grade 3) significance.

12 Kerr 2000, used by Bauman and Winter 2003

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4.3.3 Assessments of Impacts Criteria for the assessment of heritage impacts has been based on those contained in the EIA regulations, as follows:

Nature of the impact in terms of:  Physical and material impacts  Visual spatial qualities  Associational impacts

Extent of the impact in terms of:  Regional/townscape scale  Local scale  Farm/site scale  Individual element scale

Duration of the impact may be:  Permanent  Long term  Medium term  Short term  Temporary

Magnitude of the impact may be:  High involving severe alteration or damage. Substantial mitigation required;  Medium involving significant alteration or change. Significant mitigation required;  Low involving minimal alteration or change. Minimal mitigation required;  Very low and within the capacity of the site to absorb.

Status of impact in terms of cost benefit analysis The NHRA requires that impacts on heritage resources are also to be assessed in the light of the proposal to the resource to provide social and economic benefit to the community and economy at large (either positive, negative, neutral). The levels of significance in terms of the potential impacts to the heritage resource can be summarized in levels of significance (No, low, moderate, high significance) and the No development option.

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4.4 HERITAGE DESIGN INDICATORS

Heritage indicators and their appliaction to the assessment were identified to assess the impact of the 2nd 765kV powerline option corridors on the identified cultural landscapes and built environment. These were developed at regional, sub regional, local and micro (site specific) scales.

4.4.1 Scoping Phase Guidelines Preliminary guideline principles for powerline construction were developed by the authors in the Scoping Phase and informed the heritage design indicators. These guidelines were based primarily on the assessment of the impacts of existing powerlines of varying voltage capacities on sites.

Powerlines have less impact on identified heritage resources if situated in the following situations:

 Mountain foothills;  Rugged mountainous terrain;  Disturbed land e.g. agricultural lands;  Within a concentrated corridor;  A distance of approximately 500 – 1km from an established transport route;  On the edge of a valley i.e. not bisecting a valley.

Powerlines have more impact on identified heritage resources if situated in the following situations:

 Road intersections;  Smooth mountainous terrain;  Unblemished terrain/landscapes;  Variety of powerlines infrastructure within a context;  Level topography i.e. less backdrop;  In close proximity to established routes, especially scenic routes;  Bisecting a valley;  Interrupting coherent patterns, such as agricultural lands and settlement patterns.

Sensitivities

• Coherent natural and cultural landscapes, for example Karoo National Park, Karoo mountainscapes and agricultural landscapes; • Settlements within powerline corridors, for example Merweville and Beaufort West; • ‘Pristine’ landscapes, for example sections of the Karoo; • Cumulative impact verses. establishing new corridors; • Iconic scenic routes, for example N! roadway sections in context of the Three Sisters;

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4.4.2 Assessment Phase Regional and Sub Regional Scale Heritage Indicators

In areas where the proposed powerlines will have high impact on identified heritage resources on a regional and sub-regional scale the following heritage indicators apply:

Table 4.1: Assessment Phase Heritage Design Indicators at a Regional and Sub-Regional scale No Heritage Resources that are Heritage Indicator Sensitive at Regional & Sub Regional Scale 1 Distinct landscapes that are Avoid interventions in significant regional landscapes; large scale and representative of regional characteristics, e.g. If powerline proposals traverse a significant regional agricultural valleys, mountain landscape, alignments must be considered in terms of their backdrops, riverine corridors, impacts on that landscape. Mitigation would involve moving mountain passes, escarpment the line to less intrusive position. edges, mountainous ridges. 2 Intact, undisturbed areas of Avoid interventions in intact scenic wilderness areas. high wilderness qualities and If powerline proposals traverse significant wilderness scenic values landscapes, alignments must be considered in terms of their high negative impacts on that landscape. Mitigation would involve moving the line to less intrusive position. Site power lines in areas where there is existing infrastructure, such as roads, railway lines and existing power line corridors. Consideration is to be given where there could be cumulative impacts from multiple infrastructure. 3 Areas of low visual absorption, Avoid new interventions in areas of low visual absorption. such as vast open spaces If powerline proposals traverse areas of low visual without mountain backdrops absorption, alignments must be considered in terms of their where settlement is dispersed high negative impacts on that landscape. Mitigation would involve moving the line to less intrusive position. Site power lines in areas where visual absorption is high. 4 Concentration of heritage Avoid interventions into historic settlements or resources (built environment representative cultural landscapes. and /or cultural landscapes); If powerline proposals traverse significant historical settlements, alignments must be considered in terms of their high negative impacts. Mitigation would involve moving the line to less intrusive position. Site power lines in areas away from regionally significant historical settlements or cultural landscapes. 5 Dominant vistas and views of Avoid interventions into historic settlements or historic towns and their representative cultural landscapes. primary access routes If powerline proposals traverse significant vistas and views, appropriate alignments should be determined by visual impact assessment.

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No Heritage Resources that are Heritage Indicator Sensitive at Regional & Sub Regional Scale 6 Scenic routes Avoid powerlines travelling parallel to scenic routes. If powerline proposals must be sited near scenic routes, the lines should cross perpendicular to routes, should not be sited on ridge lines, should be positioned on lower topography, and not be placed closer than 600m to the route if travelling parallel. This should be determined by detailed site visit.

Summary

 Avoid sensitive distinct character landscapes;  Choose disturbed areas over wilderness areas;  Choose areas with a high visual absorption capacity;  Position new infrastructure in existing infrastructure corridors where possible;  Consider how the powerlines traverse significant scenic routes.

4.4.3 Assessment Phase Local Scale Heritage Design Indicators In areas where the proposed powerlines will have high impacts on identified heritage resources on a local scale, the scale of impacts will determine the suitability of the proposal. Once a preferred route has been established by integrated assessment, it is possible that some areas of a route will have negative impacts at local level. These can be mitigated as indicated in Table 4.2:

Table 4.2: Assessment Phase Heritage Design Indicators at a local scale No Heritage resources that are Heritage Indicator sensitive at local scale 1 Areas of low visual Position power lines along foothills of mountains so that the absorption qualities, e.g. power lines have a backdrop; flat topography, localised Select mountains with rugged characteristics as opposed to valleys with low scale smooth terrain; vegetation and buildings Position pylons on either side of mountain ridge and not on its crest; Utilise topographical features and variations (mountain slopes, ridges, vegetation) and buildings to provide a background setting and avoid pylons being seen in silhouette; Positions powerlines where there is existing infrastructure, such as roads, railway lines, existing power lines, tree belts; Consideration is to be given where there could be cumulative impacts from multiple infrastructure.

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No Heritage resources that are Heritage Indicator sensitive at local scale 2 Visual contextual setting of Power lines should be positioned perpendicular to the significant built geometry of historic routes, roads, farmsteads and/or werf. environments, e.g. Powerlines should be situated behind the dominant vista farmsteads, historic between significant structures and access route i.e. at the rear settlements. of the farmstead/farm node. 3 Features reflective of the Powerlines should not be positioned between farm nodes and cultural landscape and adjacent riverine corridors, nor should they divide any built settlement patterns, e.g. components of the farm node. siting of farmsteads with mature trees adjacent to river corridors 4 Coherent historical Avoid intact settlements and their immediate context. settlement precincts Position powerlines at a distance from settlements. Visual impact to be considered. On site determination by composite team to determine best possible option for route. 5 Gateways and thresholds of Consider gateways and thresholds in landscapes and how settlements and landform pylons are situated in sensitive contexts. typologies; On site determination by composite team to determine best possible option for route. 6 Scenic routes Avoid powerlines travelling parallel to scenic routes. If powerline proposals must be sited near scenic routes, the lines should cross perpendicular to routes, should not be sited on ridge lines, should be positioned on lower topography, and not be placed closer than 600m to the route if travelling parallel. On site determination by composite team to determine best possible option for route. 7 Historical landscape Relationships between towns and their spatial settings should patterns be retained. Position powerlines beyond/outside these spatial settlement contexts. On site determination by composite team to determine best possible option for route. 8 Farm nodes with adjacent Avoid framing farmsteads and farm nodes by introducing infrastructure infrastructure on more than one side of node. If powerline proposals introduce new powerlines near existing ones, the new lines must be positioned on the same side of the node as the existing. Consideration is to be given where there could be cumulative impacts from multiple infrastructure.

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4.4.4 Assessment Phase Micro Scale Heritage Design Indicators In areas where the proposed powerlines will have high impacts on identified heritage resources on a local scale, the scale of impacts will determine the suitability of the proposal. Once a preferred route has been established by integrated assessment, it is possible that some areas of a route will have negative impacts at site scale. These can be mitigated as indicated in Table 4.3:

Table 4.3: Assessment Phase Heritage Design Indicators at a Micro scale No Heritage resources that are Heritage Indicator sensitive at local scale 1 Farmstead structure Powerlines should be situated behind the dominant vista alignments with their access between the farmstead and the access route/river corridor, routes and dominant vistas at the rear of the farmstead front façade. Power lines should be aligned parallel to the established historical geometry of the farm node. Powerline should not be placed between farm node and the adjacent river corridor. 2 Topographical features Landscape features such as rocky outcrops and folds in landscapes can be utilised to mitigate the negative impact on the landscape at a micro site level. 3 Farm nodes with adjacent Avoid framing farmsteads and farm nodes by introducing infrastructure infrastructure on more than one side of node. If powerline proposals introduce new powerlines near existing ones, the new lines must be positioned on the same side of the node as the existing. Consideration is to be given where there could be cumulative impacts from multiple infrastructure. 4 Significant tree avenues Power lines should not result in the removal of trees within a tree avenue. Powerlines should be aligned parallel to the avenue or cross perpendicular.

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4.5 IMAGES AND DEPICTIONS OF ROUTE ALTERNATIVES Figure 10: Images from Kappa Substation to Karoopoort

Image 4.1: Existing powerlines along the R46 Image 4.2: Karooport Outspan (Provincial Heritage roadway at Karoopoort, note rugged mountainscape site), Proposed powerline to run on ridgeline behind and road separating the poort from the powerlines, the outspan, BOD/ST 2013 BOD/ST 2013

Image 4.3: Existing powerlines between Kappa and Image 4.4: Existing 400kV powerlines traversing the Karoopoort Outspan valleys, BOD/ST 2013 mountainside south of Karoopoort, note rugged mountainscape and location of lines on opposite side from the Provincial Heritage site, BOD/ST 2013

Image 4.5: Existing powerline entering the poort, note visual absorption against rugged mountainscape, BOD/ST 2013

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Figure 11: Landscape and approach to the R46 scenic routes from the R355

Image 4.6: Section of pristine valley between N1 Image 4.8: Section of pristine valley between N1 roadway and R46 to Karoopoort, BOD/ST 2013 roadway and Karoopoort, BOD/ST 2013

Image 4.8: Existing powerline from Karoopoort along Image 4.9: Existing 765kV powerline on approach to the R46, BOD/ST 2013 Hottentotskloof pass, R46, between Karoopoort and Ceres, BOD/ST 2013

Figure 12: Images Karoopoort Outspan to Ceres including Hottentotskloof and Theronsberg Passes, scenic routes

Image 4.10: Karoopoort in distance, BOD/ST 2013 Image 4.11: Valley between Karoopoort and Hottentotskloof Pass, BOD/ST 2013

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Image 4.12: Existing powerline from Kappa towards Image 4.13: Existing 765kV powerline travelling Ceres over agricultural lands and Theronsberg pass , parallel with scenic route - Theronsberg pass above BOD/ST 2013 Hottentotskloof pass, BOD/ST 2013

Image 4.14: Existing powerline from Kappa towards Image 4.15: Existing powerline from Kappa to Ceres Ceres set on foothills (left), BOD/ST 2013 valley crossing scenic route, BOD/ST 2013

Figure 13: Images Ceres Valley Context

Image 4.16: View of Bella Vista (right) within valley Image 4.17: Ceres Valley with intensive agriculture, and mountainscape context, BOD/ST 2013 existing powerlines within valley, BOD/ST 2013

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Image 4.18: Existing 400kV powerline between Bella Image 4.19: Rugged mountainscape between Ceres Vista (right) and Prince Albert Hamlet (left of image) valley and Wolseley, BOD/ST 2013 on former buffer strip between the white and Coloured race group areas, BOD/ST 2013

Image 4.20: Valley and surrounding mountain Image 4.21: Rural townscape character of Prince context of Ceres valley, BOD/ST 2013 Alfred Hamlet with surrounding mountainous context, BOD/ST 2013

Figure 14: Images Wolseley Context

Image 4.22: Existing powerline between Ceres and Image 4.23: Existing powerline between Ceres and Tulbagh valleys, BOD/ST 2013 Tulbagh valleys, BOD/ST 2013

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Image 4.24: Existing powerline between Ceres and Image 4.25: Existing powerline between Ceres and Tulbagh valleys, BOD/ST 2013 Tulbagh valleys, note rugged mountainscape, BOD/ST 2013

Image 4.26: Existing powerline crossing mountain Image 4.27: Boer War Blockhouse adjacent to ridge between Ceres and Tulbagh valleys, pylon railway line, Wolseley, BOD/ST 2013 (outside of visible on mountain ridge, BOD/ST 2013 study corridor)

Figure 15: Images of Elandsberg Farms and Landscape Context

Image 4.28: View of approach to Elandsberg showing Image 4.29: Langhoogte Farmstead, one of the nodes 400kV lines crossing the saddle. High absorption that comprise the Elandsberg heritage resources, capacity at mountain edge, low absorption on valley BOD/ST 2014 floor, BOD/ST 2014

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Image 4.30: Closer image of existing lines crossing Image 4.31: Bartholomeusklip homestead, now a mountain range onto the farms, BOD/ST 2014 guesthouse on the combined agricultural and conservation Estate, BOD/ST 2013

Image 4.32 Barn with silos behind on entrance axis to Image 4.33: Functional separation of working Bartholomeusklip, farmstead on right within werf paddocks directly adjacent to werf, BOD/ST 2014 wall, BOD/ST 2014

Image 4.34: Boathouse with existing 400kV lines in Image 4.35: Context which will be affected by new background, new proposed line will run directly on proposed 765kV line, placed along shore, BOD/ST lake edge, BOD/ST 2014 2014

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Image 4.36: Landscape showing power lines Image 4.37: Double 400kV lines across terrain with approaching and runnning south of settlement node, reasonable absorption capacity, south of the BOD/ST 2014 settlement nodes, BOD/ST 2014

Image 4.38: Powerlines on level terrain with less Image 4.39: Estimated placement of proposed new absorption capacity but situated behind (south of) the line, severing the two major farm nodes from each farm nodes, BOD/ST 2014 other, framing Bosplaas in powerlines BOD/ST 2014

Image 4.40: Bosplaas homestead looking south, Image 4.41: Rear of Bosplaas homestead, with a grove powertlines hidden from view beghind the trees, of oaks behind the house, BOD/ST 2014 BOD/ST 2014

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Image 4.42: Bosplaas rear garden precinct, the only Image 4.43: View from homestead to Riebeek Kasteel, place from which existing powerlines affect the foreground will be severed by the proposed new line homestead, BOD/ST 2014 running directly in front of trees, BOD/ST 2014

Image 4.44: Proposed placement of new 765kV powerline and pylons beyond Bosplaas werf wall. Proposed placement of new 765kV powerline, in addition to the existing 400kV lines placed to the south of the farmstead will frame the farm node and sever the farm nodes from one another. Height will exceed estimate above, BOD/ST 2014

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Figure 16: Images of Riebeek Kasteel and Landscape Context

Image 4.45: Views towards Riebeek Valley with Image 4.46: Views towards Riebeek Valley with Riebeek Kasteel in foreground, BOD/ST 2013 Riebeek Kasteel in foreground,, BOD/ST 2013

Image 4.47: Agricultural use of Riebeek Valley, Image 4.48: Agricultural use of Riebeek Valley, BOD/ST 2013 BOD/ST 2013

Image 4.49: Agricultural use of Riebeek Valley a Image 4.50: Intensive agricultural use of Riebeek portion of the Swartland, BOD/ST 2013 Valley, Swartland, BOD/ST 2013

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Figure 17: Images Saron Mission Settlement and Landscape Context

Image 4.51: Approach to Saron visible in the Image 4.52: Mature Eucalyptus Avenue on Saron distance, BOD/ST 2013 agricultural lands, BOD/ST 2013

Image 4.53: Saron historical cemetery, BOD/ST 2013 Image 4.54: Saron historical cemetery, located directly beneath proposed powerline, BOD/ST 2013

Image 4.55: Saron Church, BOD/ST 2013 Image 4.56: Saron Parsonage, BOD/ST 2013

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Image 4.57: Rural character of the Saron settlement Image 4.58: Rural character of the Saron settlement with mountainous backdrop, BOD/ST 2013 with mountainous backdrop, BOD/ST 2013

Image 4.59: Example of Saron’s locally significant Image 4.60: Saron’s contextual Landscape in Riebeek buildings and coherent streetscape, BOD/ST 2013 Valley, proposed line to run directly overhead, BOD/ST 2013

Figure 18: Images Riebeek Valley

Image 4.61: Intensive agricultural use of Riebeek Image 4.62: Intensive agricultural use of Riebeek Valley, BOD/ST 2013 Valley, BOD/ST 2013

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Image 4.63: Intensive agricultural use of Riebeek Image 4.64: Intensive agricultural use of Riebeek Valley, BOD/ST 2013 Valley with framing mountainscape, BOD/ST 2013

Image 4.65: Intensive agricultural use of Riebeek Image 4.66: Intensive agricultural use of Riebeek Valley with framing mountainscape, BOD/ST 2013 Valley with framing mountainscapes, BOD/ST 2013

Figure 19: Images Porterville and Landscape Context

Image 4.67: Northern entrance to Porterville with Image 4.68: Historic farmsteads and agricultural landmark Eucalyptus avenue, BOD/ST 2013 context in immediate surrounds, BOD/ST 2013

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Figure 20: Images Proposed Route 3 between Porterville and Piketberg

Image 4.69: R44 roadway when the proposed option Image 4.70: Swartland agricultural lands where 3 powerline corridor would cross the roadway, Option 3 route is proposed, BOD/ST 2013 BOD/ST 2013

Figure 21: IMAGES SWARTLAND PORTERVILLE, PIKETBERG AND KORINGBERG CONTEXT

Image 4.71: Historic farmsteads, Septemberkraal, Image 4.72: Swartland agricultural character, BOD/ST 2013 BOD/ST 2013

Image 4.73: Swartland agricultural character with Image 4.74: Swartland agricultural character with enclosing mountainscape, BOD/ST 2013 Piketberg in the distance on the foothills of the mountain BOD/ST 2013

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Figure 22: Images Piketberg

Image 4.75: Approach view of Piketberg, BOD/ST Image 4.76: Views over valley from Piketberg, 2013 BOD/ST 2013

Image 4.77: Views over valley from Piketberg Image 4.78: Piketberg historic Dutch Reformed towards Groot Winterhoek mountainscape in Church, BOD/ST 2013 distance, BOD/ST 2013

Image 4.79: Piketberg historic 19th c buildings, Image 4.80: Piketberg connection to its agricultural BOD/ST 2013 context, views towards the Winterhoek, BOD/ST 2013

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Figure 23: Images Koringberg

Image 4.81: Approach views of Koringberg on Image 4.82: Koringberg agricultural context, BOD/ST mountain foothills and with its grain silo’s, BOD/ST 2013 2013

Image 4.83: Koringberg agricultural context,, BOD/ST Image 4.84: Koringberg Dutch reformed Church, 2013 BOD/ST 2013

Image 4.85: Agricultural lands between Koringberg Image 4.86: Historic farmsteads in Koringberg and Picketberg, BOD/ST 2013 context, BOD/ST 2013

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Figure 24: Images R45 Roadway

Image 4.87: Swartland agricultural character, Image 4.88: Swartland agricultural character, BOD/ST 2013 BOD/ST 2013

Image 4.89: Existing powerlines on R45 roadway, Image 4.90: Existing powerlines and Aurora BOD/ST 2013 substation adjacent to R45 roadway, BOD/ST 2013

Image 4.91: Existing powerlines on R45 roadway, Image 4.92: Existing powerlines crossing R45 BOD/ST 2013 roadway, BOD/ST 2013

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Figure 25: Images Approach Darling

Image 4.93: Existing powerline in Darling context, Image 4.94: Agricultural lands on Darling’s BOD/ST 2013 periphery, BOD/ST 2013

Image 4.95: Darling Cemetery adjacent to the R315, Image 4.96: Approach views towards Darling on the BOD/ST 2013 R315, BOD/ST 2013

Figure 26: Images Philadelphia & Context

Image 4.97: Dutch reformed Church Philadelphia, Image 4.98: Local significant building, Philadelphia, Provincial Heritage site, BOD/ST 2013 BOD/ST 2013

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Image 99: Streetscape locally significant buildings, Image 4.100: View of historic parsonage with Philadelphia, BOD/ST 2013, BOD/ST 2013 Eucalyptus avenue linking to Church, Philadelphia BOD/ST 2013

Image 4.101: Agricultural landscape bordering Image 4.102: Historic farmsteads, bordering Philadelphia, BOD/ST 2013 Philadelphia, BOD/ST 2013

Figure 27: Images Kalkbaskraal

Image 4.103: Historic farmsteads, bordering Image 4.104: Historic farm buildings bordering Kalkbaskraal, BOD/ST 2013 Kalkbaskraal, BOD/ST 2013

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Image 4.105: Main Road Kalksbaskraal, BOD/ST Image 4.106: Kalkbaskraal historic streetscape, 2013 BOD/ST 2013

Image 4.107: Existing powerline north of Kalkbaskraal on agricultural lands, BOD/ST 2013

Figure 28: Images Abbotsdale

Image 4.108: Abottsdale settlement, BOD/ST 2013 Image 4.109: Abottsdale settlement with mature Eucalyptus trees, BOD/ST 2013

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Image 4.110: Agricultural development in context of Image 4.111: Abottsdale rural character settlement Abbotsdale, BOD/ST 2013 with mature Eucalyptus trees, BOD/ST 2013

Figure 29: Images Klipheuwel

Image 4.112: Klipheuwel settlement within an Image 4.113: Klipheuwel settlement with historic agricultural context, BOD/ST 2013 core on hillside, BOD/ST 2013

Image 4.114: Klipheuwel informal settlement, Image 4.115: Klipheuwel grain silos, BOD/ST 2013 BOD/ST 2013

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SECTION 5 IDENTIFIED HERITAGE RESOURCES & STATEMENTS OF HERITAGE SIGNIFICANCE

5.1 INTRODUCTION The values and patterns of identified heritage resources provide the basis for understanding the significance of sites and settlements. These informants provide the basis for assessing the impacts of linear interventions on the resources themselves. The following assessment is informed by the criteria outlined in Section 3(3) of the NHRA, which have been expanded to include intrinsic and associational values. Natural and scenic landscapes of heritage significance are dealt with under cultural landscapes below.

5.2 ROUTE OPTION 1 Route Option 1 is the most southerly route from Kappa sub station to Hottentotskloof, adjacent to Prince Alfred Hamlet, Ceres, Skoonvlei, Soetendal, Dagbreek, Steelwater to the Omega substation. On Option 1 route south of Soetendal, the route has 2 options to connect to Option 2. Option 1a connects Option 1 route to Option 2 route south of Hermon. Option 1b route connects Option 2 route adjacent to the R45 roadway.

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Table 5.1: Route Option 1: Settlement / Structure

No. Settlement/Structures Proposed Significance Proposed Grade 1 Prince Alfred Hamlet Aesthetic, townscape, Grade III settlement architectural, historical Grade II sites: 2 Bella Vista Historic ungraded 3 Ceres Aesthetic, townscape, Grade III settlement architectural, historical, Grade II sites: associational 4 Wolseley Townscape, architectural, Grade III settlement historical, associational Grade II sites: 5 Theronsberg Pass Historical, aesthetic, Grade II associational, rare 6 Botmaskloof Pass Scenic, Historical routes with Grade III associational significance 7 Hottentotskloof and Scenic, Historical routes with Grade III Theronsberg pass associational significance 8 Karoopoort Architectural, historical, Grade II (Poort, building and aesthetic, associational, rare fig tree avenue and stone wall) 9 Elandsberg farms Architectural, natural, Grade II as a collection of historical, associational, rare, farms 10 Dispersed structures and Historical, architectural, To be individually assessed buildings over 60 years aesthetic

Table 5.2: Route Option 1: Landscapes

No. Landscape Proposed Significances Proposed Grade 1 Inverdoon Private Nature biophysical, aesthetic, Grade III Reserve associational, intrinsic 2 Swartland aesthetic, biophysical, Grade II associational 3 Elandsberg Provincial Nature biophysical, aesthetic, intrinsic Grade III landscape, Reserve associational, historical, Elandsberg farms Grade representative of Swartland II in conglomerate 4 Mountain regions and biophysical, aesthetic, intrinsic Grade II and III associated valleys associational, historical, 5 Winterhoek, KoueBokkeveld, biophysical, aesthetic, intrinsic Grade II Waboomberge, Skurweberge associational, historical, 6 Klein Cederberg and biophysical, aesthetic, intrinsic Grade III Groenfontein Private Nature associational, historical, Reserves 7 Koue Bokkeveld and biophysical, aesthetic, intrinsic Grade III associated valley associational, historical, 8 Ceres Karoo aesthetic, biophysical, Grade II associational 9 Moordenaars Karoo aesthetic, biophysical, Grade II associational, 10 Great Karoo aesthetic, biophysical, Grade II associational

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Table 5.3: Prince Alfred Hamlet Name of town Prince Alfred Hamlet Historical Pattern Speculative venture of in individual, Johannes Cornelis Goosen. In March 1851 he bought the farm Wagenbooms Rivier. Ten years later he measured out first 80 and then another 10 plots and sold them with rights to water from the Bakoven river. Date of settlement 1861 Relationship to natural Upper portion of the Ceres Valley with direct relationship to systems surrounding mountain topography and the Bakoven River Rarity No Potential to Yield Information Yes, detail study of structures, land use and social histories Demonstrates a particular Small scale, fine grained townscape class of place Particular Aesthetic Character Small town within Breede Valley Technical/creative Early buildings of town have a creative and technical achievement. achievement of period Many historic buildings did not survive the 1969 earthquake Social/Cultural/Spiritual unknown Association Association with life/work of British Duke of Edinburgh, Prince Alfred after whom the town is people of importance in SA named history Association with history of No Slavery Statement of Significance  Settlement dating from mid-19th c of historic significance  Architecture: Provincial heritage sites (Dutch Reformed Church, local heritage sites (19th c and 20th c) of architectural significance  Well vegetated townscape within agricultural and mountainscape context has an aesthetic significance Proposed grading Grade III C

Table 5.4: Ceres / Bella Vista Name of town Ceres /Bella Vista Historical Pattern Reflects development of settlements as agricultural nodes expanded. Orthogonal grid at right angles to the river, town established on the farm Rietvalley adjacent to the Dwars River Date of settlement 1848 Relationship to natural Dwars River runs at the edge of the historic settlement and now in systems the centre as the 1958 expansion of Ceres occurred across the river. Surrounded by mountainscapes

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Name of town Ceres /Bella Vista All approaches to Ceres are from scenic routes Rarity Streets names after prominent scientists of the early 19th c Unusual layout in relation to river Potential to Yield Information Yes, detail study of structures, land use and social histories Particular Aesthetic Character Situated within an agricultural context (fruit farms) with the surrounding Warme and Koue Bokkeveld Mountains, surrounded by historic farms and homesteads. Approach views through mountain passes is of unique character Technical/creative 19th c structures and land uses achievement of period Social/Cultural/Spiritual Association Association with life/work of CO Hager, master Church designer people of importance in SA history Association with history of unknown Slavery Statement of Significance  Settlement dating from early 19th c of historic significance  Architecture: Provincial heritage sites (Dutch Reformed Church, local heritage sites (19th c and 20th c) of local architectural significance  Well vegetated townscape within agricultural and mountains context has aesthetic significance  Dennebos a poplar caravan park has social significance Proposed grading Grade III C

Table 5.5: Wolseley Name of town Wolseley Historical Pattern Expansion of agricultural nodes, Grid layout Date of settlement 1875 Relationship to natural Situated in the Breede River Valley on a natural watershed that systems divides the Berg River which drains towards the West Coast and the Breede River which drains towards the South-East Rarity No Potential to Yield Information Yes, detail study of structures, land use and social histories Demonstrates a particular Town that deals with agricultural services and light industrial class of place activities (e.g. former blanket making, wine industry products), part of the network of settlements in the Tulbagh-Ceres valleys Particular Aesthetic Character Low scale and density town with agricultural support businesses

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Name of town Wolseley Technical/creative Blockhouses constructed by the British military to protect bridges achievement of period over rail links during Anglo-Boer war Social/Cultural/Spiritual Anglo-Boer War Association Association with life/work of Town named Wolseley after Sir Garnet Wolseley, the British people of importance in SA governor of Natal history Association with history of No Slavery Statement of Significance Architectural and Historical: Two blockhouses dating from the Anglo-Boer War (1901) that can be seen along the railway line to the South of the town. Proposed grading Ungraded

Table 5.6: Philadelphia Name of town Philadelphia Historical Pattern Church town, on former farm Dassenvalley farm, layout a rectangular grid Date of settlement 1858 Relationship to natural Situated on a river systems Rarity Rarity relates to the Church town of a small size Potential to Yield Information Yes, detail study of structures, land use and social histories Demonstrates a particular Aesthetic of historical townscape with central Church complex class of place and later expansion of residential areas Particular Aesthetic Character Village of rural character (dirt roads and Eucalyptus trees) situated within the Swartland agricultural context, associated link to Church Parsonage: Kerkplaas (Church farm) ‘Dasvlei’ Technical/creative Yes, Church settlement and associated village achievement of period Social/Cultural/Spiritual Dutch Reformed Church Association Association with life/work of D R Minister JJ Beck who withheld permission to start the parish people of importance in SA history Association with history of No Slavery Statement of Significance  Settlement dating from early 19th c of historic significance; successful appeal by local farmers and villages to the Synod to establish a new parish after permission as upheld ______61

Name of town Philadelphia  Architecture: Provincial heritage sites (Dutch Reformed Church, local heritage sites (19th c and 20th c) of local architectural significance  Original layout, mature trees, rural context and Church precinct has aesthetic significance Proposed grading Grade III B

5.3 ROUTE OPTION 2 Route Option 2 is from Kappa to east of Portville over the Koue Bokkeveld and Winterhoek Mountain ranges. From position east of Porterville the route travels south west to Saron and adjacent to Riebeek Kasteel. It changes a series of directions travelling south to adjacent Abbotsdale, Kalbaskraal to Omega substation.

Table 5.7: Route Option 2: Settlement / Structure No. Settlement Proposed Significance Proposed Grade 1 Saron Aesthetic, townscape, Grade III settlement architectural, historical, Grade II sites: associational 2 Riebeek Kasteel Aesthetic, townscape, Grade III settlement architectural, historical, Grade II sites: 3 Kalbaskraal Historical Grade III 4 Dispersed structures and Historical, architectural, Grade III buildings over 60 years aesthetic

Table 5.8: Route Option 2: Landscapes No. Landscape Proposed Significance Proposed Grade 1 Inverdoon Private Nature biophysical, aesthetic, Grade III Reserve associational, 1 Koue Bokkeveld Mountain biophysical, aesthetic, Grade II range 2 Valley between Koue biophysical, aesthetic, historic Grade II Bokkeveld Winterhoek Mountain ranges 3 Winterhoek Mountain range biophysical, aesthetic, Grade II 4 Visgat Natural Heritage Site biophysical, aesthetic, historical, Grade III 5 Riebeek valley biophysical, aesthetic, Grade III associational, historical,

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Table 5.9: Riebeek Kasteel Name of town Riebeek Kasteel Historical Pattern VOC outpost and later a Church town, On the road between Malmesbury to Hermon, site of VOC outpost established to monitor movement of the KhoeSan Surveyor RJ Moll established a rectangular street grid of 1.3 x 0.7m below Main road Date of settlement Pre 1840, Parish established 1868 Relationship to natural Situated on lower slopes of Kasteelberg with streams giving water systems to settlement Rarity Indirect relationship to early 19th century slave rebellion Potential to yield Information Yes, detail study of structures, land use and social histories Demonstrates a particular Yes, small Church town within agricultural Swartland landscape class of place

Particular aesthetic character Settlement within an agricultural and natural context of high aesthetic significance; surrounding historic farms of Cloovenburg and Allesveloren; views from settlement towards agricultural valley, mountainscapes and visual links with other settlements in the valley Technical/creative Early 19th c significant structures achievement of period Social/Cultural/Spiritual DR Church Association Association with life/work of Jan Smuts, born on Ongegund farm (in context) people of importance in SA DF Malan, born on farm Allesveloren history Association with history of Indirect relationship with slavery and the quelling of the early 19th Slavery century slave rebellion in the region Statement of Significance  Settlement dating from early 19th c of historic significance  Architecture: Provincial heritage sites (former Dutch Reformed Church, local heritage sites (19th c and 20th c) of local architectural significance  Surrounding agricultural landscape: Farms de Hoop, and historic structures and landscape features of aesthetic significance Proposed grading Grade IIIB

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Table 5.10: Saron Name of town Saron Historical Pattern Rhenish Mission Station, on farm De Leeuwenklip, now run by DR Mission Church Date of settlement 1846 Relationship to natural Foothills of the Groot Winterhoek mountains systems Rarity Rare, established for the resettlement of freed slaves, unusually intact and authentic, its placement of level ground is unusual Potential to Yield Information A single recent architectural stud has revealed the heritage values inherent in the settlement. The social history of the community and its relationships to other mission settlements should be researched Demonstrates a particular Yes, mission village, unrecognised heritage values class of place Particular Aesthetic Character Yes, 19th c mission village Technical/creative Yes, especially the civic buildings such as the Mission Church, achievement of period graveyard, Parsonage and Mission store Social/Cultural/Spiritual Yes, with Rhenish and DR Churches Association Association with life/work of Emancipated Slaves and their descendants people of importance in SA Rev. JH Kulpmann, founded the mission station history Association with history of Yes Slavery Statement of Significance  Settlement dating from early 19th c of historic significance;  Successful appeal by local farmers and villages to the Synod to establish a new parish after permission as upheld  Architecture: Provincial heritage sites (Dutch Reformed Church and graveyard, local heritage sites (19th c and 20th c) of local architectural significance  Original layout, mature trees, rural context and Church precinct has aesthetic significance  Remaining intact layout of houses with productive gardens behind them Proposed grading III A

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Table 5.11: Kalbaskraal Name of town Kalbaskraal (Kalabaskraal) Historical Pattern Ribbon layout, town established due to railway junction and station Date of settlement Late 19th c Relationship to natural No systems Rarity No Potential to Yield Information Demonstrates a particular Town developed at the establishment of a railway station and class of place siding Particular Aesthetic Character Main road ribbon development, smallholding character Technical/creative No achievement of period Social/Cultural/Spiritual No Association Association with life/work of No people of importance in SA history Association with history of No Slavery Statement of Significance Structures of local architectural sigificance Proposed grading Ungraded

Table 5.12: Abbotsdale Name of town Abbotsdale Historical Pattern Ribbon development, Anglican Mission settlement for resettlement of freed slaves Date of settlement 1869 farm purchased by Bishop Grey, settlement established 1877 Relationship to natural Diep River in centre of settlement systems Rarity One of few mission stations in Western Cape (others are Saron, Elim, Wuppertal, Mamre) and one of very few Anglican missions Potential to yield Information Yes, social history of decedents of freed slaves and their settlement histories Demonstrates a particular Subsistence agricultural Christian community class of place Particular Aesthetic Character Predominately modern structures on low urbanised town Technical/creative Early structures from the 19th c century ______65

Name of town Abbotsdale achievement of period Social/Cultural/Spiritual Anglican Church Association Slaves Association with life/work of Bishop George Grey people of importance in SA history Association with history of yes Slavery Statement of Significances Historical (resettlement of slave in the late 19th c)

Proposed grading Grade IIIC

5.4 ROUTE OPTION 3 Route Option 3 is the same as Option route 2 on the initial alignment from Kappa traveling north east over the Koue Bokkeveld and Winterhoek Mountain ranges. The route is north of Porterville Koringberg and Hopefield to the Aurora substation. The route travels south to west of Darling to the Omega substation. Option 3b is west of Oprtion 3 adjacent to the R27 roadway to join option 3 south of Darling. Option 3a connects Options 3b to 3 west of Darling. Option 3c is from Aurora on the same alignment as Option 3 until it diverts towards the coast west of Mamre and re-joins Option 3 south west of Atlantis. Table 5.13: Route Option 3: Settlement / Structure No. Settlement Proposed Significance Proposed Grade 1 Porterville Aesthetic, townscape, Grade III settlement architectural, historical, Grade II buildings associational 2 Piketberg Aesthetic, townscape, Grade III settlement architectural, historical, Grade II buildings associational 3 Koringsberg Aesthetic, townscape, Grade III settlement architectural, historical,

4 Darling Aesthetic, townscape, Grade III settlement architectural, historical, Grade II buildings associational 5 Dispersed structures and Historical, architectural, buildings over 60 years aesthetic

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Table 5.14: Route Option 2: Landscapes No. Landscape Proposed Significance Proposed Grade 1 Koue Bokkeveld mountain Biophysical, aesthetic, historical, Grade II range associational 2 Groot Winterhoek mountain Biophysical, aesthetic, historical, Grade II range associational, intrinsic 3 Valley between Koue Biophysical, aesthetic, historical, Bokkeveld and Winterhoek associational, intrinsic, mountain ranges 4 Fossil Park Biophysical, aesthetic, historical, Grade I associational 5 West Coast National Park Biophysical, aesthetic, historical, Grade I associational 6 Rondeberg Private nature Biophysical, aesthetic Grade III Reserve 7 Jakkelsfontein Private nature Biophysical, aesthetic Grade III reserve 8 Hopefield Nature Reserve Biophysical, aesthetic Grade III 9 Buffelfontein Private reserve Biophysical, aesthetic Grade III 10 Pierre Jeanne Gerbel Private Biophysical, aesthetic Grade III Nature Reserve

Table 5.15: Piketberg (outskirts of town falls on edge of corridor, included because of viewshed) Name of town Piketberg Historical Pattern Church town established on farm Grootfontein. Irregular grid layout by surveyor J Knoble (some streets are straight but are irregular spaces and at time not parallel), possibly a piecemeal layout determined by existing wagon road (original name Piquetberg) Date of settlement 1836, establishment of Church 1836, erven sold from 1840 Relationship to natural Foot of Piquet Mountain with streams used in furrow system systems throughout town Rarity Exemplary urban design of town around central Church site Mid 19th c residences exist in late 19th c form Victorian Hotel intact Potential to Yield Information Yes Demonstrates a particular Yes, small town within agricultural Swartland landscape class of place

Particular Aesthetic Character Stone Church and vegetated site with surrounding historic

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Name of town Piketberg buildings Avenue of Eucalyptus trees on Main road Technical/creative Town layout, Church, 19th c buildings achievement of period Social/Cultural/Spiritual DR Church Association Jewish community Association with life/work of Cochoqua, leader of the Gonnema who killed burgers nearby in people of importance in SA 1673 history Architect Hager Association with history of No Slavery Statement of Significance  Settlement dating from early 19th c of historic significance  Architecture: 32 Provincial heritage sites that include buildings, graves, trees (refer Annexure ? ) local heritage sites (19th c and 20th c) of local architectural significance  Historic core with notable buildings and pear trees avenue has aesthetic significance Proposed grading Historic core PHS Grade II

Table 5.16: Porterville (outskirts of town falls on edge of 4km corridor) Name of town Porterville Historical Pattern Grid layout, founded by Frederick John Owen on farm Willemsvallei Date of settlement 1862 Relationship to natural Foothills of mountainscape systems Rarity No Potential to Yield Information Yes, detail information of built structures and residents social histories Demonstrates a particular Yes, small town within agricultural Swartland landscape class of place

Particular Aesthetic Character 19th c townscape, with historic and modern structures Technical/creative Yes, early structures, such as Old Police Station and residences achievement of period Social/Cultural/Spiritual Named after William Porter, attorney general Association Association with life/work of CO Hager Architect of initial Church (now demolished) people of importance in SA

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Name of town Porterville history Association with history of No Slavery Statement of Significance  Settlement dating from early 19th c of historic significance  Architecture: 32 Provincial heritage sites that include buildings, graves, trees local heritage sites (19th c and 20th c) of local architectural significance  Historic core with notable buildings and pear trees avenue has aesthetic significance Proposed grading III C

Table 5.17: Koringberg and surrounding farms Name of town Koringberg Historical Pattern Church town established at a railway siding Date of settlement Relationship to natural systems Rarity Very small settlement driven by rail link, surrounding farms of significant historical buildings and include graveyards Potential to Yield Information Yes, detail study of structures, land use and social histories Demonstrates a particular Yes, small town of rural character within agricultural Swartland class of place landscape Particular Aesthetic Character Rural character within a Swartland agricultural context Technical/creative Early land uses and 19th c structures achievement of period Social/Cultural/Spiritual Church, links to community and surrounding parishes not yet Association established Association with life/work of unknown people of importance in SA history Association with history of Slavery Statement of Significance  Rural character of town of aesthetic significance Proposed grading of Grade III C settlement

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Table 5.18: Darling Name of town Darling Historical Pattern Church town, established on part of the farm Langfontein. Almost square historic settlement. Rectangular grid of elongated blocks with a wider strip in the centre to accommodate the river. 20th c expansions to the north east (Nuwedorp) created grid of smaller erven resulting in smaller houses and higher density. Date of settlement 1853, named after the acting Governor of the Cape, Sir Charles Henry Darling Relationship to natural River in the centre of the historic settlement systems Rarity Unusual grid layout of river in centre (similar to Ceres with its expansion to both sides of river) Potential to Yield Information Yes, detail study of structures, land use and social histories Demonstrates a particular Yes, small town of rural character within agricultural Swartland class of place landscape Particular Aesthetic Character Rural character within a Swartland agricultural context, nearby farm Oudepost Technical/creative Early land uses and 19th c structures achievement of period Social/Cultural/Spiritual DR Church Association Association with life/work of Named after acting Governor of the Cape, Sir Charles Henry people of importance in SA Darling history Entertainer Pieter Dirk Uys lives in Darling Association with history of Slavery Statement of Significance  Settlement dating from early 19th c of historic significance  Architecture: Provincial heritage sites, local heritage sites (19th c and 20th c) of local architectural significance  Rural character of town of aesthetic significance Proposed grading of Grade III B settlement

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SECTION 6 IMPACT ASSESSMENT

6.1 INTRODUCTION Section 6 presents assessment of the impacts of the proposals on cultural landscapes, settlements and individual resources. The assessment of impact has been undertaken in terms of the analytical framework established by heritage indicators. Assessment tables below identify and describe resources and assess impacts on the resource. The scale of impact, degree of scale and duration of impact are recorded. Where negative impacts are assessed, mitigation measures and/or directives for implementation are provided.

6.2 SCOPING PHASE ASSESSMENT The preferred route for detailed assessment recommended in the Scoping Phase is Option 1, Ia and 2, south of its conjunction with option 1a. Route Option 2 north of this junction and Option 3 were not the preferred routes as the proposed negative impacts of a 765kV powerlines and associated infrastructure on mountains and valleys with a high degree of intactness and historic settlements was assessed to be extremely high. These routes were therefore excluded from viability prior to the assessment stage.

6.3 ASSESSMENT PHASE The assessment phase includes a detailed study of the preferred route and its possible alternatives (options 1, 1a, and 1b), while mapping existing and possible heritage resources for all eight proposed routes (refer Tables 6.1 – 6.6). Where heritage resources will be adversely impacted, the consideration of alternative routes and no-go areas are recommended. The powerline assessments include mitigation measures of adverse impacts to cultural landscapes and the built environment.

Figure 31: Diagram of Cultural Landscape Elements and Informants (adapted from MetroGIS) ______71

Figure 32: Kappa Omega Assessment Zones

6.4 ZONES AND ROUTE OPTIONS The linear nature of the proposals has necessitated dividing the routes into zones for clear communication.

 Zone 1 Ceres Karoo: The lower border of the Ceres Karoo region lies to the area just northeast of the Karoopoort.  Zone 2 Cape Fold Belt Mountains and valleys  Zone 3 Swartland and narrow coastal strip

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Table 6.1 Impact Assessment Route Option 1 Zone 1 No. KAPPA OMEGA 2ND 765KV POWER LINE ROUTE OPTION 1 ZONE 1: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Heritage Resources Landscape Typology Description Position in corridor Impact assessment13 Mitigation of assessed Confidence of assessment negative impacts Image if applicable F Platfontein Farm Productive agricultural Small farm complex on Mid corridor 500m north Local No mitigation required Medium High 1/1/1 node within remote arid riverine tributaries, dam, of farm node Cumulative medium landscape kraals and irrigated fields, 450m from existing 400kV negative impact Ref large trees, on stream power line and 1st 765kV map 8 tributaries structures <5, power line, Situated Permanent 1.4km from Kappa (1970T-2) substation, bisected by roadway to Kappa substation Already highly impacted further high impact F Die Brak Farm Farm node within remote Small farm node on Mid corridor 1.6km south Sub regional No mitigation required Medium High 2/1/1 arid landscape riverine corridor, of node Cumulative Medium structures <5 400kV line 1.6km south of negative impact ref (1970T-3) node Map 8 F Kolkiesrivier Farm Productive agricultural Small farm node situated Mid corridor 170m north Local Position power line south Medium High 3/1/1 node within remote arid on edge of riverine west of farm node, 290m Cumulative medium of existing 400kV landscape corridor with 3 structures north of existing 400kV negative impact powerline within corridor Ref kraals, reservoir power line and 990m to prevent framing farm map 8 (1969T-3) north of 1st 765kV & Cumulative High negative node with powerlines 400kV power line if power line situated north of 440kV line Permanent F Tweerivier Farm Productive agricultural Small farm adjacent to Mid corridor 420m south Local Position power line south Medium High 3/1/1 node within remote arid R356 on edge of riverine node, 1.3km north of Cumulative medium of existing 400kV landscape corridor, kraals, large dam 400kV power line, situated negative impact powerline within corridor Ref Structures <5 on edge of Inverdoorn Cumulative high negative map 7 (1969T-3) private nature reserve impact if line situated north of 400kV line Permanent

NR Inverdoorn Private Ceres Karoo 10 000 hectare reserve Mid corridor traverses Local Position power line south Medium High 1/1/1 Nature Reserve with 1200 animals, largest nature reserve High impact of existing 400kV number of animals of all Sub regional powerline within corridor Map 7 Cumulative medium the private reserves in the & 8 negative impact Cape Cumulative high negative impact if line situated north of 400kV line Permanent

13 Impact Assessment: Scale (regional, sub regional, local) Measurement (High, Medium, Local) (Positive, Neutral, Negative) Duration of Impact (Permanent, Semi permanent, temporary)

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Table 6.2 Impact Assessment Route Option 1 Zone 2

No. KAPPA OMEGA 2ND 765KV POWER LINE ROUTE OPTION 1 ZONE 2: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Heritage Resources Landscape typology Description Position in corridor Impact assessment14 Mitigation of assessed Confidence of assessment negative impacts Image if applicable

SR Karoopoort Scenic route R46 through Karoopoort, Local Position power line south High 1/1/2 Proposed line runs along High negative impact of existing 400kV power the peak of the ridge on lines so that powerline is Ref the north of the scenic south of scenic route Map 7 route Historical and scenic route Permanent

Position powerlines off ridge lines

BoD/ST 2013 O Karoopoort Outspan Outspan within poort Mentioned repeatedly by Mid corridor traverses Local Position power line south High 1/1/2 (1848) on narrow kloof early travellers. An former outspan High negative impact of existing 400kV power within mountainous important stop on the old lines so that powerline is Ref terrain highway into the interior, Permanent south of outspan and Map 7 Confluence of historic particularly after the outside of the immediate routes to interior and discovery of diamonds in poort, position proposed Sutherland Kimberly. The old inn line within existing (1971T-3) complex built around powerline corridor 1848-1850, probably after Position powerline off ARCOM: 2011 the opening of Mitchells crest of ridge Pass. Of regional historical, architectural, & Position to be determined aesthetic significance. Its at walk down unique sense of place has been negatively impacted on by existing transmission lines (ARCON ARCOM:2011 2011). Rectangular thatched hipped house with rear lean to, tree avenue, wall, structures 5+ Toll House: Provincial Heritage Site (PHS)

14 Impact Assessment: Scale (regional, sub regional, local); Measurement (High, Medium, Local) (Positive, Neutral, Negative); Duration of Impact (Permanent, Semi permanent, temporary) ______74

Google Earth 2014 F Vrede Farm Productive agricultural Large farm with irrigated Mid corridor 600m to farm Local: Position power line south Medium High 1/1/2 node within fertile valley lands, structures approx. node Cumulative medium of 400kV power line so 10+ mature trees, graves, 400kV power line negative that farm node not Ref adjacent to R46, traverses farm & approved Cumulative high negative framed by powerlines Map 7 mountainside south of 765kV power line south of if line situated north of farm node, structures 5+ 400kV lines 400kV line (1971T-3)&(1971T-5) Permanent Permanent

F Nuwerus Farm Productive agricultural Large farm with irrigated 400m south from mid Local: Position power line south Medium High 2/1/2 node within fertile valley lands structures 5+ corridor Cumulative medium of 400kV power line so (image see above) Adjacent to R46, mature 400kw power line on farm negative that farm node not Ref trees, dam (1971T-7) 765kV line on south framed by powerlines Map 7 corridor Cumulative high negative if line situated north of 400kV line Permanent

F Heilbron Farm Productive agricultural Small farm node with 580m south of mid Local: Position power line south Medium High 3/1/2 node within fertile valley irrigated lands structures corridor Cumulative medium of 400kV power line so (image see above) F <5 400kw power line negative that farm node not 4/1/2 Adjacent to R46, mature adjacent to farm node Cumulative high negative framed by powerlines Eucalyptus grove dam 765kV line south of 400kV if line situated north of Ref (1965T-3) on farm 400kV line Permanent Map 7

F Hottentotskloof Farm Ruin adjacent to R46 and 400kw and 765kV power No impact – no residence No mitigation required Medium High 5/1/2 mountain (1965T-2) line south of ruin in node Permanent Ref Map 7

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SR Hottenstotkloof Pass Scenic linking route Early mountain passes Proposed line runs parallel Local: High Position power line south 2/1/2 linking agriculturally with the pass (above the of existing 400kV power Ref productive landscapes, road) and crosses the Permanent lines to the south, cross Map 7 scenic route scenic route more than roads and scenic routes at + 30 once right angles

F Langfontein Farm Productive agricultural Large historic farm node Mid corridor traverses Local: Position power line south High confidence 6/1/2 node within fertile valley with irrigated lands farm, homestead 220m High negative impact of existing 400kV power Ref Fransen 2004:380 structures 10+ from mid corridor lines beyond ridge so not Ref Adjacent to R46, Historic Existing 440kV line south Cumulative high negative to frame farm node Map 7 homestead mature trees, of mid corridor and impact if line situated + 30 dam, Labourers housing homestead north of 400kV line structures 10+ Permanent (1965T-13) F Slangfontein Farm Productive agricultural Small farm node with Mid corridor traverses Local: Position power line south High 7/1/2 node within fertile valley irrigated lands structures farm and scenic route High negative impact of existing 400kV power <5 (R46), homestead 140m Sub Regional: lines beyond ridge so not Ref Adjacent to R46, mature from mid corridor Cumulative medium to frame farm node Map 7 trees, dam, Labourers negative impact; + 30 housing Existing 2 x 440kV lines Cumulative high negative (1965T-4) south of mid corridor and if line situated north of homestead existing 400kV line Permanent SR Theronsberg Pass Scenic route Single lane road entering Mid corridor adjacent and Local: Position power line south Medium high 3/1/2 R46 Ceres valley to the east, traverses scenic route High negative impact of existing 400kV power adjacent to Waboomberg. lines beyond ridge Ref Views of valley & Permanent Line crosses the R46 Map surrounding mountains approximately at right 30 Recommended Grade III angles, with the valley Route and landscape (D- topography and mountain PSDF 2013: Annexure backdrops providing a B:28) visually absorptive This pass is of backdrops considerable scenic significance within the local context, as well as of regional historical significance as part of the historic road system running to Karoopoort and beyond. This became the main stage coach & transport rider’s route to Kimberly after the discovery of diamonds (ARCON: 2011). ______76

Unnamed Outbuildings or Labourers Mature trees (1971T-1) Node 1.6km north of mid No impact on site No mitigation required Medium High housing within irrigated corridor line Ref fields Map 30 M Koue Bokkeveld Mountain wilderness Dominant scenic features, Mid corridor on mountain Local: High negative Position powerline off Medium high confidence 1/1/2 forms part of the Cape foothills impact foothills, south Waboomberg Fold Mountains of existing 400kV power Ref representing locally Permanent lines Map significant biodiversity and 30 water catchment. Contains numerous archaeological resources, recreational elements,

scenic and historical mountain passes Recommended as Grade III (D-PSDF)

F8/1/2 Die Wingerd Farm Productive agricultural Modest linear werf Mid corridor 1.3km from Local: Position power line south Medium High node within fertile valley consisting of an ‘L’-shaped homestead. Existing Cumulative high negative of R46 closer to farm node (Image Arcon, 2010) Ref homestead with small out- 400kV line on farm impact which is already framed Map buildings. The werf faces adjacent to R46 (north of and highly impacted by 30 into the valley. The farm node) and south of Sub regional: existing and approved 1st homestead has strong farm node behind ridge, Cumulative high negative 765kV line. Walk down to late 19th/early 20th C 1st 765kV to be parallel to impact determine mitigatory stylistic characteristics exiting 400 kV line north measures including surviving of farm node Permanent Victorian verandah & small pane sash windows. Structures 5+Adjacent to R46, mature trees, dam, Labourers housing. Tall palm in front garden is a

typical landscaping feature of this period. The werf is of broad contextual architectural/ aesthetic, rather than intrinsic cultural significance within the sub-regional context (1959T-6) (ARCON 2010)

F9/1/2 Rhodona Farm Formal farm layout within Historic 18th c homestead, Mid line 1.2km north of Local: Walk down required Medium high confidence productive agricultural formal garden, mature homestead node. Farm High negative impact Ref node within fertile valley trees, irrigated lands, node is located approx.- ______77

Map grave site, dam within imately equidistant Cumulative high negative 30 500m from R46 (1959T-8) between existing as farm node is framed powerlines. Existing 400kV on farm 1st 765kV on northern portion of farm and traverses R46 adjacent to farm. Existing 2nd 400kV line south of farm node visible

F De Rust Farm Formal farm layout Homestead later 19th c, Mid line 1.7km north of Sub regional No mitigation measures High Medium 10/1/2 adjacent to riverine Labourers housing, homestead Cumulative negative Ref corridor within productive mature treed avenue, impact of additional line Map agricultural node within dam, irrigated land within valley 30 fertile valley structures 5+ (1959T-6) Permanent F Elim Farm Productive agricultural Small farm node with Mid line 1.5km south of Sub regional No mitigation required High Medium 11/1/2 node on edge of Koue dams, irrigated land, farm node. Existing 400kV Cumulative negative Bokkeveld escarpment mature trees structures 5+ lines south of mid line. 1st impact of additional line Ref (1959T-4) 765kV north of farm node within valley Map Permanent Permanent 30 F Hamlet Farms Formal farm layout Historic homestead, Mid line 1km south of Sub regional No mitigation required High Medium 12/1/2 adjacent to riverine mature trees, dams, homestead Cumulative negative corridor within productive irrigated lands, Labourers impact of additional line Ref agricultural node within housing, mature trees within valley Map fertile valley structures <5 (1959T-4) Permanent 30 CL Ceres Valley Coherent historical Distinctive pattern of rural Mid corridor bisects Sub regional Position line adjacent to High confidence 1/1/2 agricultural valley: rural settlement interspersed northern section of valley Cumulative Medium existing 400kV lines and (for detailed images, see section 4.6) settlement and cultivation with compact nodes, with negative impact minimum 400m away Ref mid 18th century cultivation forming an arc from homestead nodes Map at the valley’s southern and Bella Vista settlement 30 and western edges with the Witzenberg and Hexberg backdrop. Collection of historic homesteads (Winter & Baumann 2010 in D-PSDF 2013) F Welgemeen Farm Farm node adjacent to Historic homestead late Farm node 400m north of Local Position powerlines south Medium High 12/1/2 riverine corridor within 19th c, mature trees, treed mid corridor. High impact High negative impact of existing 400kV lines fertile valley, significant entrance avenue, dams, on farm node Sub regional within corridor Ref agricultural context irrigated lands, Labourers Cumulative negative Map housing, mature trees impact of additional line 30 structures 10+ (1959T-5) within valley (1959T-5) (1959T-4) Permanent

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F De Liefde Farm Small farm node adjacent Historic farmstead late Mid line 1.7km south of Sub regional Cumulative No mitigation required Medium High 13/1/2 to riverine corridor within 19th century, irrigated farm. No impact on farm negative impact of fertile valley, significant lands, dam, structures >5 and its immediate context additional line within Ref agricultural context (1959T-4) valley Map Permanent 30 F Jagerskraal Farm Large farm within Historic farmstead late Mid line 1.4km south of Sub regional No mitigation required Medium High 14/1/2 productive agricultural 19th century, Labourers main farm node. Cumulative negative node within fertile valley, housing, additional impact of additional line Ref significant agricultural farmhouse, extensive within valley Map context outbuildings, irrigated 30 lands, dam, dispersed Permanent nodes, structures 10+ (1959T-4) & (1959T-4) & (1959T-2) F Delta Farm Large farm nodes in Farm consists of 2 nodes: Mid line 1.9km south of Sub regional No mitigation required Medium High 15/1/2 agricultural context within historic homestead with main farm node Cumulative negative fertile valley large outbuildings; Packing impact of additional line Ref sheds and Labourers within valley Map housing adjacent to R303 Permanent 30 and river, mature trees, structures 10+ (1959T-7) RS Price Alfred Hamlet Station precinct in Station precinct consists Mid line 1.4km south of Sub regional No mitigation required Medium High 1/1/2 Station agricultural context within of railways infrastructure, station precinct. Low Cumulative negative Ref fertile valley railways residences (c impact impact of additional line Map 1950s), sheds within valley 30 Permanent Permanent F Sonop Farm Small farm node in Compact farm node, Mid line 1.7km south of Sub regional No mitigation required Medium High 16/1/2 agricultural context within historic and modern node. Cumulative negative fertile valley adjacent to R homesteads, late 19th impact of additional line Ref 303 c/20th c Labourers within valley Map housing, mature trees, Permanent 30 irrigated lands (1959T-6) F Poiters Farm Linear farm node within Linear farm node with Mid line 1.6km south of Sub regional: Cumulative No mitigation required Medium High 17/1/2 productive agricultural homestead, Labourers node. negative impact of valley housing, outbuildings, additional line within Ref mature trees, irrigated valley Map lands, dam, structures 10+ Permanent 30 (1959T-5) F Unnamed Farm Farm node with irrigated Labourers settlement, Mid corridor 200m south Local No mitigation possible 18/1/2 lands within significant mature trees, structures of farm node High negative impact agricultural valley 5+ (1959T-9) Sub regional Ref Cumulative negative Map impact of additional line 30 within valley Permanent ______79

F Eureka Farm Small farm node with Homestead, outbuildings, Mid corridor 1.35km south Sub regional Cumulative No mitigation required Medium High 19/1/2 irrigated lands within Labourers housing, of farm node negative impact of agricultural valley, structures 5+ (1959T-5) additional line within Ref significant agricultural valley Map context Permanent 30 F Mendoza Farm Farm node with irrigated Homestead, outbuildings, Mid corridor 630m south Sub regional Cumulative No mitigation required Medium High 20/1/2 lands within fertile valley, structures 5+ (1959T-7) of farm node negative impact of significant agricultural additional line within Ref context valley Map Permanent 30 F Larochelle Farm Farm node with irrigated Homestead, Labourers Mid corridor 1.45km south Sub regional No mitigation required Medium High 20/1/2 lands within fertile valley, housing, dam, of farm node Cumulative negative significant agricultural outbuildings, mature impact of additional line Ref context trees, structures 5+ within valley Map (1959T-6) & (1959T-5) Permanent 30 F Perdefontein Farm Dispersed nodes within Homestead, labourers Mid line 200m north of Local Position line south of Medium High 21/1/2 productive fertile valley, housing, dam, farm node. Existing 400kV High negative impact. Perdefontein adjacent to significant agricultural outbuildings, mature lines 250m and 1km south Farm node with be existing 400kV line and Ref context trees, structures 5+ of farm node significantly impacted by located north of Bella Map (1959T-5) proposed line Vista 30 Sub regional: Cumulative negative impact of additional line within valley Permanent

F Den Haag Farm Agricultural node within Farm node with late 19th c Mid line traverses farm Local: Position line south and Medium High 22/1/2 productive fertile valley, homestead irrigated land, node. Existing 400kV High negative impact adjacent to existing 400kV significant agricultural dam, structures situated approx. 600m Sub regional: Cumulative line Ref context (1959T-4) south of farm node negative impact of Map additional line within 30 valley Farm node with be significantly impacted by additional proposed line Permanent

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S Bella Vista settlement Apartheid era settlement Adjacent to R303 Mid line 0.74m north of Local: Settlement already highly High 1/1/2 to enable racial Medium density settlement. 400kV line High negative impact impacted by two existing segregation, with 21st c settlement with cemetery immediately north of Sub regional 400kV lines Ref expansion with few apparent settlement and bisecting Cumulative negative Map amenities, settlement impact of additional line in Position line minimum 400 30 bisected by existing 400kV immediate context from northern edge of powerline servitude settlement (1959T-4) Permanent

F Pomona Farm Small farm node within Adjacent to R303, Mid line 170m south of Local Position line south Medium High 23/1/2 productive agricultural dispersed small nodes farm node High negative impact adjacent to existing 400kV valley (homestead) structures <5 Sub regional line Ref (1959T-4) Cumulative negative Map impact of additional line in 30 immediate context Permanent

F Rhodene Farm Small farm node with Homestead, outbuildings, Mid corridor 1.62km south Sub regional No mitigation required Medium High 24/1/2 irrigated lands within Labourers housing, of farm node Cumulative negative fertile valley on foothills of structures 10+ (1959T-4) impact of additional line in Ref mountain valley Map 30 F Voelvlei Farm Small farm node in Homestead, outbuildings, Mid corridor 2km south of Local No mitigation required Medium High 25/1/2 context to river within mature trees, irrigated farm node Low negative fertile valley on foothills of lands (1959T-1) Sub regional Ref mountain Cumulative negative Map impact of additional line in 30 valley

F Petervale Farm Small farm node in Homestead, outbuildings, Mid corridor 1.10km south Local No mitigation required Medium High 26/1/2 context to river within kraals, formally irrigated of farm node Low negative fertile valley on foothills of lands, structures <5 Sub regional Ref mountain (1959T-3) Cumulative negative Map impact of additional line in 30 valley

F Cascade Farm Farm node with irrigated Dispersed nodes, Mid corridor 100m south Local Position line south High 27/1/2 lands within fertile valley Homestead, outbuildings, of farm node High negative impact adjacent to existing 400kV & GF on foothills of mountain mature trees, guest farm, Sub regional line dam, structures 10+ Cumulative negative Ref (1959T-5) impact of additional line in Map valley 30 Permanent

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F Unnamed Farm Labourers settlement Labourers housing Mid corridor 1km north of Local Position line minimum Medium 28/1/2 within irrigated lands structures 5+ (1959T-6) node High negative impact 400m from residences within fertile valley possibly for Waterval Sub regional Ref adjacent to river or/and Groenhof farm Cumulative negative Position to be determined Map impact of additional line in at walk down 30 valley

F Groenhof Farm Dispersed farm nodes with Dispersed node with Mid line is directly over Local Position line minimum High 29/1/2 irrigated lands within homestead, outbuildings, Labourers housing, 170m High negative impact 400m from residences fertile valley on edge of Labourers housing, from outbuilding node and Sub regional Ref mountainside in context mature trees, dam, 350m from homestead Cumulative negative Position to be determined Map to river structures 5+ (1959T-9) node impact of additional line in at walk down 30 valley

F Waterval Farm Small farm node with Homestead, outbuildings, Mid corridor 380m north Local Position line south Medium High 30/1/2 irrigated lands within mature trees (1959T-6) of farm node High negative impact adjacent to existing 400kV fertile valley adjacent to Sub regional so that farm is not framed Ref mountainside on riverine Cumulative negative by powerlines Map corridor impact of additional line in 30 valley

NR Wakkerstroom, Mountainous fynbos Rugged mountain terrain Mid corridor traverses Local Position line adjacent to Medium High 1,2,3 Boointjiesrivier , nature reserves, Wakkerstroom, Medium Negative impact existing 400kV /1/2 Witzenburg and Boontjiesrivier and mitigated by rugged Do not position pylons Winterhoek Nature Witzenburg reserves terrain along ridgelines. Cross Ref reserves Sub regional ridge line Map Cumulative negative 30 + impact of additional line 29 on mountain Permanent

CL Witzenberg Valley Fertile agricultural valley Coherent historical Mid corridor traverses Sub regional No mitigation required Medium high 2/1/2 of cultural significance agricultural valley with section of valley Low cumulative negative PHSs outside corridor (D- impact of additional line in Ref PSDF recommended valley Map grading CL III) 29 Permanent

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F Klein Weltevrede Farm Small farm node on Homestead, outbuildings, Mid corridor traverses Local Position powerlines south High 31/1/2 mountain slope Labourers housing, farm node High negative impact closer to existing 400kV structures >10 (1945T-4) Sub regional lines and a minimum Ref Medium cumulative 400m from farm node Map negative impact of 29 additional line in valley Permanent F Unnamed Farm Small farm node on Homestead, outbuildings, Mid corridor 1.6km south Sub regional No mitigation required Medium High 32/1/2 mountain slope mature trees, structures west of farm node Cumulative negative <5 (1045T-3) impact of additional line in valley Permanent

F Weltevrede Farm Small farm node on Homestead situated Mid corridor 1.9 south Sub regional No mitigation required Medium High 33/1/2 mountain slope with within 2 riverine corridors, west of farm node Cumulative negative irrigated lands in mature trees, impact of additional line in Ref Witzenberg Valley outbuildings, dam, valley map structures 10+ Permanent 29 F Unnamed Farm Farm node situated Structures, mature trees, Mid corridor 1.5km north Sub regional No mitigation required Medium High 34/1/2 adjacent to riverine structures <5 (1945T-1) west of farm node Cumulative negative corridor within medium impact of additional line in Ref agricultural context valley map Permanent 29 F Booitjiesrivier Farm Large farm with dispersed Homesteads, Labourers Mid corridor traverses Local: Position powerlines south Medium High 35/1/2 nodes on riverine corridor housing, dams, section of farm node High Negative impact closer to existing 400kV in Witzenberg Valley outbuildings structures (Labourers housing) south Sub regional lines and a minimum Ref 10+ (1945T-15) west of homestead farm Cumulative negative 400m from farm node map node impact of additional line in 29 valley Permanent

F Unnamed Liner node between to Structures within Mid corridor 300m south Local: Position powerlines Medium High 36/1/2 railway lines uncultivated immediate west of farm node High negative impact minimum 400m from context structures 5+ Sub regional residences Ref (1945T-7) Cumulative negative map impact of additional line in 29 valley Permanent F Unnamed Linear node of cottages Labourers housing with Mid corridor 900m south Sub regional Position powerlines south Medium High 37/1/2 between parallel railway homestead within west of farm node Cumulative low negative closer to existing 400kV lines uncultivated immediate impact of additional line in lines and a minimum Ref context, structures 10+ valley 400m from settlement map (1945T-14) Permanent node 29 ______83

F Goedgevonden Farm Node adjacent to Homestead, outbuildings, Mid corridor 1.5km north Sub regional No mitigation required Medium High 38/1/2 Voortrekker road within Labourers housing, kraals, west of farm node Cumulative low negative agricultural context dams, mature trees, impact of additional line in adjacent to riverine structures 10+ (1945T- 12) valley corridor Permanent CL Wolseley Urban Edge Town in historically Collection of historic Urban edge 1.7km from Sub regional No mitigation required Medium High 2/1/3 significant cultural setting homesteads on the slopes centre of corridor Cumulative low negative Map of the Witzenburg, town impact of additional line in Ref 29 of Wolseley has limited valley heritage value although Permanent placed at the junction of two scenic routes and two valley systems, contributing to a sense of place. (Witzenburg SDF 2012:66) FP Knolvlei Forestry Large Forest Station on Isolated structures within Mid corridor transvers Sub regional No mitigation required Medium High 1/1/2 Plantation edge of mountainside exotic treed environment plantation & 700m south Cumulative low negative (1945T-3) west of structure impact of additional line in Ref valley map Permanent 29 NR Waterval and Hawequas Mountain nature reserves, Natural landscape Corridor traverses Sub regional Position line adjacent to Medium High 4,5 nature reserve, mountainous fynbos features of local Waterval and Elandsberg Cumulative negative existing 400kV ½ Elandsberg (zone three) significance Reverses, cuts across the impact of additional line Do not position pylons north of Hawequas on mountain along ridgelines. Cross Ref reserve north of two Permanent ridge line map existing 400kV lines 29

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Table 6.3 Impact Assessment Route Option 1 Zone 3

No. KAPPA OMEGA 2ND 765KV POWER LINE ROUTE OPTION 1 ZONE 3: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Heritage Resources Landscape typology Description Position in corridor Impact Assessment15 Mitigation of assessed Confidence of assessment negative impacts Image if applicable NR Elandsberg Nature 6000 hectare conservation Provincial Nature reserve Mid corridor traverses Local Position powerlines High 1/1/3 reserve and agricultural site with (D-Psdf 2013:WC Map), southern section, severs High negative impact adjacent to and south of dispersed farm nodes, recommended possible the Bosplaas and Sub regional existing 400kV lines to Ref multiple heritage grade II and III sites Bartholomeusklip High negative severing avoid severing the farm map significances including (Baumann and Winter, homesteads which are farm nodes from one nodes and framing the 29 historical, environmental, 2009). two component parts of another; Bosplaas homestead, see social, associational and Recommended Grade II the same heritage Cumulative high negative below individual farm contextual/experiential for the four Trust farms as resource impact of additional line in assessment. Powerline significance a collective. valley can be mitigated to should cross mountain medium negative by re- range in saddle. positioning to protect this Route link to option 1a set of resources south of Elandsberg Permanent boundary F Bosplaas Farm Bosplaas and 9 bay Historic homestead, Mid corridor 480m north Local Position line south east of High 1/1/3 Bartholomjesklip/Bartholo trees, ruined Boer war west of farm node in High Negative, farm node existing 400kV lines to meusklip, together form structures after damage in direct viewshed will be framed by avoid framing the Ref part of Elandsberg Nature the 1969 Tulbagh powerlines and the farm farmstead and creating map Reserve with De Rust and earthquake (1945-4) High negative impact nodes severed unacceptably high impacts 29 Langhoogte, see above Farm incorporated into Sub regional on the immediate context reserve High negative severing (see photographs), farm nodes from one another; Exact position to be Cumulative negative determined out of impact of additional line in farmstead viewshed at valley can be mitigated by walkdown re-positioning line south of exisiting to protect this set of resources

Permanent F Bartholomiesklip Farm Large farm node on Homestead, outbuildings, Mid corridor 700m south Local Position line south east of High 2/1/3 mountain foothills, part of kraals, mature trees, treed west of farm node High negative impact by existing 440kV lines to Elandsberg Nature reserve, avenues, large dam, severing farm nodes avoid severing farm nodes Ref see above structures 10+ (1945-4) High negative Impact Sub regional from one another, map Cumulative high negative 29 impact of additional line in Exact position to be valley can be mitigated to determined out of medium negative by re- farmstead viewshed at positioning to protect this walkdown set of resources

Permanent

15 Impact Assessment: Scale (regional, sub regional, local) Measurement (High, Medium, Local) (Positive, Neutral, Negative) Duration of Impact (Permanent, Semi permanent, temporary) ______85

RS Soetendal Railway Railway siding within Railway buildings and Mid corridor 1.4km south Sub regional No mitigation required Medium High 1/1/3 station agricultural context, residences, mature trees, west of farm node Low negative Ref undulating topography structures 10+ Permanent map 29 F Menin Farm Farm node within Homestead, outbuildings, Mid corridor 2km north No impact No mitigation required Medium High 5/1/3 agricultural context, labourers housing, mature west of farm node undulating topography trees, structures 5+ Ref (1958T-8) map 29

F Burgersdrif Farm Farm node within Node adjacent to R45, Mid corridor 500m south Sub regional No mitigation required Medium High 6/1/3 agricultural context, homestead, outbuildings, east of farm node Low negative impact undulating topography mature trees, treed Ref avenue, irrigated lands Permanent map (wheat fields), demolished 29 structures, dam, structures 10+ (1963T-11)

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No. KAPPA OMEGA 2ND 765KV POWER LINE ROUTE OPTION 1 ZONE 3: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Heritage Resources Landscape typology Description Position in corridor Impact Assessment15 Mitigation of assessed Confidence of assessment negative impacts Image if applicable F Akkedisvlei Farm Former agricultural node Dam, mature trees, Mid corridor 90m south Sub regional No mitigation required Medium High 7/1/3 within agricultural context structures >5 All ruins east of farm node Low negative impact (see image at Menin farm, above) (1963T-4) Ref Permanent map 29 F Watervlei Farm Farm node within Homestead, labourers Mid corridor 2km from Sub regional No mitigation required Medium High 8/1/3 undulating typography in housing, outbuildings, farm node Low negative impact agricultural context dam, mature trees, Ref structures 5+ (1963T-7) Permanent map 29 F Vergesig Farm Farm node on hill within Homestead, outbuildings, Mid corridor 1.7km south Sub regional No mitigation required Medium High 9/1/3 undulating typography in mature trees, treed east of farm node Low negative impact agricultural context avenues, irrigated land, Ref dams, structures >10 Permanent map (1964T-2) 29 F De Rus Farm Large farm with numerous Homestead, Labourers Mid corridor 600m north Local: Position powerline south Medium High 10/1/3 nodes adjacent to R45 housing, treed avenues west of farm node Medium negative impact of farm node minimum within agricultural context, and grove, irrigated crops, 400m from farm node Ref undulating topography structures 10+ Permanent map (1963T-2) & (1963T-9) 29 F Olyvenhout Farm Small farm node within Homestead, outbuildings, Mid corridor 800m south Local: No mitigation required Medium High 11/1/3 agricultural context, Labourers housing, dam, east of farm node Medium negative (see image below) adjacent to river mature trees, structures Sub regional Ref undulating topography 10+ (1963T-6) Cumulative negative map impact 29 Permanent F Haaskraal Farm farm node within Homestead, outbuildings, Mid corridor 860m south Sub regional Position powerline south Medium High 12/1/3 agricultural context, mature trees, avenue east of farm node Cumulative negative adjacent to existing 400kV adjacent to river trees, structures 10+ impact line Ref undulating topography (1963T-10) map Permanent 29

F Fleur de lys Farm Historic farm layout of Homestead, outbuildings, Mid corridor 500m north Local Position powerline south Medium High 13/1/3 node within agricultural mature trees, avenue west of farm node Medium negative impact adjacent to existing 400kV (see image above) context, adjacent to river trees, structures <5 Sub regional line, a minimum 400m Ref undulating topography (1963T-4) Cumulative negative from farm node so that map impact farm node is not framed 29 Permanent by powerlines ______87

F Unnamed Small farm node within Labourers housing/farm Mid corridor 1.77km north Sub regional No mitigation required Medium High 18/1/3 agricultural context, structures, mature trees, west of farm node Low negative undulating topography irrigated crops, structures Permanent >5 (1963T-2) F Diemerskraal Farm Large farm node within Homestead, Labourers Mid corridor 1.75km north Sub regional No mitigation required Medium High 19/1/3 agricultural context, housing, multiple west of farm node Low negative adjacent to river and R45 outbuildings, mature Permanent undulating topography trees, irrigated crops, structures 10+ (1963T-8) F Voelgesang Farm Large farm node within homestead, Labourers Mid corridor 1.7km north Sub regional No mitigation required Medium High 20/1/3 agricultural context, housing, outbuildings, west of farm node Low negative adjacent to river and mature trees, irrigated Permanent Map secondary road, undulating crops, structures 10+ ref 29 topography (1963T-7) F Blydskap Farm Historic Farm node within Historic farm and Mid corridor 650m north Sub regional No mitigation required for Medium 21/1/3 agricultural context, homestead 1802 altered of farm node Medium negative impact farm node High Fransen 2004 undulating topography after a fire, historic Map outbuildings and werf Permanent ref 27 wall, mature trees, irrigated crops, structures 5 (1963T-5)

F Sandrivier Farm Farm node within Homestead, outbuildings, Mid corridor 800m south Sub regional No mitigation required Medium High 22/1/3 agricultural context, Labourers housing, of farm node Medium negative ______88

F Acropolis Farm Farm node within Homestead, Labourers Mid corridor 340m north Local Use alternative corridor Medium High 23/1/3 agricultural context, on housing, outbuildings west of farm node High negative Option 1a ridge, undulating structures 5+, (1963T-5) Farm framed by Map topography powerlines ref 27 Sub regional Medium negative

Permanent F Langkloof Farm Farm node within Homestead, Labourers Mid corridor 1.97km north Sub regional Use alternative corridor Medium High 24/1/3 agricultural context, housing, outbuildings, west of farm node High negative impact Option 1a undulating topography mature trees, tree avenue, Map dam, irrigated lands New corridor established ref 27 structures 5+, (1963T-5) Permanent F Fransrug Farm Dispersed farm node Homestead, Labourers Mid corridor 480m south Local Use alternative corridor, Medium High 25/1/3 within agricultural context, housing, outbuildings, of farm node High negative impact Option 1a (see below) adjacent to riverine mature trees, dam, Map corridor, undulating irrigated lands, chicken Sub regional ref 27 topography sheds structures <5, High negative (1963T-5) New corridor established Permanent

F Klein Knolfontein Farm Dispersed farm node Homestead, Labourers Mid corridor 460m north Local Use alternative corridor, Medium High 26/1/3 within agricultural context, housing, outbuildings, of farm node High negative Option 1a (see image below) adjacent to riverine mature trees, tree Map corridor, undulating avenues, dam, irrigated Sub regional ref 27 topography lands, structures <5, High negative (1963T-1) New corridor established Permanent

CL Paardeberg & Paardeberg Recommended Grade III Mid corridor traverses Local Use alternative corridor, Medium High 1/1/3 Paardeberg slopes Natural wilderness cultural landscape D-PSDF Paardeberg foothills, High negative impact Option 1a landscape setting 201317 (historical, corridor impacted includes by framing Paardeberg in Map Slopes Cultural landscape aesthetic, architectural slopes linear infrastructure ref 27 Collection of historical farm and social significances) Permanent werfs and associated rural Northern slopes of settings related to slopes Paardeberg negatively Threshold condition impacted by approved 1st between Swartland and 765kV powerline Cape Winelands 16

16 Winter & Baumann 2000 in D PSDF 2013 17 DHS 2012 in D-PSDF 2013; Annexure B page 22 ______89

F Weltevreden Farm Farm node within Homestead, outbuildings, Mid corridor 1.85km south Sub regional Use alternative corridor, Medium High 28/1/3 agricultural context, Labourers housing mature of farm homestead node High negative Option 1a adjacent to Paardeberg trees, tree avenue, dam, Map irrigated crops, structures New corridor established ref 27 5+ (1963T-5) Permanent

F Meerlust Farm Large farm node within Homestead, outbuildings, Mid corridor immediately Local Use alternative corridor, Medium High 29/1/3 agricultural context, Labourers housing mature adjacent to northern farm High negative impact Option 1a adjacent to river trees, irrigated crops, node boundary Should this option be the Map undulating topography structures 5+ (1963T-4) Sub regional EIA preferred route, ref 27 High negative impact position powerline New corridor established minimum 600m from farm node Permanent F Sonop Farm Dispersed nodes Homestead, outbuildings, Mid corridor 1.2km south Sub regional Use alternative corridor, Medium High 30/1/3 labourers housing, mature of farm node High negative impact Option 1a trees, irrigated crops, New corridor established No mitigation to farm Map damstructures 5+ (1963T- node ref 27 4)& (1963T-8) F De Hoek Farm Small linear farm node Homestead, outbuildings, Mid corridor 820m south Sub regional Not preferred corridor Medium High 31/1/3 within agricultural context, Labourers housing mature of farm node High negative Use alternative corridor, adjacent to road on trees, tree avenues, New corridor established Option 1a Map mountain foothills irrigated crops, structures Permanent ref 27 <5 (1963T-2) P Paardeberg prison Small prison within Prison, residences, Mid corridor 200m south Sub regional Not preferred corridor Medium High confidence 32/1/3 agricultural context, outbuildings, mature trees of farm node High negative Use alternative corridor, adjacent to road on and avenues, dam, Option 1a Map mountain foothills irrigated crops, structures New corridor established ref 27 <5 (1963T) Permanent

F Weltevreden Farm Farm node within Homestead, outbuildings, Mid corridor 820m south Sub regional Not preferred corridor Medium High 33/1/3 agricultural context, Labourers housing mature of farm homestead node High negative Use alternative corridor, adjacent to mountain trees, tree avenue, dam, Option 1a Map irrigated crops, structures New corridor established ref 27 5+ (1963T-5) Permanent

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F Slent/Silent Farm Large historic farm node Historic farm and Mid corridor 850m south Local PI to check visual Not preferred corridor Medium 35/1/3 with formal layout within Homestead 1868, of farm node impact Use alternative corridor, High Ref Fransen 2004:317 agricultural context, outbuildings, Labourers Option 1a Map adjacent to mountain housing mature trees, Sub regional ref 27 dam, irrigated crops, High negative structures 10+ (1963T-10) New corridor established

Permanent

F Clear Springs Farm Large farm node within Homestead, outbuildings, Mid corridor 1.1km south Sub regional Not preferred corridor Medium High 36/1/3 agricultural context, Labourers housing mature of farm node High negative Use alternative corridor, adjacent to mountain trees, irrigated crops, New corridor established Option 1a Map structures 20+ (1963T-5) Permanent ref 27 F Dun Durach Farm Large farm node within Homestead, Labourers Mid corridor 200m south Local Not preferred corridor 37/1/3 agricultural context, housing outbuildings, of farm node, separates High negative impact Use alternative corridor, adjacent to mountain chicken sheds, orchards, central structures from Sub regional Option 1a Map mature trees, irrigated one anothe High negative ref 27 crops, structures 5+ New corridor established (1963T-20+) Permanent

Medium High F Vrederus Farm Farm node within fertile Homestead, Labourers Mid corridor 900m north Sub regional Not preferred corridor Medium High 38/1/3 valley, agricultural context housing outbuildings, of farm node High negative mature trees, tree New corridor established No mitigation to farm Map avenues, dam, irrigated Permanent ref 27 crops, structures 5+ (1963T-5) F Bordeaux Farm Small farm node within Homestead, Labourers Mid corridor 1.4km north Sub regional Not preferred corridor Medium High 39/1/3 fertile valley, agricultural housing outbuildings, of farm node High negative Use alternative corridor, (see image below) context mature trees, tree New corridor established Option 1a Map avenues, dam, irrigated Permanent ref 27 crops, structures <5 ______91

F Aanhou wen Farm Small farm node within Homestead, Labourers Mid corridor 1.1km north Sub regional Not preferred corridor Medium High 41/1/3 fertile valley, agricultural housing outbuildings, of farm node High negative Use alternative corridor, (see image above) context mature trees, dam, New corridor established Option 1a Map irrigated crops, structures Permanent No mitigation to farm ref 27 <5 (1963T-4) F Toekoms Farm Small farm node within Homestead, outbuildings, Mid corridor 1.1km north Sub regional Not preferred corridor Medium High 42/1/3 fertile valley, agricultural mature trees, dam, sand of farm node High negative Use alternative corridor, context mines, structures <5 New corridor established Option 1a Map (1963T-2) Permanent No mitigation to farm ref 27 F Rusoord Farm Large farm node within Homestead, outbuildings, Mid corridor 350m north Local Not preferred corridor Medium High 43/1/3 fertile valley, agricultural mature trees, dam, of farm node. Mid corridor High impact impact Use alternative corridor, context extensive tunnel bisects tunnel Option 1a Map agriculture, structures <5 infrastructure Sub regional If route is the preferred ref 27 (1963T-2) High negative EIA route, New corridor established position line minimum Permanent 600m from farm node and tunnel infrastructure

F De Kopje Farm Small farm node within Homestead, Labourers Mid corridor 675m south Sub regional Not preferred corridor Medium High 44/1/3 agricultural context, housing outbuildings, of farm node High negative Use alternative corridor, adjacent to mountain mature trees, irrigated New corridor established Option 1a Map crops, structures <5 No mitigation to farm ref 27 (1963T-4) Permanent F Uitkyk Farm Small farm node within Homestead, Labourers Mid corridor 970m south Sub regional Not preferred corridor Medium High 45/1/3 agricultural context, housing outbuildings, of farm node High negative Use alternative corridor, adjacent to mountain mature trees, structures New corridor established Option 1a Map <5 (1963T-4) Permanent No mitigation to farm ref 27 F Grootfontein Farm Large farm node within Homestead, Labourers Mid corridor 880m south Sub regional Not preferred corridor Medium High 46/1/3 agricultural context housing outbuildings, of farm node High negative Use alternative corridor, dams, irrigated lands, New corridor established Option 1a

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F Houmoed Farm Farm node within Homestead, Labourers Mid corridor 1.9 south of Sub regional Not preferred corridor Medium High 49/1/3 agricultural context, housing outbuildings, farm node High negative Use alternative corridor, adjacent to R304 road, mature trees, dam, New corridor established Option 1a Map undulating topography irrigated crops, livestock, Permanent No mitigation to farm ref 27 structures <5 (1966T-3) required F Wolvedans Farm Formal farm node within Homestead, Labourers Mid corridor 1.1km north Sub regional Not preferred corridor Medium High 50/1/3 agricultural context, housing outbuildings, of homestead node High negative Use alternative corridor, undulating topography mature trees, tered New corridor established Option 1a avenue, dam, irrigated Permanent Map crops, livestock, structures ref 27 10+ (1966T-11) F Klein Wolwedans Historic farm node within Homestead, Labourers Mid corridor 430m north Local High negative Not preferred corridor Use 51/1/3 agricultural context, housing outbuildings, of farm node and 190m Sub regional alternative corridor, adjacent to R304 road, mature trees, tree avenue, north of labourers housing High negative Option 1a Map undulating topography irrigated crops, structures New corridor established If route is the preferred ref 27 <5 (1966T-3) Permanent EIA route, position powerline minimum 600m from farm node Medium High F Elandsvlei Small farm node within Homestead, Labourers Mid corridor 0.9km south Sub regional Not preferred corridor Use Medium High 52/1/3 agricultural context, housing outbuildings, semi of farm node High negative alternative corridor, adjacent to dam undulating demolished structure, New corridor established Option 1a Map topography mature trees, dam, Permanent ref 27 irrigated crops, structures <5 (1966T-1)

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F Bottelfontein Small farm node within Homestead, Labourers Mid corridor traverses Sub regional Not preferred corridor Medium High 54/1/3 agricultural context, housing outbuildings, centre of farm node High negative Use alternative corridor, adjacent to railway, mature trees, irrigated New corridor established Option 1a Map undulating topography crops, structures <5 Permanent If route is the preferred ref 27 (1966T-4) EIA route, position powerline minimum 600m from farm node

F Vrede Small farm node within Homestead, Labourers Mid corridor 250m north Local High negative Not preferred corridor Use Medium High 55/1/3 agricultural context, housing outbuildings, of farm node Sub regional alternative corridor, adjacent to railway, mature trees, irrigated High negative Option 1a Map undulating topography crops, chicken sheds, New corridor established If route is the preferred ref 27 structures <5 (1966T-2) Permanent EIA route, position powerline minimum 600m from farm node F Bonnie Doon Farm node within Homestead, Labourers Mid corridor 160m south Local Not preferred corridor Medium High 56/1/3 agricultural context, housing outbuildings, of farm node High negative Use alternative corridor, undulating topography mature trees, irrigated Option 1a Map crops, structures 5+ Sub regional If route is the preferred ref 27 (1966T-6) High negative EIA route, New corridor position powerline minimum 600m from farm Permanent node F Magrug Small farm node within Cottages outbuildings, Mid corridor 810m south Sub regional Not preferred corridor Use Medium High 57/1/3 agricultural context, mature trees, irrigated of farm node High negative alternative corridor, adjacent to river crops, possible vacated New corridor established Option 1a Map undulating topography buildings structures <5 Permanent No mitigation to farm ref 27 (1966T-5) node required

F Remhoogte Large farm node within Homestead, Labourers Mid corridor 1.7km south Sub regional Not prefered corridor Medium High 58/1/3 agricultural context, housing outbuildings, east of farm node High negative Use alternative corridor, adjacent to river mature trees, irrigated New corridor established Option 1a Map undulating topography crops, structures <5 Permanent No mitigation to farm ref 27 (1966T-4) node required

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F Goedontmoeting Farm Large historic farm node Historic Homestead & Mid corridor 420m north Local: Not preferred corridor, Medium High 60/1/3 within agricultural context, outbuildings, Labourers of farm node High negative impact use alternative corridor, adjacent to river, bisected housing mature trees, Sub regional Option 1a Map by Philadelphia road, livestock, irrigated crops, High negative If route is the preferred ref 27 undulating topography structures 20+ (1966T-17) New corridor established EIA route, Permanent position power line minimum 600m from farm node and off ridgeline

F Van Schoorsdrif Farm Former farm building Mature trees, irrigated Mid corridor 560m south No Impact, farm node No mitigation required Medium High 61/1/3 within agricultural context, crops, no structures <5 of farm node vacated adjacent to road, (1966T-1) Map undulating topography ref 27 F Dasvlei Farm Historic farm node within Historic homestead, Mid corridor 539m south Local Position powerlines Medium High 62/1/3 agricultural context, Labourers housing of farm node High negative minimum 400m from farm adjacent to Philadelphia outbuildings, mature Sub regional node Map road, undulating trees, tree avenues, High negative ref 27 topography irrigated crops, structures New corridor established <5 (1966T-4) Permanent

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F Steelwater Farm Small farm node within Cottages, mature trees, Mid corridor 1.4km north Sub regional Not preferred corridor Medium High 64/1/3 agricultural context, demolished structures, of farm node High negative Use alternative corridor, Map adjacent to Old vacant structures <5 New corridor established Option 1a ref 27 Malmesbury road, (1966T-1) Permanent No mitigation to farm undulating topography node required S Philadelphia Church town 1864. Provincial Heritage Sites, Mid corridor 1.8km south Sub regional Not preferred corridor High 1/1/3 Smallest laid out Church cemetery, Grade III of town’s modern High negative Use alternative corridor, town in the Cape; heritage resources residential area New corridor established Option 1a agricultural context, Permanent No mitigation to adjacent to Philadelphia settlement node required road, undulating topography

F Uitkyk Farm Farm node within Homestead, Labourers Mid corridor 360m north Local Not preferred corridor Medium High 65/1/3 agricultural context, housing outbuildings, of farm node High negative impact Use alternative corridor, undulating topography mature trees, tree Sub regional Option 1a avenues, irrigated crops, High negative If route is the preferred dam, structures 5+ New corridor EIA route, (1965T-2) Permanent position powerline minumum 600m from farm node F De Hoop Farm Small farm node within Asymmetrical T shaped Mid corridor 1.4km north Sub regional Not prefered corridor Use Medium High 66/1/3 agricultural context, Homestead c 1833 of farm node High negative alternative corridor, Ref Fransen 2004:318 undulating topography victoriansied, Labourers New corridor Option 1a housing outbuildings, No mitigation to farm dam, mature trees, Permanent node required irrigated crops, structures <5 (1966T-3)

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Table 6.4 Impact Assessment Route Option 1A Zone 3

No. KAPPA OMEGA 2ND 765KV POWER LINE ROUTE OPTION 1A ZONE 3: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Two existing 400kV lines perpendicular to proposed corridor Heritage Resources Landscape typology Description Position in corridor Impact assessment18 Mitigation of assessed Confidence of assessment negative impacts Image if applicable F Vredenhof Farm Formal farm node in Homestead, outbuildings, Mid corridor 500m north Sub regional Recommended Option Medium High 1/1A/3 context of riverine Labourers housing, mature of farm node medium cumulative Position line minimum corridor undulating trees, dam, structures 10+, impact of additional 400m from farm node Ref topography, high irrigated crops (1963T-8) powerlines in corridor Position to be determined Map agricultural use at walk down 29

F Eikenboom Farm Two farm nodes Homestead, outbuildings, Mid corridor m 300m Local Recommended Option Medium High 2/1A/3 adjacent to R45 on Labourers housing, mature north of farm node Negative high impact Position line minimum riverine corridor trees, dams, structures Sub regional 400m from farm node Ref undulating topography, 10+ , irrigated crops, medium cumulative Position to be determined Map high agricultural use livestock (1963T-11) impact of additional at walk down 29 powerlines in corridor F Onwego Farm Two farm nodes Homestead, outbuildings, Mid corridor 900m south Sub regional No mitigation required Medium High 3/1A/3 adjacent to river Labourers housing, mature of farm node medium cumulative undulating topography, trees, dams, structures impact of additional Sub regional medium Ref high agricultural context >10, irrigated crops(1963T- powerlines in corridor context Map 2) 29 F Koorlands-drif Farm Farm node adjacent to Homestead, outbuildings, Mid corridor 400m north Local Recommended Option Medium High 4/1A/3 river undulating mature trees, dams, of farm homestead Negative high impact Position line minimum topography, high structures 10+, irrigated Sub regional 400m from farm node Ref agricultural context crops(1963T-13) medium cumulative Position to be determined Map impact of additional at walk down 29 powerlines in corridor F Vlakken-heuwel Farm Large linear farm node Homestead, outbuildings, Mid corridor 180m south Local Recommended Option Medium High 5/1A/3 undulating topography, mature trees, treed of farm node high negative impact Position line minimum high agricultural context avenue, dam, structures Sub regional 400m from farm node Ref 10+, irrigated crops Add 1st 765kV medium cumulative Position to be determined Map (1963T-7) impact of additional at walk down 29 + powerlines in corridor 27 F Jonkershoek Farm Farm node undulating Homestead, outbuildings, Mid corridor 1.8km south Sub regional No mitigation required Medium High

18 Impact Assessment: Scale (regional, sub regional, local) Measurement (High, Medium, Local) (Positive, Neutral, Negative) Duration of Impact (Permanent, Semi permanent, temporary) ______97

No. KAPPA OMEGA 2ND 765KV POWER LINE ROUTE OPTION 1A ZONE 3: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Two existing 400kV lines perpendicular to proposed corridor Heritage Resources Landscape typology Description Position in corridor Impact assessment18 Mitigation of assessed Confidence of assessment negative impacts Image if applicable 5/1A/4 topography, high mature trees, treed of farm node medium cumulative agricultural context avenue, dam, structures impact of additional Ref 10+, irrigated crops Add 1st 765kV powerlines in corridor Map (1963T-3) 29 + 27

Table 6.5 Impact Assessment Route Option 2 Zone 3 Route option 2, from the point at which it joins route option 1a and proceeds southwest to Omega is being assessed. The reason for this is that both option 1 and 1b have high negative impacts on Heritage resources, in addition to the proposed lines constituting first bulk infrastructural interventions into those landscapes. Option 2 south of Riebeek Kasteel has an already approved 765kV line, and the cumulative impacts are compared to the high negative impacts of creating new corridors.

Figure 33 (right): portion of map 29 showing the point at which route option 2 assessment begins in relation to contextual topography (MetroGIS2013)

F Dassenheuwel Farm Large farm node on Homestead, outbuildings, Mid corridor traverses farm Local Position line minimum Medium 2/2/3 small riverine corridor, Labourers housing, mature node High negative impact 400m from farm node High undulating topography, trees, structures 10+, Sub regional Position to be determined Map high agricultural context irrigated crops (1963T-3) medium cumulative at walk down 27 impact of additional powerlines in corridor

19 Impact Assessment: Scale (regional, sub regional, local) Measurement (High, Medium, Local) (Positive, Neutral, Negative) Duration of Impact (Permanent, Semi permanent, temporary) ______98

F Grasrug Farm Two small farm nodes Homestead, outbuildings, Mid corridor 1.5km south Sub regional No mitigation required Medium High 4/2/3 within undulating mature trees, structures west of farm node medium cumulative topography, high <5, irrigated crops (1963T- impact of additional Map agricultural context 4) & (1963T-1) powerlines in corridor 27 Permanent

F Tweekluil Farm Large farm node on Homestead, Labourers Mid corridor traverses farm Local Position line south of farm Medium High 5/2/3 riverine corridor within housing, outbuildings, node Negative high impact node minimum 400m from undulating topography, treed avenues, mature Sub regional farm node Map high agricultural context trees, structures 10+, medium cumulative Position to be determined 27 dams, irrigated crops impact of additional at walk down (1963T-4) powerlines in corridor Permanent

F De Vlei Farm Small farm node on Homestead, outbuildings, Mid corridor 1.5km south Sub regional No mitigation required Medium high 6/2/3 riverine corridor within treed avenue, mature west of farm node medium cumulative undulating topography, trees, structures >5, dam, impact of additional Map high agricultural context irrigated crops (1963T-4) powerlines in corridor 27 Permanent F De Grendel Farm Farm node on hill top Homestead, Labourers Mid corridor 1.95km south Sub regional No mitigation required Medium High 7/2/3 within undulating housing, outbuildings, west of farm node Neutral topography, high mature trees, structures Map agricultural context 5+, irrigated crops (1963T- Permanent 27 4)

F Annandale Farm Farm node on riverine Homestead, Labourers Mid corridor traverses edge Local Position line south of farm Medium High 8/2/3 corridor within housing, outbuildings, of farm node Negative high impact node minimum 400m from undulating topography, treed avenues, mature Sub regional farm node Map high agricultural context trees, structures 10+, medium cumulative ______99

SR Scenic route R45 Recommended linking Local No mitigation Medium High 1/2/3 scenic route (SDF), Grade Negative high impact III (D-PSDF 2013) Sub regional Map Medium cumulative 27 impact of additional powerlines in corridor

F Nuwerus Farm Small dispersed farm Homestead, Labourers Mid corridor 1.4km north Sub regional No mitigation required Medium High 9/2/3 nodes within undulating housing, outbuildings, west of farm node neutral topography, high treed avenues, mature Map agricultural context trees, structures 10+, dam, 27 irrigated crops (1963T-5) & (1963T-7) F Unnamed Small dispersed farm Homestead, , mature Mid corridor 800m south Sub regional cumulative No mitigation required Medium High 10/2/3 node on riverine corridor trees, structures <5, east of farm node Medium negetaive within undulating irrigated crops (1963T-2) Permanent Map topography, high 27 agricultural context F Slot Farm Farm node within Homestead, Labourers Mid corridor 500m north of Local Slot already highly Medium High confidence 11/2/3 undulating topography, housing, outbuildings, farm node Medium negative impact impacted by 1st 765kV line high agricultural context mature trees, structures Sub regional Recommend 2nd 765kV Map <5, dam, irrigated crops medium cumulative line positioned south of 27 (1963T-13 impact of additional farm node adjacent to 1st powerlines in corridor 765kV line so that Slot is not framed by powerlines Permanent Walk down required

F Eendrag Farm Small farm node on Homestead, Labourers Mid corridor 400m north of Local Eendrag node already Medium High 12/2/3 riverine corridor within housing, outbuildings, farm node high negative impact highly impacted by 1st undulating topography, mature trees, structures Sub regional 765kV line Map high agricultural context <5, dam, irrigated crops medium cumulative Recommend 2nd 765kV line 27 (1963T-2) impact of additional positioned south adjacent powerlines in corridor to approved 1st 765kV line so that Eendrag node is Permanent not framed by powerlines ______100

F Doorenfontein Farm Two farm nodes on Homesteads, labourers’ Mid corridor 1.8km north of Sub regional No mitigation required Medium High 18/2/3 hilltop within undulating cottages, outbuildings, farm node medium cumulative topography, high tree avenues and grove, impact of additional Map agricultural context dairy, quarry, structures powerlines in corridor 27 10+, dam, irrigated crops (1963T-12) & (1965T-4) Permanent F Middelpos Farm Farm node within Homestead, Labourers Mid corridor 500m north of Local Farm node already highly 19/2/3 undulating topography, housing, outbuildings, farm node Medium negative impact impacted by approved 1st high agricultural context mature trees, tree avenue, Sub regional 765kV line Map structures <5, irrigated medium cumulative 27 crops (1965T-2) impact of additional No mitigation powerlines in corridor Permanent Medium High

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F Kersfontein Farm Farm node within Homestead, Labourers Mid corridor 700m west of Sub regional Farm node already Medium High 23/2/3 undulating topography, housing, outbuildings, farm node medium cumulative impacted by approved 1st high agricultural context mature trees, dams, impact of additional 765kV line Map structures 5+, irrigated powerlines in corridor 27 crops (1965T-4) Permanent No mitigation to farm node SR Kalbaskraal Scenic route Recommended scenic Local No mitigation required Medium High 1/2/3 route (2012 SDF) medium negative impact Route already impacted Map by approved 1st 765kV 27 line

S Kalbaskraal historic town settlement Low density settlement Mid corridor 1.3km east of Sub regional No mitigation required; Medium High 1/2/3 late 19th c developed bisected by Old urban edge and 1.6km from medium cumulative town context already Google Earth 201 around railway junction Malmesbury road, historic core impact of additional impacted by approved 1st and station, within residential areas, railway powerlines in corridor 765kV line agricultural context station, Cemetery Permanent proposed (SDF 2012), Quarry,

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4 F Weltevrede Farm Small farm node within Homestead, Labourers Mid corridor 1.2km north Sub regional No mitigation required Medium High 24/2/3 undulating topography, housing, outbuildings, west of farm node medium cumulative high agricultural context mature trees, tree avenue, impact of additional Map in close proximity to structures 10+ (certain powerlines in corridor 27 Kalbaskraal demolished), dams, Permanent irrigated crops (1965T-5) O Uitspan Farm Node adjacent to Collection of buildings, Mid corridor 680m south of Local No mitigation required Medium High 1/2/3 Kalbaskraal town within mature trees, tree avenue, rural node Medium negative Node already impacted by undulating topography, structures <5, irrigated Sub regional approved 1st 765kV line Map high agricultural context, crops in context (1965T-4) medium cumulative 27 former outspan impact of additional powerlines in corridor Permanent F Kalbaskraal Farm Small farm node within Homestead (modern), Mid corridor 1.3km north Sub regional No mitigation required Medium High 25/2/3 undulating topography, Labourers housing, west of farm node medium cumulative Ref Fransen 2004:321 high agricultural context historic outbuildings, impact of additional Map mature trees & grove, powerlines in corridor 27 dam, structures <5, Permanent irrigated crops (1965T-7)

F Populierbos Farm Farm node within Homestead, Labourers Mid corridor 350m south of Local Position line on south of Medium High 26/2/3 (incorporating res) undulating topography, housing, outbuildings, farm node High negative impact and adjacent to 1st 765kV high agricultural context mature trees, tree avenue, Sub regional line Map structures <5, irrigated medium cumulative 27 crops (1965T-3)(1965T-1) impact of additional powerlines in corridor Permanent

F Berg en Dalen Farm Large farm node Homestead, Labourers Mid corridor 1.3km north of Sub regional No mitigation required Medium High 27/2/3 bisected by Old housing, outbuildings, farm node medium cumulative Malmesbury road, on mature trees, tree avenue, impact of additional Map riverine corridor, within livestock, structures 10+, powerlines in corridor 27 undulating topography, irrigated crops (1965T-7) high agricultural context Permanent ______103

No. KAPPA OMEGA 2ND 765KV POWER LINE ROUTE PORTION OPTION 2 ZONE 3: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Undulating topography, high use irrigated agriculture, 1st 765kV line within corridor SE of mid line Heritage Resources Landscape typology Description Position in corridor Impact assessment19 Mitigation of assessed Confidence of assessment negative impacts Image if applicable F Goedgedacht Farm Farm node on riverine Homestead, Labourers Mid corridor 1.45km south Sub regional No mitigation required Medium High 28/2/3 corridor within housing, outbuildings, of farm node medium cumulative undulating topography, mature trees, tree avenue, impact of additional Map high agricultural context structures 10+, irrigated powerlines in corridor 27 crops (1965T-6) Permanent F Res Farm node adjacent to Homestead, Labourers Mid corridor 1.65km south Sub regional No mitigation required Medium High 29/2/3 N7, medium agricultural housing, outbuildings, of farm node medium cumulative context mature trees, tree avenue, impact of additional Map 1 structures <5, irrigated powerlines in corridor crops in context (1965T-1) Permanent F Klipvlei Farm Formal farm node within Outbuildings, mature Mid corridor 1.4km south of Sub regional No mitigation required Medium High 30/2/3 high agricultural use trees, structures <5, farm node medium cumulative Ref context irrigated crops (1965T-4) impact of additional Map 1 powerlines in corridor Permanent SR Scenic route N7 Major route between Important linkling route20 Mid corridor traverses Local No mitigation required Medium High /2/3 Cape Town, West Coast roadway High negative impact and Namibia Scenic route identified in Sub regional cumulative Map Klein Dassenberg SH21 negative impact 27 & 1 Sub regional medium cumulative F Rondeberg Farm Formal farm layout Provincial heritage site Mid corridor 200km south Local Position line south of and Medium High 31/2/3 within undulating Simple linear werf pattern of farm node High negative impact adjacent to approved 1st topography adjacent to in gum tree setting. Sub regional 765kV Map N7 road, medium Thatched cottage with medium cumulative 27 & 1 agricultural context surviving mid 19thC front impact of additional door, fanlight & powerlines in corridor fenestration. Front stoep Permanent with suspect 20th C werf wall. Corrugated iron roofed barn, mature trees, tree avenue, structures 5+, Google Earth 2014 irrigated crops (1965T- 8)Of intrinsic architectural/aesthetic & historical significance (ARCON 2010)

F Schoongezicht Farm Farm node within Homestead, Labourers Mid corridor 800m west of Sub regional No mitigation required Medium High 32/2/3 undulating topography, housing, outbuildings, farm node medium cumulative adjacent to N7 road, on demolition of structures, impact of additional Ref hilltop, high agricultural mature trees, tree avenue, powerlines in corridor Map 1 context structures 10+, irrigated Permanent

20 D-PSDF 2013: Annexure B page 16 21 2012 BDP ______104

No. KAPPA OMEGA 2ND 765KV POWER LINE ROUTE PORTION OPTION 2 ZONE 3: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Undulating topography, high use irrigated agriculture, 1st 765kV line within corridor SE of mid line Heritage Resources Landscape typology Description Position in corridor Impact assessment19 Mitigation of assessed Confidence of assessment negative impacts Image if applicable crops, horses, (1965T-5) Will be impacted by 1st 765kV Permanent F Tierhoogte Farm Large farm formal node Labourers housing, Mid corridor 1.9km west of Sub regional No mitigation required Medium High 33/2/3 adjacent to N7 Roadway outbuildings, mature farm node medium cumulative within undulating trees, tree avenues (entry impact of additional Ref topography, high + roadway), dam, powerlines in corridor Map 1 agricultural context structures 10+, irrigated Permanent crops (1965T-6) F Boterberg Farm Farm node adjacent to Homestead, Labourers Mid corridor 1.6km north Sub regional No mitigation required Medium High 34/2/3 N7 roadway on housing, outbuildings, west of farm node medium cumulative Philadelphia road, within graves, mature trees, tree impact of additional Ref undulating topography, avenue, kraals, dam, powerlines in corridor Map 1 high agricultural context, structures <5, irrigated Permanent 1.5km to Philadelphia crops in context (1965T-4) F Botterberg General area PHS list from HWC – Unknown Medium High 35/2/3 general area listed without boundaries, map or status Ref Map 1 F Klipvlei Farm Farm node adjacent to Labourers housing, Mid corridor 1.2km north Sub regional No mitigation required Medium High 36/2/3 N7 road, on coastal outbuildings, mature west of farm node medium cumulative Check repeat plain, medium trees, structures <5, impact of additional Ref agricultural context, irrigated crops in context powerlines in corridor Map 1 petrol station between (1965T-5) Permanent node and road F Unnamed Farm node on riverine Homestead, Labourers Mid corridor 600m south Local medium cumulative Already impacted by Medium High 37/2/3 corridor, medium housing, outbuildings, east of farm node impact approved 1st 765kV line agricultural context mature tree grove, Sub regional medium Ref structures <5, irrigated impact medium Map 1 crops in context (1965T-4) Permanent F Mesech Farm Farm node adjacent to Homestead, Labourers Option 2 Mid corridor Sub regional No mitigation required Medium High 38/2/3 N7 roadway, within housing, outbuildings, 1.5km north west of farm medium cumulative Add both distances undulating topography, mature tree grove, node impact of additional Ref high agricultural context, structures <5, irrigated Option 1 mid corridor powerlines in corridor Map 1 on minor riverine crops in context (1965T-4) 1.4km from farm node Permanent corridor F Die Anker Farm Large farm node Homestead, Labourers Mid corridor 900m south Sub regional No mitigation required Medium High 39/2/3 adjacent to R304 housing, outbuildings, east of farm node medium cumulative roadway, within livestock, mature tree impact of additional Ref undulating topography, grove, structures 10+, powerlines in corridor Map 1 medium agricultural (1965T-4) Permanent context F Witdam Farm Farm node adjacent to Homestead, Labourers Mid corridor 600m north Local Already impacted by Medium High 40/2/3 R304 roadway, within housing, outbuildings, west of farm node Omega Cumulative high approved 1st 765kV line undulating topography, mature trees, structures substation 1km south west impacted ______105

Table 6.6 Impact Assessment Route Option 1b Zone 3 No KAPPA OMEGA 2ND 765KV POWER LINE ROUTE PORTION OPTION 1B ZONE 3: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Undulating topography, high use irrigated agriculture, no large infrastructure within corridor Heritage Resources Landscape typology Description (farm name Impact assessment22 Mitigation of assessed Confidence of assessment and descript. Position in Position in corridor negative impacts Image if appliacable corridor) CL Paardeberg & Paardeberg Recommended Grade III 1km from Paardeberg Local Use alternative corridor, Medium High 1/1/3 Paardeberg slopes Natural wilderness cultural landscape D-PSDF foothills, corridor High negative impact Option 1a landscape setting 201324 (historical, impacted includes slopes by framing Paardeberg in Map ref Slopes Cultural landscape aesthetic, architectural and linear infrastructure 27 Collection of historical social significances) farm werfs and Northern slopes of Permanent associated rural settings Paardeberg negatively related to slopes impacted by approved 1st Threshold condition 765kV powerline between Swartland and Cape Winelands 23 F Ongegund Farm Farm node within Homestead, labourers Mid corridor 1.02km Sub regional Corridor not High 1/1B/3 undulating topography, housing, outbuildings, west of farm node high negative impact recommended. high agricultural context, mature trees, structures establishment of new Use alternative corridor, Ref on ridge <5, irrigated crops in Permanent corridor Option 1a Map 27 context (1965T-4) If route is the preferred EIA route, position powerline minimum 600m from farm node F Diemerskraal Farm Farm node within Homestead, labourers Option 1B Mid corridor Sub regional Corridor not High 2/1B/3 undulating topography, housing, outbuildings, 250m south west of farm high negative impact recommended. high agricultural context, mature trees, structures node establishment of new Use alternative corridor, Ref adjacent to river 5+, irrigated crops in Option 1 mid corridor corridor Option 1a Map 27 context (1965T-8) south east 1.75km If route is the preferred Permanent EIA route, position powerline minimum 600m from farm

22 Impact Assessment : Scale (regional, sub regional, local) Measurement (High, Medium, Local) (Positive, Neutral, Negative) Duration of Impact (Permanent, Semi permanent, temporary) 23 Winter & Baumann 2000 in D PSDF 2013 24 DHS 2012 in D-PSDF 2013; Annexure B page 22

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No KAPPA OMEGA 2ND 765KV POWER LINE ROUTE PORTION OPTION 1B ZONE 3: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Undulating topography, high use irrigated agriculture, no large infrastructure within corridor node F Welgegund Farm Small farm node within Homestead, labourers Mid corridor 980m west Sub regional Corridor not High 3/1B/3 undulating topography, housing, outbuildings, of farm node high negative impact: recommended. adjacent to riverine mature trees, structures establishment of new Use alternative corridor, Ref corridor, high agricultural 5+, irrigated crops in Permanent corridor Option 1a Map 27 context context (1965T-4) F Botriviervlei Farm Farm node within Homestead, labourers Mid corridor 800m north Sub regional Corridor not High 4/1B/3 undulating topography, housing, outbuildings, east of farm node High negative impact recommended. high agricultural context, mature trees, tree avenue establishment of new Use alternative corridor, Ref adjacent to river and structures 5+, irrigated corridor Option 1a Map 27 road (R45) crops in context (1965T-8) Permanent F Soutpan Farm Farm node within Homestead, labourers Mid corridor 760m south Sub regional Corridor not High 5/1B/3 undulating topography, housing, outbuildings, west of farm node High negative impact: recommended. high agricultural context, mature trees, structures establishment of new Use alternative corridor, Ref on riverine corridor <5, irrigated crops in corridor Option 1a Map 27 context (1965T-3) Permanent If route is the preferred EIA route, position powerline minimum 600m from farm node F Gras en Dalen Farm Small liner farm node Homestead, outbuildings, Mid corridor 870m north Sub regional Corridor not High 6/1B/3 within undulating mature trees, structures east of farm node High negative impact: recommended. topography, high <5, irrigated crops in 1.9km establishment of new Use alternative corridor, Ref agricultural context context (1965T-4) corridor Option 1a Map 27 Permanent If route is the preferred EIA route, position powerline minimum 600m from farm node F La Rhine Farm Large farm with two Homestead, labourers Mid corridor 1.6km north Sub regional Corridor not High 7/1B/3 nodes within undulating housing, outbuildings, east of farm node High negative impact: recommended. topography, high mature trees, structures establishment of new Use alternative corridor, Ref agricultural context, 10+, irrigated crops in Permanent corridor Option 1a Map 27 adjacent to river context (1963T-7) & If route is the preferred (1963T-9) EIA route, position powerline minimum 600m from farm node F Goetverwagting Farm Farm nodes within Homestead, labourers Mid corridor 1.9km north Sub regional Corridor not High 8/1B/3 undulating topography, housing, outbuildings, east of farm node High negative impact: recommended. high agricultural context, mature trees, structures establishment of new Use alternative corridor, Ref adjacent to river <5, irrigated crops in Permanent corridor Option 1a Map 27 context (1965T-4) If route is the preferred EIA route, position powerline minimum 600m from farm node

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No KAPPA OMEGA 2ND 765KV POWER LINE ROUTE PORTION OPTION 1B ZONE 3: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Undulating topography, high use irrigated agriculture, no large infrastructure within corridor F Boesmansrivier Farm Large farm node within Homestead, labourers Mid corridor immediately Local Corridor not recomended. High 9/1B/3 undulating topography, housing, outbuildings, adjacent to labourers High negative Impact Use alternative corridor, high agricultural context, mature trees, structures housing Option 1a Ref on ridge 10+, livestock, irrigated Sub regional If route is the preferred Map 27 crops in context (1963T-17) Permanent High negative impact: EIA route, establishment of new position powerline corridor minumum 600m from farm node F Kanolfontein Farm Small farm node within Residence, outbuilding, Mid corridor 870m north Sub regional Corridor not High 10/1B/3 undulating topography, mature trees, dams, east of farm node High negative impact: recommended. high agricultural context, structures <5, irrigated establishment of new Use alternative corridor, Ref adjacent to river crops in context Permanent corridor Option 1a Map 27 (1963T-3) If route is the preferred EIA route, position powerline minimum 600m from farm node F Rhenosterbosrug Farm Farm node within Homestead, labourers Mid corridor traverses Local Corridor not High 11/1B/3 undulating topography, housing, outbuildings, farm node High negative impact recommended. high agricultural context, mature trees, dams, Sub regional Use alternative corridor, Ref adjacent to river livestock, structures 10+, Permanent High negative impact: Option 1a Map 27 irrigated crops in context establishment of new If route is the preferred (1963T-10) corridor EIA route, position powerline minimum 600m from farm node F Twee Kuil Farm Farm node within Homestead, labourers Mid corridor 1.35km Sub regional Corridor not High 12/1B/3 undulating topography, housing, outbuildings, south west of farm node High negative impact: recommended. high agricultural context mature trees, structures establishment of new Use alternative corridor, Ref 5+, dam, irrigated crops in Permanent corridor Option 1a Map 27 context (1963T-7) If route is the preferred EIA route, position powerline minimum 600m from farm node F Welgelegen Farm Farm node within Homestead, labourers Mid corridor 1.85km Sub regional Corridor not 13/1B/3 undulating topography, housing, outbuildings, north east of farm node High negative impact: recommended. high agricultural context mature trees, structures establishment of new Use alternative corridor, Ref <5, dam, irrigated crops in Permanent corridor Option 1a Map 27 context (1963T-7) If route is the preferred EIA route, position powerline minimum 600m from farm node F Ribbokam Farm Farm with two nodes Homestead, labourers Mid corridor 1.5km north Sub regional Corridor not High 14/1B/3 within undulating housing, outbuildings, east of farm node High negative impact: recommended. topography, high mature trees, structures establishment of new Use alternative corridor, Ref agricultural context 5+, irrigated crops in Permanent corridor Option 1a ______108

No KAPPA OMEGA 2ND 765KV POWER LINE ROUTE PORTION OPTION 1B ZONE 3: BUILT ENVIRONMENT AND CULTURAL LANDSCAPE RESOURCES Undulating topography, high use irrigated agriculture, no large infrastructure within corridor Map 27 context (1963T-7) If route is the preferred EIA route, position powerline minimum 600m from farm node

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6.5 SUMMARY OF IMPACT ASSESSMENT Impacts of the proposals on cultural landscapes, settlements, and individual resources have been assessed in relation to the established heritage indicators as follows:

 Avoid sensitive distinct character landscapes;  Choose disturbed areas over wilderness areas;  Choose areas with a high visual absorption capacity;  Consider how the powerlines traverse significant scenic routes. The following therefore applies -  Position new infrastructure in existing infrastructure corridors where possible. Heritage Indicators at local and micro scales apply to mitigate negative impacts along the preferred route.

Route options 2 (excluding the lower portion) and 3 have high impacts on regional and sub- regional scales:

1. distinct landscapes that are large scale and representative of regional characteristics (heritage indicator 1), 2. on Intact, undisturbed areas of high wilderness qualities and scenic values (heritage indicator 2), 3. on areas of low visual absorption, such as vast open spaces without mountain backdrops where settlement is dispersed (heritage indicator 3), 4. on concentrations of heritage resources (built environment and /or cultural landscapes) (heritage indicator 4), 5. on dominant vistas and views of historic towns and their primary access routes (heritage indicator 5), 6. on scenic routes (heritage indicator 6).

As a result route options 2 and 3 were excluded from Assessment, except for route option 2 where it coincides with route option 1a (see image below).

Figure 34: Diagram depicting portion of route option 2 which coincides with route 1a, studied at impact assessment phase. Route 1b

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Route Option 1

Route option 1, zone 1 (from Gamma to immediately east of Karoopoort) travels alongside of existing bulk infrastructure. High local impact on Inverdoorn, mitigation measures suggested in Table 6.1.

Route option 1, zone 2 (from Karoopoort to the west edge of the mountainous zone) Mitigation measures to prevent the framing of Karoopoort PHS, to prevent the proposed line from riding a ridgeline, and to keep powerlines within the existing corridor. Mitigation measures recommended along the remainder of this section of route minimise negative impacts by keeping powerlines in existing corridors, minimising impacts on scenic routes, mountains and farmsteads.

Heritage Resources impacted in this section of the route are:

Karoopoort Outspan, single farmsteads across the Ceres and Witzenberg Valleys, private nature reserves on the mountain crossings, and a provincial nature reserve crossing the Hawequas. Mitigation measures are recommended in Table 6.2. The connection between route 1 and route 1a will require specific attention and study on site.

Route option 1 in zone 3

Mitigation measures are recommended to reduce negative impacts on Nature reserves, recommended Provincial heritage sites, farmsteads, the Paardeberg slopes, and Philadelphia in Table 6.3.

Mitigation measures around Elandsberg nature reserve (4 registered farms owned and worked in unison) prevent the severing of the farm nodes from one another, keep powerlines in existing corridors and ensure their placement in areas with higher visual absorption capacity and out of direct viewsheds of significant heritage resources. This mitigates the high negative cumulative impact of an additional powerline on a recommended Provincial Heritage site. Route option 1 in the southern area below route option 1b will generate a new bulk infrastructure corridor with unacceptably high negative impacts on the Paardeberg slopes and the following significant historical farmsteads: Schoone Oordt, Staart van de Paardeberg, Blydschap, Slent/Silent, Uitkyk, and de Hoop among others. Table 6.3 details the assessed impacts on single and settlement resources.

The cumulative impacts on the regionally characteristic and distinctive landscapes are lower than the impacts of inserting new bulk infrastructure into untouched cultural landscapes.

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Route option 1a in zone 3

Three farmsteads (Eikenboom, Koorlansdrift, Vlakenheuwel) and portion of the Elandsberg farms (Langhoogte) will be severely negatively impacted at local scale. Mitigation measures to minimize negative impacts of the powerline Route 1b location to be determined at walkdown.

Figure 35: Connection between recommended routes that will require specific and close attention to avoid negative impacts on Heritage Resources

The connection between route 1 and route 1a will require specific attention and study on site to avoid unacceptably high impacts on the Bartholomeusklip, Bosplaas, Langhoote and de Rust farm nodes, which form Elandsberg Nature reserve.

The remainder of route option 1a provides the possibility of lower negative impact than other proposed options. Two existing powerlines (perpendicular to the proposed 1a), in addition to roadways and a railway line exist in the proposed 1a corridor. It is, in addition the shortest and lowest impact option to connect to route option 1 to route option 2.

Route option 1b in zone 3

Route option 1b will create a framing effect on the Paardeberg slopes. In order to avoid the sub-regional impact on this significant cultural landscape, use of an alternate option is recommended.

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SECTION 7 RECOMMENDATIONS

The specialist spatial history, cultural landscape and built environment assessments of the proposed 2nd 765kV power lines form kappa to Omega sub stations recommend:

1. Adoption of the report’s heritage indicators in the assessment of the proposed 2nd 765kV power lines; 2. Option Route 2 (north and east route option 1a) assessed as undesirable due to the unacceptably high negative impacts on heritage resources and cultural landscapes, including on iconic landscapes, by the establishment of a new powerline corridor; 3. Option Route 3 assessed as undesirable due to the unacceptably high negative impacts on heritage resources and cultural landscapes, including on iconic landscapes by the establishment of a new powerline corridor. 4. Acceptance of Option Route 1, 1a and 2, south of Riebeek Kasteel and the R46 Scenic Route, as the preferred route due to the lower impact on settlements and landscapes. The presence of existing 400kV and approved first 765kV power lines have already impacted the landscape and farm settlements along the greater distance of route option 1. 5. Adoptions of mitigation measures for options 1, 1a and 2 where it intersects with option 1a, contained in the Tables 6.1- 6.6.

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SECTION 8 BIBLIOGRAPHY OF SOURCES

Adhikari M. (2010). The Anatomy of a South African Genocide. Cape Town: UCT Press. ARCON Architects and Heritage Consultants (2011). Kappa Omega Transmission Line Heritage Impact Assessment Phase 2 Prepared for Professional Grave Solutions On behalf of the Nature Conservation Corporation For ESKOM Transmission

Athiros, G. (nd) Route 27 West Coast South Africa: The Hildebrand Monument: Anglo-Boer War 1899- 1902. Accessed on 27 May 2013 at: http://www.route27sa.com/hildebrand.html Baumann, N & Winter, S. in association with Clift, H. 2009. Heritage Scoping Study of Proposed Gamma-Omega Transmission Power line; Specialist Built Environment and Landscape Study. Unpublished report for Cape Archaeological Survey on behalf of ESKOM Transmission. Bulpin, T.V. (1980). Discovering Southern Africa (2nd edition). TV Bulpin Publishers: Cape Town. Burman, J. (1984). Early Railways at the Cape. Cape Town: Human & Rousseau. Clift, H. (2008). Appendix accessed on 10 May 2013 at: http://www.eskom.co.za/content/APPENDIX%205%20Historical%20chronology%20HC%20Correction s~1.pdf Cross, C. and Hornby, D. (2002). Obstacles to Women’s Land Access in South Africa. A Research Report for the Promoting Women’s Access to Land Programme. Accessed on 20 June 2013 at: http://www.info.gov.za/otherdocs/2002/landgender.pdf Darling, Western Cape (nd). Accesses on 22 May 2013 at: http://en.wikipedia.org/wiki/Darling,_Western_Cape Du Plessis, K. and Cowling, V. (2006). West Coast: Cederberg to the Sea. Cape Town: Struik. Elphick, R. and Giliomee, H. editors (1989). The Shaping of South African Society 1652-1840. (2nd ed) Cape Town: Maskew Miller Longman. Elphick, R. and Malherbe, C. (1989). The Khoisan to 1828. In The Shaping of South African Society 1652-1840. (2nd ed) Cape Town: Maskew Miller Longman. Fransen, H. (2004). The Old Buildings of the Cape. Johannesburg: Jonathan Ball. Fransen, H. (2006). Old Towns and Villages in the Cape. Johannesburg: Jonathan Ball. Freund, W.B. (1989). The Cape under transitional governments, 1795-1814. In: Elphick, R. and Giliomee, H. editors (1989). The Shaping of South African Society 1652-1840. (2nd ed) Cape Town: Maskew Miller Longman. Google Maps. (2013). Accessed on 13 June 2013 at: Heritage Western Cape, A Short Guide to Grading Version 5, 2007 ICOMOS, Charter for the Conservation of Historic Towns and Urban Areas (Washington Charter 1987) ICOMOS, Guidance on Heritage Impact Assessments for Cultural World Heritage Properties Draft May 2010 Inskeep, R.R. (1978). The Peopling of Southern Africa. Cape Town: David Philip. James, W.G. and Simons, M. editors (1989). The Angry Divide. Cape Town: David Philip. Inskeep, R.R. (1978). The Peopling of Southern Africa. Cape Town: David Philip. Malmesbury Tourism Bureau (nd). Malmesbury Historic Route. Accessed on 22 May 2013 at: http://www.malmesburytourism.co.za/malmesbury-history.htm ______110

Mangin, G. and Lloyd, S. (1998). The Special Signal Services (Sss): We scanned the seas and skies in the Second World War. Military History Journal Vol 11 No 2 - December 1998.

Marquis-Kyle, P and Walker, M: Australia ICOMOS: The Illustrated Burra Charter: making good decisions about the care of important places, Australia ICOMOS 1992 Mossop, E.E. (1927). Old Cape Highways. Cape Town: Maskew Miller. Mostert, L. (2011). History Textbook Workbook Grade 10 NCAPS. Cape Town: Allcopy Publishers. Accessed on 20 June 2013 at: intranet.parklands.co.za/?dl_id=2 National Heritage Resources Act, No 25 of 1999 Orton, J. (2004). Heritage Scoping Study of the Farm Groot Oliphantskop (Farm 81) for the Proposed Omega Substation, Western Cape. Prepared for Eyethu Engineers. South Africa. Archaeology, Contracts Office, University of Cape Town. Orton, J. (2010) Heritage Impact Assessment for the Proposed Zen Wind Energy Facility, Tulbagh Magisterial District, Western Cape. Prepared for Savannah Environmental. South Africa. Archaeology, Contracts Office, University of Cape Town. Orton, J. (2010). Heritage Impact Assessment for the Proposed Expansion of the N7 between the Melkbos and Atlantis Junctions, Malmesbury Magisterial District, Western Cape. Prepared for CCA Environmental. South Africa. Archaeology, Contracts Office, University of Cape Town Parkington, J. et al (2008). Karoo Rock Engravings: Marking Places in the Landscape. Clanwilliam: Living Landscape Project. Peires, J.B. (1989). The British and the Cape, 1814-1834 in Elphick, R. and Giliomee, H. editors (1989). The Shaping of South African Society 1652-1840. (2nd ed) Cape Town: Maskew Miller Longman. Penn, N. (1989). Labour, land and livestock in the Western Cape during the eighteenth century: the Khoisan and the colonists. In James, W.G. and Simons, M. editors (1989). The Angry Divide. Cape Town: David Philip Penn, N. (2005) The Forgotten Frontier. Cape Town: Double Storey Books. Pinnock, D. (1989). Ideology and Urban Planning: Blueprints of a Garrison City. In James, W.G. and Simons, M. editors (1989). The Angry Divide. Cape Town: David Philip. Porterville, Western Cape (nd1). Accessed on 22 May 2013 at: http://en.wikipedia.org/wiki/Porterville,_Western_Cape Randle, T. (2005). Brief historical timeline for the Dwars River Valley for the last 2000 years. A report produced for the Boschendal Estates Heritage Impact Assessment. Robert Jacob Gordon (nd). Accessed on 13 June 2013 at: http://en.wikipedia.org/wiki/Robert_Jacob_Gordon Sleigh, D. (2004). Die Buiteposte: VOC-Buiteposte onder kaapse bestuur 1652-1795. Pretoria: Protea Boekhuis. Smidt, I. (2013). Saron: Valued heritage: final draft of MPhil in Conservation of the Built Environment, UCT. Western Cape Provincial Heritage Sites (Previously National Monuments) (nd). Accessed on 8 May 2013 at: http://www.westerncape.gov.za/other/2010/11/provincial_heritage_sites_2002_09_19_- _old_national_monuments.pdf Whitehead, M. (2010). Passes and Poorts: Getaway’s Top 30 Scenic Mountain Routes in the Western Cape. Johannusburg: Jacana Media. Wilson, F. (1975). Farming, 1866-1966. In The Oxford History of South Africa Vol. II. South Africa 1870- 1966. Oxford: Oxford University Press.

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Wilson, M. and Thompson, L. editors (1975). The Oxford History of South Africa Vol. II. South Africa 1870-1960. Oxford: Oxford University Press. Winter, S., & Oberholzer, B., in Association with Setplan. May 2013. Heritage and Scenic Resources: Inventory and Policy Framework: A Study Prepared for the Western Cape Provincial Spatial Development Framework. Published on the DEA&DP website, with associated inventory and maps. Worden, N. and Crais, C. (1994). Breaking the Chains: Slavery and its Legacy in the Nineteenth-Century Cape Colony. Johannesburg: Witwatersrand University Press.

LIST OF MAPPING SOURCES Historic 1: 50 000 Topo-Cadastral Maps  Chief Director Surveys and Mapping (1987). 3319AB Gydo Pass. First Edition.  Chief Director Surveys and Mapping (1980). 3318AB Hopefield. Third Edition.  Chief Director Surveys and Mapping (1971). 3319AA Groot Winterhoek. First Edition.  Chief Director Surveys and Mapping (1971). 3319BA Baviaanshoek. First Edition.  Chief Director Surveys and Mapping (1969). 3319BB Inverdoorn. First Edition.  Chief Director Surveys and Mapping (1966). 3317BB& 3318AA Saldanha. Second Edition.  Chief Director Surveys and Mapping (1965). 3218CD Bergrivier. First Edition.  Chief Director Surveys and Mapping (1965). 3219CD De Meul. First Edition.  Chief Director Surveys and Mapping (1965). 3318AB Yzerfontein. Second Edition.  Chief Director Surveys and Mapping (1965). 3318DA Philadelpihia. Second Edition.  Chief Director Surveys and Mapping (1965). 3319BC De Doorns. First Edition.  Chief Director Surveys and Mapping (1963). 3219CC Keerom. First Edition  Chief Director Surveys and Mapping (1963). 3318BB Porterville. Second Edition.  Chief Director Surveys and Mapping (1963). 3318BD Riebeek-Kasteel. Second Edition.  Chief Director Surveys and Mapping (1963). 3318DB Paarl. Second Edition.  Chief Director Surveys and Mapping (1961). 3218DC Moravia. First Edition.  Chief Director Surveys and Mapping (1961). 3218DD Piketberg. First Edition.  Chief Director Surveys and Mapping (1959). 3319AD Ceres. First Edition.  Chief Director Surveys and Mapping (1958). 3319CA Bains Kloof First Edition.  Chief Director Surveys and Mapping (1949). 3319AC Tulbagh. First Edition.  Chief Director Surveys and Mapping (1943). 3318 AB Yzerfontein. First Edition.  Chief Director Surveys and Mapping (1943). 3318AD Darling. First Edition.  Chief Director Surveys and Mapping (1943). 3318BA. Moorreesburg. First Edition.  Chief Director Surveys and Mapping (1941). 3318CB Mamre. First Edition.

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Recent Edition 1: 50 000 Topo-Cadastral Maps  Chief Director Surveys and Mapping (2010). 3318AB Yzerfontein. Fifth Edition.  Chief Director Surveys and Mapping (2003). 3218CD Bergrivier. Third Edition.  Chief Director Surveys and Mapping (2003). 3218DC Moravia. Third Edition.  Chief Director Surveys and Mapping (2003). 3218DD. Piketberg. Third Edition.  Chief Director Surveys and Mapping (2003). 3219CC Keerom. First Edition  Chief Director Surveys and Mapping (2003). 3219CD De Meul. Third Edition  Chief Director Surveys and Mapping (2000). 3318AB Hopefield. Fourth Edition.  Chief Director Surveys and Mapping (2000). 3318BA Moorreesburg. Fourth Edition.  Chief Director Surveys and Mapping (2000). 3318 BB Porterville. Fourth Edition.  Chief Director Surveys and Mapping (2000). 3318 BD Riebeek-Kasteel. Fifth Edition.  Chief Director Surveys and Mapping (2000). 3318 CB Mamre. Fifth Edition.  Chief Director Surveys and Mapping (2000). 3318 DA Philadelpihia. Fifth Edition.  Chief Director Surveys and Mapping (1999). 3318AD Darling. Fourth Edition.  Chief Director Surveys and Mapping (1998). 3317BB& 3318AA Saldanha. Fourth Edition.  Chief Director Surveys and Mapping (1997). 3319AA Groot Winterhoek. Second Edition.  Chief Director Surveys and Mapping (1997). 3319AB Gydo Pass. Second Edition.  Chief Director Surveys and Mapping (1997). 3319AC Tulbagh. Third Edition.  Chief Director Surveys and Mapping (1997). 3319AD Ceres. Third Edition.  Chief Director Surveys and Mapping (1997). 3319BA Baviaanshoek. Second Edition.  Chief Director Surveys and Mapping (1997). 3319BB Inverdoorn. Third Edition.  Chief Director Surveys and Mapping (1997). 3319BC De Doorns. Third Edition.  Chief Director Surveys and Mapping (1997). 3319CA Bains Kloof. Third Edition.

POLICY DOCUMENTS  City of Cape Town (2012). City of Cape Town Spatial Development Framework – Statutory Report: o Map 5.8: Cultural landscapes, scenic drives and world heritage areas.  City of Cape Town (2012). Blauwberg District Plan: Technical Report – Final (adopted): o Figure 5-4: Blaauwberg Cultural and Recreational Zone. o Figure 6.10: Blaauwberg Sub-district 6: Atlantis and surrounds.  City of Cape Town (2012). Northern District Plan: Technical Report – Final (adopted): o Figure 6: Northern Cultural and Recreational Zone. o Figure 17: Northern Sub-distinct 4.

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 City of Cape Town (2008). Draft Urban Edge Plan: Atlantis, Mamre, Philadelphia and Klipheuwel.  Drakenstein Local Municipality (2010). Witzenberg Spatial Development Framework 2012-2017 – Final (adopted): o Figure 31.a. Drakenstein Cultural landscapes. o Figure 39.a.5 (Saron urban edge).  Swartland Local Municipality (2012). Swartland 2012-2017 Spatial Development Framework – Final (adopted): o Abbotsdale Spatial Proposals (plan); o Darling Spatial Proposals (plan); o Kalbaskraal Spatial Proposals (plan); o Riebeek-Kasteel Heritage& Conservation (plan); o Riebeek-Kasteel Spatial Proposals (plan).  Provincial Spatial Development Framework (Draft May 2013): Heritage and Scenic Resources: Inventory and Policy Framework for the Western Cape. o Appendix A; o Appendix B (22.7); o Cape Metro Heritage and scenic reources; o West Coast Heritage and Scenic resources map; o Western Cape Heritage and Scenic resources map; o Winelands Heritage and Scenic resources.  Witzenberg Local Municipality (2012). Witzenberg Spatial Development Framework 2012-2017 – Final (adopted): o Map 25 (Witzenberg Cultural and Sensitive landscapes); o Plan C.6 4-2 (Bella Vista urban edge); o Plan C.6 4-5 (Wolseley Vista urban edge).

INTERNET  Google Earth 2013.

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ANNEXURE 1: RECORDS OF DECISION APPLICABLE TO THE STUDY

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Gamma Kappa 2

Our Ref: 9/2/100/001, 9/2/091/0004

Enquiries: Kathryn Smuts Date: Wednesday October 17, 2012 Tel: 021 462 4502 Email: [email protected] Page No: 2 CaseID: 615

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Palaeontologist is needed to indicate that this is unnecessary. If the area is deemed sensitive, a full Phase 1 Palaeontological Impact Assessment will be required and if necessary a Phase 2 rescue operation might be necessary. (See www.palaeontologicalsociety.co.za for a list of accredited Palaeontologists).

Any other heritage resources that may be impacted such as built structures over 60 years old, sites of cultural significance associated with oral histories, burial grounds and graves, graves of victims of conflict, and cultural landscapes or viewscapes must also be assessed.

Should you have any further queries, please contact the designated official using the case number quoted above in the case header.

Yours faithfully

______Kathryn Smuts Heritage Officer: Archaeology South African Heritage Resources Agency

______Colette Scheermeyer SAHRA Head Archaeologist South African Heritage Resources Agency

ADMIN:

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ANNEXURE 2.1: BRIEF HISTORICAL TIMELINE FOR THE WARM AND KOUE BOKKEVELD AND TULBAGH VALLEY Research and compilation by Richard Whiteing for Bridget O’Donoghue and Sally Titlestad. To be read in conjunction with timeline for the Swartland.

PERIOD ROLE OF THE DISTRICT ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - PHYSICAL/DOCUMENTARY ± 2000 BP - As a hunting area for the - The San had been living in the region for many thousands of years. - Physical evidence of the San and PRE COLONIAL San. Khoekhoen is located in rock art, stone SETTLEMENT artefacts found in agrricultural fields, in mountains and along river courses, as well as being associated with muliple place names in - As seasonal grazing - Around 2000 BP, a group of pastoralists called the Khoekhoen the region. grounds for the migrated down through southern Africa towards the south-western Khoekhoen populations area of the continent where the winter rains of the Western Cape - Some 2 000 years ago Khoekhoen that entered the region. are present. They were a group of people that derived from the pastoralists entered into the region and lived aboriginal hunters of Southern Africa, in particular a group found in mainly in small settlements. They were the northern Botswana. [Inskeep 1978] first food producers in South Africa and introduced domesticated animals (sheep, goat and cattle) and ceramic vessels to southern Africa. Often, these archaeological sites are found close to the banks of large streams and rivers. (Deacon and Deacon). 1652 – 1795 - As a site of conflict - The free burghers who became pastoralists required “extensive - Evidence of the expansion is “seen” as between indigenous areas of land which, if need be, they could vacate once the grazing much in the absence of the earlier societies DUTCH COLONIAL people, Khoekhoen and deteriorated” thus a system of renting land, loan farm system, was as in the farms which have been developed PERIOD San, and the trekboers. instituted by the VOC at the Cape. The consequence was that it in the region. encouraged rapid dispersal of the free burghers into the interior; this in turn had major impacts on the KhoeSan societies. The Khoekhoen lost their livestock and land to the colonisers and either became 1652 - 1740 - As a route dominated by hunter gatherers (i.e. San) or were absorbed into the colonial society Two early travellers who used the pass left passes through the s labourers. [Penn 1989] the descriptions of it. Carl Thunberg (1793 in mountains to Tulbagh and - “Several early passes existed between the Swartland and the Ross, 2002) passed through in 1772 stating the interior Tulbagh Valley, which was originally known as “Roodezand”. The that: first of these stemmed from the need to find the Khoekhoe people “the cleft through which we passed from the

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT PERIOD ROLE OF THE DISTRICT ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - PHYSICAL/DOCUMENTARY and their herds of domestic stock for trading purposes. An sandy plain that lies towards the Cape, but expedition in 1658 was sent out by Van Riebeeck. On this expedition gradually rises until it comes to Roodezand, is a surveyor named Pieter Potter became the first European to see the one of the few chasms left by the long range Tulbagh Valley when he climbed a ridge some miles the north of the of mountains through which it is possible for river and gained a view into the valley. He had previously tried to a wagon to pass, though possibly not entirely walk through the kloof but found the going too difficult along the without danger. In some places it is so

river. [Orton ] narrow two wagons could not pass each In order to provide access to the valley a new pass some 4 km to the other.” As an area for the north was made (Ross, 2002 cited by Orton 2004). Mossop (1927) William Burchell (1822:137-138), passing trekboers grazing their suggests this new pass to have been somewhere near the spot through in 1811, described the kloof as: livestock; and establishing where Potter had ascended. Despite W.A. van der Stel’s new name, “a narrow winding defile of about three homesteads in a few well- the name “Roodezand” was still in common use for the Tulbagh miles in length, just enough to allow passage watered areas. valley and the pass became known as “Roodezand Pass”. A rather for the Little Berg River on each side of which poor pass, it had a very steep slope on its eastern side, and wagons the mountains rise up abruptly and lofty. were frequently taken apart and carried over the pass before being Their rocky sides are thickly clothed with

reassembled on the other side. [Orton 2010] bushes and trees from their summits down - As an agricultural region - Local farmers succeeded in creating a road along the northern side to the water… Along the steep and winding of the river that was not too steep. A toll was levied as a contribution sides, a road has been cut, which follows the towards maintenance of the road and this resulted in some farmers course of the river, at a height above it still driving their cattle over the old pass to avoid the toll fee. [Orton generally between fifty and a hundred feet; 2010] in one part rising much higher, and in another, descending to the bottom, and - As a site of conflict - “In 1699 Willem Adriaan van der Stel, then governor at the Cape, leading through the river, which, at this time, between indigenous opened the Roodezand valley to farming, naming it “Land van was not more than three feet deep, although people, Khoekhoen and Waveren” after a place in the Netherlands.” [Orton 2010] often so much swollen by the rains, as to be, San, and commandos and - On 31 July 1700 the first farmers began settling in the basin of the for a day or two, quite impassable.” [Orton

settlers. Little Berg River called Waveren. Two Buiteposte, the Land van 2010: 13] Waveren and Elandskloof, were established in the area to tighten border controls and monitor movement of the KhoeSan. [Bulpin 1980, Penn 2005] - In 1714 the first farms in Waveren were granted, four to Huguenots The remains of this pass were found to be - As a region for the and four to Dutch settlers. [Fransen 2006] still in existence by Burman (1963), although establishment of church - The first stock farmers arrived in the Warm Bokkeveld from the it was in a very state with low-lying sections congregations east via Karoopoort in 1714. [Fransen 2006] washed away and others blocked by tumbled

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT PERIOD ROLE OF THE DISTRICT ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - PHYSICAL/DOCUMENTARY - In 1715, San resisters, possibly the Ubiqua from the mountains in rocks. He also notes the scars of the Waveren district, repeatedly stole cattle and sheep from colonial “remskoene” to be present in places on this farmers. The VOC established an additional military post in the pass. [Orton 2010]. The Nuwekloof pass was - As a route to the district at Witsenberg. The settlers formed a commando and opened in it place in 1968. hinterland pursued one of the groups but were unsuccesfull and only retrieved one cow. The raiders had made off with 32 cows and 700 sheep. Some of the farmhouses have been declared

[Penn 2005] provincial heritage sites including - By 1740 the KhoeSan had been subdued or driven out of the Schoonderzicht, Mont Pellier, Wolwefontein Western Cape region, and Trekboers entered the Hantam, homestead, Schalkenbosch and Klipfontein. Roggeveld, Bokkeveld and Tankwa districts. [Penn 2005] [Western Cape nd] - A VOC commissioner, Baron van Imhoff, visited the rural districts of the Cape in 1743 and recommended improvements. Two more The church, completed in 1748, still stands churches were established, one in Waveren, called the Roodezand today having undergone few alterations. congregation, which was to become the centre of the new town of [Fransen 2006] The church designed by Louis Tulbagh [Fransen 20006] Thibault has been described as a severe

- In 1765 a farmer, Mostert, constructed a road through the pass example of Cape Dutch architecture, and is linking Waveren with the Warm Bokkeveld however there were now a museum. It is also a declared regular washaways as the road crossed the river frequently. provincial heritage site. [Bulpin 1980] 1740 - 1795 [Whitehead 2010] - Karoopoort provided a route to the Karoo once Mostert’s Pass was Theronsberg and Hottentotskloof passes lead opened. east into the hinterland.

The pass through Karoopoort remains in existence. 1795 -1806 - The village of Tulbagh was laid out in 1795, named after Ryk The Drostdy as well as close to 100 other INTERREGNUM Tulbagh, a former and reportedly one of the Cape’s best governors. buildings in Tulbagh have been listed as A drostdy building, hald an hour’s walk from the village, was built on provincial heritage sites. [Western Cape nd] the farm, Rietvlei, and in 1804 a magistrate was appointed. Tulbagh later lost its role as a district centre when Worcester was favoured. [Bulpin 1980]

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT PERIOD ROLE OF THE DISTRICT ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - PHYSICAL/DOCUMENTARY 1806 - 1910 - As a region of agriculture - In 1813 a proclamation to end the loan farm system was issued and the Quitrent system was introduced. Farmers then made use of BRITISH ‘request farms’ in order to reduce their costs. [Freund 1989, Peires OCCUPATION OF THE 1989] CAPE - The Cape Government set up the Cape Land Board in1828; the - As a place for mission Board was tasked with recording farm boundaries accurately [Peires 1806 - 1867 stations 1989] - As a transit route to the - Steinthal was established in 1843 by the Rhenish Mission Society The site of the church and school at Steinthal (to the discovery of Karoo and the diamond on the farm Witzenberg in the Tulbagh valley. have been declared a provincial heritage site. diamonds) fields - In the 1840s, John Montagu, the Cape’s colonial secretary, began [Western Cape nd] the first major road building programme in the Cape, utilising convict labour to reduce costs. He was ably assisted by Major Charles Michell and the road builder, Andrew Geddes Bain. Among their first projects were the construction of a route from Cape Town to the Karoo. Key passes that were constructed included Tulbagh Pass, Michell’s Pass to the Warm Bokkeveld, and the Theronsberg and Karoopoort passes to the Tankwa and Great Karoo. [Bulpin 1980] “The Swartruggens Mountains, to the north - “Karoopoort was one of the routes that people used in travelling of Karoopoort, contain many painted images from the Cape to the Karoo and, during the 1870s and early 1880’s it that almost certainly date to the late 1800s became well used as a result of the discovery of diamonds near when the Karoopoort route was in heavy use Kimberley. Its importance faded from 1885 when the railhead first (Hall & Mazel 2006) and a few other painted reached Kimberley.” [Orton 2004: 13] sites probably dating to the same period also - Karoopoort is a pass 4km long, winding alongside the Doring River occur in other localities nearby (S. Hall, pers. between the ranges of the Witteberg Mountains. It leads to the comm. 2008)”. [Cited in Orton 2004] Bokkeveld Karoo, the beginning of the Great Karoo. [Bulpin 1980] The paintings include horse-drawn vehicles - There was an oustspan beneath Klein Hangklip on the eastern side closely resembling a design called the Spring of the Doring Valley. For travellers from the hinterland, it was a Wagon which was built in Paarl and welcome relief after journeying across the hot and arid Bokkeveld Wellington in the 1870s. [Hall and Mazel Karoo. [Bulpin 1980] 2005]

- In 1848 Michell’s Pass was completed and the route to Cape Town Little has changed in this landscape since the was significantly shortened. [Whitehead 2010] 1800s and the roads are still gravel. [Orton 2004] - As an agricultural centre - This development led to the development of the new village of

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT PERIOD ROLE OF THE DISTRICT ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - PHYSICAL/DOCUMENTARY Ceres, named after Ceres in Scotland. The farm Rietvallei on the Karoopoort and its buildings have been Dwars River was purchased in 1848 and the first erven sold in 1849. declared a provincial heritage site. [Heritage A Dutch Reformed Congregation was established in 1855. Water [Western Cape] was channelled to the town from the Skurwe mountains as the Dwars River was insufficient. A bridge over the Dwars River was built The pass is still in use although on a different by Thomas Bains, son of Andrew Geddes Bains, to link the two halves alignment. Parts of the buttressing of the of the developing town. [Fransen 2006] early pass built by convict labour are still visible. [Bulpin 1980] - In 1864 Ceres was declared a municipality. Ceres flourished with the increased traffic to the diamond fields and the railway link at Ceres is not rich in heritage buildings and Ceres Road, built in 1875. It became an agricultural centre known only one building has been declared a for its apples, cherries and fruit juice. [Fransen 2006, Bulpin 1980] provincial heritage site. However the region - Prince Alfred Hamlet, named after Queen Victoria’s 2nd son who is rich in “fine old homesteads”. [Western visited the Cape in 1860, was established by proclamation on 8 Cape nd, Fransen 2006] December 1864. It was laid out on the farm Wagensboomrivier which was owned by JG Goosen and situated close to the foot of the Gydo Pass. [Bulpin 1980] 1868 - 1910 - As a transit route for a - On 3 October 1893 Wolseley, named after Sir Garnet Wolseley, a railway line linking Cape British general who had served at the Cape, was established as a (to the Union of Town and Kimberley; and town. A railway siding, named Ceres Road, had been built on the site South Africa) later also the Reef. in 187 . Furrows were constructed alongside the town’s streets to Two blockhouses from the Anglo-Boer War allow water to flow through the town. [Bulpin 1980] stand guard as the tarred road from Wolseley passes over the river. These are - During the Anglo-Boer War blockhouses were constructed to declared provincial heritage sites. [Western - As a site of conflict protect bridges along the railway line, including in the Tulbagh Cape nd] District.

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT PERIOD ROLE OF THE DISTRICT ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - PHYSICAL/DOCUMENTARY 1910-1948 - As a centre for packing - In 1912 a branch line from Wolseley reached Ceres via Michell’s and despatching fruit Pass. [Bulpin 1980] UNION OF SOUTH AFRICA - The possibility of exporting fruit and other perishable produce was enabled by the development of refrigeration during WWI. [Wilson 1975]

- The railway was further extended to Prince Alfred Hamlet in 1929 which became a terminus resulting in the town becoming an important centre for the despatch of fruit to Cape Town and beyond. [Bulpin 1980] 1948- present day - As a fruit and wine - Well known farms in the Tulbagh region, some nestling close to the producing region Winterhoek, include Theuniskraal, known for its dry white wines; FROM APARTHEID Remhoogte, a fruit producer; Montpellier and Tweede Jonge TO DEMOCRATIC Gezellen, also known for their wines; and Roodezand, known for its FREEDOM prunes, peaches and grapes. [Bulpin 1980]

REFERENCES

Adhikari M. (2010). The Anatomy of a South African Genocide. Cape Town: UCT Press.

Bulpin, T.V. (1980). Discovering Southern Africa (2nd edition). TV Bulpin Publishers: Cape Town.

Elphick, R. and Giliomee, H. editors (1989). The Shaping of South African Society 1652-1840. (2nd ed) Cape Town: Maskew Miller Longman.

Fransen, H. (2006). Old Towns and Villages in the Cape. Johannesburg: Jonathan Ball.

Freund, W.B. (1989). The Cape under transitional governments, 1795-1814. In: Elphick, R. and Giliomee, H. editors (1989). The Shaping of South African Society 1652-1840. (2nd ed) Cape Town: Maskew Miller Longman.

James, W.G. and Simons, M. editors (1989). The Angry Divide. Cape Town: David Philip.

Inskeep, R.R. (1978). The Peopling of Southern Africa. Cape Town: David Philip.

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Orton, J. (2004). Heritage Scoping Study of the Farm Groot Oliphantskop (Farm 81) for the Proposed Omega Substation, Western Cape. Prepared for Eyethu Engineers. South Africa. Archaeology, Contracts Office, University of Cape Town.

Orton, J. (2010) Heritage Impact Assessment for the Proposed Zen Wind Energy Facility, Tulbagh Magisterial District, Western Cape. Prepared for Savannah Environmental. South Africa. Archaeology, Contracts Office, University of Cape Town.

Peires, J.B. (1989). The British and the Cape, 1814-1834 in Elphick, R. and Giliomee, H. editors (1989). The Shaping of South African Society 1652-1840. (2nd ed) Cape Town: Maskew Miller Longman.

Penn, N. (1989). Labour, land and livestock in the Western Cape during the eighteenth century: the Khoisan and the colonists. In James, W.G. and Simons, M. editors (1989). The Angry Divide. Cape Town: David Philip

Penn, N. (2005) The Forgotten Frontier. Cape Town: Double Storey Books.

Western Cape Provincial Heritage Sites (Previously National Monuments) (nd). Accessed on 8 May 2013 at: http://www.westerncape.gov.za/other/2010/11/provincial_heritage_sites_2002_09_19_-_old_national_monuments.pdf

Whitehead, M. (2010). Passes and Poorts: Getaway’s Top 30 Scenic Mountain Routes in the Western Cape. Johannusburg: Jacana Media.

Wilson, F. (1975). Farming, 1866-1966. In The Oxford History of South Africa Vol. II. South Africa 1870-1966. Oxford: Oxford University Press.

Wilson, M. and Thompson, L. editors (1975). The Oxford History of South Africa Vol. II. South Africa 1870-1960. Oxford: Oxford University Press.

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION ESKOM PROPOSED 765KV POWERLINES KAPPA OMEGA SPECIALIST ASSESSMENT OF SPATIAL HISTORY, CULTURAL LANDSCAPE AND BUILT ENVIRONMENT ANNEXURE 2.2: BRIEF HISTORICAL TIMELINE FOR THE SWARTLAND Research and compilation by Richard Whiteing for Bridget O’Donoghue and Sally Titlestad. To be read in conjunction with timeline for the Warm Bokkeveld and Tulbagh

PERIOD ROLE OF THE SWARTLAND ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - REGION PHYSICAL/DOCUMENTARY ± 2 000 BP - As a hunting area for the - The San had been living in the region for many thousands of years. Physical evidence of the San inhabitants San. living in the Swartland region during the PRE COLONIAL last 2 thousand years is found in the various rock art sites situated in shelters of the SETTLEMENT - Around this time, a group of pastoralists called the Khoekhoen mountain ranges within and surrounding migrated down through southern Africa towards the south-western the area.

- As seasonal grazing area of the continent where the winter rains of the Western Cape It is difficult to find physical evidence of grounds for the are present. They were a group of people that derived from the Khoekhoe kraals and settlements in the Khoekhoen populations aboriginal hunters of Southern Africa, in particular a group found in Swartland. “The great mobility resulting that entered the region. northern Botswana. [Inskeep 1978] from a pastoral mode of subsistence, the destructive action of hooves of the moving herds, as well as the fact that the majority of potential sites are now ploughed lands, have all contributed to the lack of suitable archaeological sites.” [Clift 1995: 4 cited in

Randle 2005] The movement of these fairly large groups of people and their flocks of sheep and cattle created broad trails where - From the 1590s the Khoekhoen along the coast began trading with once only narrow paths existed. It has been passing ships requiring fresh meat and water. In return for their suggested that these stock trails became livestock, the Khoekhoen received iron, copper and tobacco. In later the basis of the Dutch East India Company years the Dutch stopped trading iron as they saw that this improved (VOC) trading routes. [Ross 2002: 71 cited the weaponry of the Khoekhoen who made spear- and arrow-points in Randle 2005] from the metal. [Elphick & Malherbe 1989] The Khoekhoe groups were entering environments that were already inhabited by San hunters. “Any introduction of exotic herds is bound to have put pressure on the

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PERIOD ROLE OF THE SWARTLAND ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - REGION PHYSICAL/DOCUMENTARY San’s resources, such as grazing for wild game. The incoming herdsmen would have changed the social life and environment of the local hunting population” [Boonzaier et al 1996: 27 cited in Randle 2005].

1652 – 1795 - As a site of conflict - The free burghers who became pastoralists required “extensive Evidence of the expansion is “seen” as much between indigenous areas of land which, if need be, they could vacate once the grazing in the absence of the earlier societies as in DUTCH COLONIAL people, Khoekhoen and deteriorated” thus a system of renting land, loan farm system, was the farms which have been developed in the PERIOD San, and the trekboers. instituted by the VOC at the Cape. The consequence was that it region. encouraged rapid dispersal of the free burghers into the interior; this in turn had major impacts on the KhoeSan societies. The Khoekhoen lost their livestock and land to the colonisers and either became 1652 - 1740 hunter gatherers (i.e. San) or were absorbed into the colonial society as labourers. [Penn 1989] - During the 2nd Khoe-Dutch War, 1673-77, the first official commando was organised to defeat the Cochoqa whose range covered much of the Swartland and whose centre of transhumance was probably in the vicinity of Mamre. The action resulted in the seizing of 1 765 head of cattle and nearly 5 000 sheep. The Cochoqa led by Gonnema disintegrated as a group. The remaining groups were at the mercy of the Dutch and hostile KhoeSan. [Penn 2005]

- As a transit route to the - During the mid- and late-1600s, exploration and trading groups northern hinterland travelled through the Swartland to the area of the Oliphants River Maps in Mossop’s book provide evidence for and Namaqualand as well as to the Roodezand area. Cattle and the early routes through the region. [Mossop sheep were acquired from the Khoekhoen through trade by VOC 1927] butchers and were driven through the Swartland to Cape Town. Later a ‘farm’ called Deurgang was allocated for the purpose of ‘The 1890 Cape Survey shows this driving livestock to Cape Town, stretching from Salt River to the east thoroughfare running all the way from the

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PERIOD ROLE OF THE SWARTLAND ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - REGION PHYSICAL/DOCUMENTARY of Riebeek Kasteel. [Mossop 1927, Orton 2010] region of present day Salt River (where the Salt River Outspan was located) northwards - As an area for the - At the time of the 3rd frontier in the early 1700s, there were 4 VOC past several outspans (including Baas trekboers grazing their buiteposte in the Swartland: Groene Kloof, Riebeek-Kasteel, Ariesfontein Outspan) to eventually leave the livestock; and establishing Sonquas Drift and Vogel Vallei. Their purpose was to build up the map to the east of Riebeek Kasteel. On this homesteads in a few well- stock of sheep and cattle for the VOC to trade with ships, as well as survey map it is labelled “Thoroughfare for

watered areas. to tighten the border and monitor the movements of the KhoeSan. Butcher‟s cattle 50 roods wide”.’ [Orton Some of the remaining Khoe captains grazed their stock close to the 2010] buiteposte for protection against KhoeSan who raided their livestock in retaliation to their loss of land. As trade with Khoe herders was opened up to settlers, the role of the buiteposte diminished and they became farms or villages. [Penn 2005] - As an agricultural region - Early farms in the Riebeek Valley and environs date from 1704 including Ongegund (later named Boplaas), Allesverloren and Kloovenburg. From 1714 farmers were allowed to grow crops on

leased lands and over time the following were introduced: vines, oats, barley and wheat. [Du Toit and Cowling 2006] Map of Buiteposte van die derde grens, 1703- - The smallpox epidemic of 1713 decimated the Khoe population of 1706 in Sleigh [Sleigh 2004] the Western Cape, thereby ending a long process of the breakdown Some of the farmhouses in the Malmesbury - As a place for churches of the Khoe as a society in the region. The change in the land policy District have been declared provincial with the introduction of loan farms in 1714 is possibly directly linked heritage sites including Ongegund, De to the final decimation of Khoekhoen in the region. [Elphick & Groote Post and Klawervallei. [Western Malherbe 1989, Penn 2005] Cape nd]

- As a region for agricultural - The Swartland, named after the “renosterbossies” found in the

developments area and not the colour of the soil, became a fairly intensive th agricultural area from the early 18 century.

- By 1740 the KhoeSan had been subdued or driven out of the Western Cape region, and Trekboers entered the Hantam, 1740 - 1795 Roggeveld, Bokkeveld and Tankwa districts. Many of the defeated KhoeSan became herders or servants for the new farmers, including

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PERIOD ROLE OF THE SWARTLAND ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - REGION PHYSICAL/DOCUMENTARY those captured in raids. [Penn 2005]

- A VOC commissioner, Baron van Imhoff, visited the rural districts of the Cape in 1743 and recommended improvements. Two more churches were established, one in present-day Malmesbury. In 1775 the Inboekseling system of [Fransen 2006] indenturing indigenous people was - Robert Gordon is credited with introducing merino sheep to the legalised. Cape in 1789. [Robert Jacob Gordon ND]

The farm of the widow Van der Westhuyzen, Welvergenoegd, on the Diep River was acquired for the new congregation in Malmesbury. The congregation has retained its original name of Swartland despite the town being named Malmesbury. [Fransen 2006]

1795 -1806 INTERREGNUM

1806 - 1910 - As a place of mission - In 1807 the mission station of Groene Kloof, renamed Mamre in The original farmhouse, dating back to the stations 1854, was established by two Moravian missionaries on the 1760s, and the water mill are provincial BRITISH invitation of the Earl of Caledon after the perceived success of heritage sites. Much of the historic OCCUPATION OF THE Genadendal. The mission station was developed on 3 farms, Groene ambience of the village has been lost to CAPE Kloof [also called De Kleine Post], Louwsplaas, a Khoekhoe reserve, the modernisation of the houses in recent and Cruijwagenskraal. [Fransen 2006] years. Photographs of the 1960s show 360 1806 - 1867 The layout of the village included agricultural allotments on either thatched and whitewashed houses. side of the Louwskloof River with houses facing the river. [Fransen [Fransen 2006, Western Cape nd] (to the discovery of 2006]. Regulations regarding church membership, diamonds) conversion to Christianity and importance - As a region for slave - In 1808 a slave rebellion began on the farm Vogelgezang, just north of the family resulted in homogeneous

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PERIOD ROLE OF THE SWARTLAND ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - REGION PHYSICAL/DOCUMENTARY rebellion of Malmesbury. It was instigated by Louis of Mauritius who lived and communities in the mission stations. worked in Cape Town. The slaves went from farm to farm ransacking the properties on their route however none of the farmers were A silver beaker that had belonged to the killed. Some 340 slaves, mostly men, participated in the unsuccessful farmer Petrus Gerhardus Louw, where the rebellion. In the ensuing retribution, five of the ringleaders were revolt had begun, is said to have been used executed. [Mostert 2011] by the initiators of the rebellion. The story about the beaker is part of the family’s oral - As a region of revised - The Caledon Code requiring labour contracts between employers tradition and the beaker has been donated labour relations and workers was introduced in 1809. The code introduced the first to Iziko Museums. [Iziko Museum press pass laws in that indigenous people tied by contract were required to release reproduced in Mostert 2011] have signed permission when leaving farms they worked on. It also legalised the ‘apprenticeship’ or indentured labour of Khoekhoen between the ages of 8 and 18. Despite some protection for Revised legislation in the form of the Masters indigenous workers, the code entrenched the power of the farmers. and Servants Act of 1856 entrenched [Penn 2005] control of the movement of people of colour and made it a crime to be - As a region of agriculture - In 1813 a proclamation to end the loan farm system was issued and unemployed. the Quitrent system was introduced. Farmers were compelled to look at the output of the land. However some farmers then made use of ‘request farms’ in order to reduce their costs, while others moved to away to border lands with their stock. [Freund 1989, Peires 1989, Wilson 1969] - As a region for the - In response to an increase in international prices, wool farming development of church production increased and greater numbers of merino sheep towns acquired. [Wilson 1969]

- The Cape Government set up the Cape Land Board in 1828; the Board was tasked with recording farm boundaries accurately [Peires 1989]

- In 1827 the town of Malmesbury was proclaimed and 16 erven were offered for sale the following year. In 1829 the town was - As a place for further named after the Earl of Malmesbury, a relative of Sir Lowry Cole, A number of the early houses still exist

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PERIOD ROLE OF THE SWARTLAND ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - REGION PHYSICAL/DOCUMENTARY changes to labour relations governor of the Cape at the time. A plan for the town was developed however many have lost their gables and by J Knobel, and 24 houses are shown in a plan of 1840; but growth thatched roofs were exchanged for tin, was rapid and the town had a population of more than 1 000 by possibly due to severe storms in 1895 and 1865. [Fransen 2006] 1912. Photographs of some of these - After some difficulties, the new congregation of Wellington came houses and other historic buildings appear into being and the farm of Champagne was purchased in 1838. RL in Fransen and the Malmesbury Tourism Aling surveyed the area and laid out 30 erven which were soon sold. Bureau online publication, Malmesbury An earlier wagon route became the main street, and the church was Historic Route. [Fransen 2006, erected on a very prominent site on a T-junction. On 4 November Malmesbury Tourism Bureau nd] 1863 the railway reached the town and it became the 1st rail terminus in the hinterland until the line was extended to Kimberley. [Fransen 2006] - Slaves in the Cape were declared freed on 1 December 1834 The original opstal of Champagne, a T- however a 4-year ‘apprenticeship’ indentured them to their ex- shaped homestead, is still standing and a owners until 1838. Thereafter a number of slaves sought a safe number of other houses as well as haven on mission stations in the region including Groenekloof educational institutional buildings are (Mamre) and later on Saron. Due to insufficient land, the mission listed provincial heritage sites. [Fransen stations became reservoirs of seasonal labour for neighouring farms. 2006, Western Cape nd] An unintended consequence of the freeing of slaves was the reduction of the permanent work force and the introduction of seasonal labour on a grand scale on wheat and wine farms. [Worden and Crais - As a place for mission - Saron was started when the 2 300ha farm, De Leeuwensklip, was The site of the church at Saron is a declared stations bought in 1846 by Johannes Kulpmann of the Rhenisch Missionary provincial heritage site. The church itself Society in order to establish a mission station to serve the freed has been much altered since 1853 and the slaves and indigenous inhabitants in the area. By 1848 there were village has lost much of its character as a 120 families living on the mission. The farm comprised a house mission station. Smidt has identified over (c1775), ‘werf wall’, water mill, smithy and wine cellar. The mission 40 historic buildings in the town. [Western was sited at the existing farm complex and the farm buildings were Cape nd, Fransen 2006, Smidt 2013] incorporated into the mission complex. The farm house became the pastorie, and a church was built adjacent to it after the RMS took control of the mission station in 1852. Additions were made to the church in 1897 and 1949. [Western Cape 2003, Smidt 2013]

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PERIOD ROLE OF THE SWARTLAND ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - REGION PHYSICAL/DOCUMENTARY - In 1853 the town of Darling was founded on the farm, Langfontein. There are numerous older buildings but few It was named after Sir Charles Darling, Lt Governor of the Cape. The of architectural interest. The original town was laid out in elongated blocks and built up close to the small church burnt down in 1957 and a modern river that runs through the town. [Fransen 2006] structure erected in its place. The pastorie and the old mission church built in 1927 - Riebeek West, named after the adjacent Kasteelberg, was first are however of architectural interest. established in 1855 on part of the farm Allesverloren and requested Aerial photographs provide evidence of to be a kerkdorp. This request was opposed and it was only in 1858 the lay out of the town. [Fransen 2006] that a Dutch Reformed parish was formed. The town is sited on the slopes of Kasteelberg and 5 streams run through it. [Fransen 2006] The church has an unusual design as it is - The farming community of Koeberg acquired part of the farm pedimented and classicist rather than - As a region for the Dassenvallei and started to build a church in 1858, gaining Gothic. There are a number of well- development of church permission from the moederkerk in Durbanville later after initial preserved mid-Victorian houses behind towns opposition. The town, given the name Philadelphia, is arguably the the church. A photograph of the church smallest formally established kerkdorp, with only 12 buildings at the provides evidence. [Fransen 2006] end of the 19th century. A small township developed across the spruit, most likely due to apartheid legislation. [Fransen 2006] - Riebeek Kasteel became a separate parish in 1863 however the town was founded earlier than this on the farm De Hoop. The town Aerial photograph available in Fransen. was developed on a grid pattern flanked by the main road with the [Fransen 2006] church facing the village from the opposite side of the road. [Fransen 2006] - In 1863 the town of Porterville was laid out on the farm Pomona, An early map of Malmesbury c1840 has two previously called Willem’s Vallei. It was named after Porter, attorney roads marking the direction of of Riebeek’s general of the Cape Colony from 1839 to 1866. It became a Kasteel, suggesting that the town began municipality in 1901. The surrounding area is known for its yellow long before it gained its kerkdorp status. disas and hang gliding. [Porterville, Western Cape nd] The map as well as photographs of the town are reproduced in Fransen. [Fransen 2006]

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PERIOD ROLE OF THE SWARTLAND ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - REGION PHYSICAL/DOCUMENTARY 1868 - 1910 - As an area for transport - On 12 November 1877 a branch line to serve the Swartland reached A map showing the railways in the Cape linking Cape Town with Malmesbury. This was extended to Picketberg in 1905. [Burman Colony in 1882. [Cape Government Railways (to the Union of towns in the region 1984] Map 1882 in Burman 1984] South Africa) - A railway crossing was built on the farm Spes Bona in 1898. The farm was sub-divided and the settlement of Kalbaskraal was developed on the site. [Swartland 2007] - In 1901 a start was made on the construction of a narrow gauge [24-inch] railway from Kalbaskraal to Hopefield. It reached Darling - As a region of intensified on 4 October 1902 and Hopefield on 28 February 1903, and was agriculture known as the Hopefield-Darling line. The lines at Kalbaskraal were constructed at different levels so that goods could be easily transhipped between goods wagons. Due to the different gauge line, additional rolling stock was acquired for the line. Despite plans, the line was never extended to Saldanha Bay or further north; however it did benefit the Malmesbury line with the additional traffic. [Burman 1984] - Introduction of Prison - In 1889 the prison system began hiring out prisoners for work on farms wine farms. [Wilson 1975] - As a region of conflict - During the Anglo-Boer War or South African War, blockhouses were The southernmost blockhouse from the during the Anglo-Boer War constructed to protect bridges along the railway line, including in the Anglo-Boer War near Wellington is a Wellington District. declared provincial heritage site. [Western - The town of Darling experienced the most southerly action of the Cape nd] Boer commandos during November 1901 when a group of 150 men led by Fieldcornet CP Hildebrand entered the town, cut the telegraph The monument still stands close to Klipberg, line, freed a prisoner, and requisitioned supplies and commandeered and a photograph was included in the horses from the surrounding farms. A British force of 500 soldiers article by Athiros. [Athiros nd]. under LtCol Crabbe detrained at Kalbaskraal and proceeded to Darling where they engaged the commando at Klipberg, some 6km north of the town. During the engagement Hildebrand was mortally wounded and his troops later concealed his remains in a porcupine burrow. They returned to bury him but failed to find the site. The body, found by a shepherd, and buried by the farmer, was later given a formal burial and a monument erected on the site in 1939. [Athiros

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PERIOD ROLE OF THE SWARTLAND ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - REGION PHYSICAL/DOCUMENTARY nd]

1910-1948 - As a region of intensive - The possibility of exporting eggs, meat, fruit and other perishable agriculture produce was enabled by the development of refrigeration during UNION OF SOUTH WWI. [Wilson, 1975] AFRICA - During the 1930s there was an increase of 66% in wheat production due to the introduction of tariffs to prevent cheaper imports and government intervention to reduce price fluctuations of agricultural products which had been problematic for farmers. This led to the uneconomic expansion of wheat, wine, milk and butter production to the detriment of the ecology in marginal areas. [Wilson 1975] - In 1937 the prison labour system expanded, and from 1947 prison farms were built. The costs were borne by the farmers but the prisons were run by the prison services. By 1966 there were 13 gaols providing farm labour in the Western Cape. [Wilson 1975] - As a site for aircraft bases - During WWII 6 additional airfields were developed in response to and radar facilties during the U-Boat attacks in 1942; one of these airfields was situated at WWII Darling and Lockheed Ventura aircraft of 23 Squadron were based here, followed by 27 Squadron. In 1943 29 Operational Training Unit was relocated from Nigel. Training included launching of torpedoes. A steel hangar and lecture rooms were erected in 1944. A crew of six died when their aircraft crashed into the hill of Dassenberg in 1948. [Darling, Western Cape nd] - Another aspect of defence was the introduction of radar facilties. A transportable radar unit was placed at Somersveld north-west of Darling. The readings were taken only on aircraft, using two tall 30m masts right out in the flat veld. This radar set was designed for accurately plotting high-flying aircraft, presumably in anticipation of

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PERIOD ROLE OF THE SWARTLAND ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - REGION PHYSICAL/DOCUMENTARY bombers from an enemy aircraft carrier on their way to attack Cape Town. The operators spent most of the time plotting friendly SAAF and RAF aircraft from a big air force training camp not far away. The radar operators were young women from the Special Signals Service. [Mangin and Lloyd 1998] 1948- present day - In 1948 the newly elected National Party government formalises segregation under its apartheid policy. FROM APARTHEID TO - As a region of segregated - The Population Registration Act of 1950 required every South The houses constructed in the new DEMOCRATIC towns African to register and was classified according to their ‘racial’ townships are very similar in design and FREEDOM characteristics. Linked to this act, the Group Areas Act of 1950 can be seen throughout the region. These divided towns into residential and business for different groups townships are often far removed from classified by apartheid legislation, resulting in complete segregation town centres and are separated by of people of colour as thousands of people were forcibly removed geographic or other ‘barriers’, for example from their homes. New ‘townships’ were developed for the in Malmesbury the areas developed for different ‘race’ groups. people of colour are to the west of the N7. - Capital investment on farms increased after WWII with the [Pinnock 1989; Google Maps 2013] - As a wheat and wine construction of dams and contour banks, the closing of dongas and producing region other improvements. This was made possible through the availability of credit, tax concessions and the rapid increase in land values. [Wilson 1975] - Mechanisation with the purchasing of tractors and harvesters increased exponentially in the 1940s and 50s. The wealth generated saw the construction of large brick houses, tennis courts and the introduction of electricity on farms. The role of government subsidies also assisted this process with R13.2 million paid to wheat farmers by 1967. [Wilson 1975]

- As a place for the - During 1990-91 the “1913 and 1936 Land Acts, Group Areas Act, development of democracy Population Registration Act, and separate Amenities Act repealed; political organizations unbanned; state of emergency revoked; amid widespread violence, delegates from 18 parties start formal negotiations.” [Thompson 1995: xix in Randle 2005] - As a site for new housing - After 1994 new legislation introduced free RDP (Reconstruction and

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PERIOD ROLE OF THE SWARTLAND ASSOCIATIONS/PEOPLE/EVENTS/ACTIVITIES/ELEMENTS/BUILDINGS MATERIAL EVIDENCE - REGION PHYSICAL/DOCUMENTARY projects Development Programme) houses for people below with low incomes. The newly developed areas can be easily - As a region of new - Since 1990 olive production has expanded in the Swartland and identified due to the new house designs agricultural opportunities prizes won for excellence of the olive oil produced. The historic farm which are generally square in shape as of Kloovenburg in the Riebeek Valley won an international prize in compared to the oblong semi-detached 2005 after only 4 years of production. Riebeek Kasteel hosts an houses of the 1960-80 period. [Google Maps annual olive festival. [Du Toit and Cowling 2006] 2013] - The Land Reform (Labour Tenants) Act of 1995 and the Extension of - As a region of contested Security of Tenure Act of 1997 have attempted to strengthen the rights to residency on farms occupation and use rights of farm dwellers, including rights against and changes in labour evictions from the land. A consequence has been the casualisation of relations farm labour by farmers to limit the number of farm workers with rights to residence on the farms. [Cross and Hornby 2002]

REFERENCES

Adhikari M. (2010). The Anatomy of a South African Genocide. Cape Town: UCT Press.

Athiros, G. (nd) Route 27 West Coast South Africa: The Hildebrand Monument: Anglo-Boer War 1899-1902. Accessed on 27 May 2013 at: http://www.route27sa.com/hildebrand.html

Bulpin, T.V. (1980). Discovering Southern Africa (2nd edition). TV Bulpin Publishers: Cape Town.

Burman, J. (1984). Early Railways at the Cape. Cape Town: Human & Rousseau.

Clift, H. (2008). Appendix accessed on 10 May 2013 at:

http://www.eskom.co.za/content/APPENDIX%205%20Historical%20chronology%20HC%20Corrections~1.pdf

Cross, C. and Hornby, D. (2002). Obstacles to Women’s Land Access in South Africa. A Research Report for the Promoting Women’s Access to Land Programme. Accessed on 20 June 2013 at:

http://www.info.gov.za/otherdocs/2002/landgender.pdf

Darling, Western Cape (nd). Accesses on 22 May 2013 at:

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Du Plessis, K. and Cowling, V. (2006). West Coast: Cederberg to the Sea. Cape Town: Struik.

Elphick, R. and Giliomee, H. editors (1989). The Shaping of South African Society 1652-1840. (2nd ed) Cape Town: Maskew Miller Longman.

Elphick, R. and Malherbe, C. (1989). The Khoisan to 1828. In The Shaping of South African Society 1652-1840. (2nd ed) Cape Town: Maskew Miller Longman.

Fransen, H. (2006). Old Towns and Villages in the Cape. Johannesburg: Jonathan Ball.

Google Maps. (2013). Accessed on 13 June 2013 at:

Inskeep, R.R. (1978). The Peopling of Southern Africa. Cape Town: David Philip.

James, W.G. and Simons, M. editors (1989). The Angry Divide. Cape Town: David Philip

Malmesbury Tourism Bureau (nd). Malmesbury Historic Route. Accessed on 22 May 2013 at:

http://www.malmesburytourism.co.za/malmesbury-history.htm

Mangin, G. and Lloyd, S. (1998). The Special Signal Services (Sss): We scanned the seas and skies in the Second World War. Military History Journal Vol 11 No 2 - December 1998.

Mossop, E.E. (1927). Old Cape Highways. Cape Town: Maskew Miller.

Mostert, L. (2011). History Textbook Workbook Grade 10 NCAPS. Cape Town: Allcopy Publishers. Accessed on 20 June 2013 at: intranet.parklands.co.za/?dl_id=2 Orton, J. (2010). Heritage Impact Assessment for the Proposed Expansion of the N7 between the Melkbos and Atlantis Junctions, Malmesbury Magisterial District, Western Cape. Prepared for CCA Environmental. South Africa. Archaeology, Contracts Office, University of Cape Town.

Peires, J.B. (1989). The British and the Cape, 1814-1834 in Elphick, R. and Giliomee, H. editors (1989). The Shaping of South African Society 1652-1840. (2nd ed) Cape Town: Maskew Miller Longman.

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Pinnock, D. (1989). Ideology and Urban Planning: Blueprints of a Garrison City. In James, W.G. and Simons, M. editors (1989). The Angry Divide. Cape Town: David Philip.

Porterville, Western Cape (nd1). Accessed on 22 May 2013 at: http://en.wikipedia.org/wiki/Porterville,_Western_Cape

Porterville, Western Cape (nd2). Accessed on 22 May 2013 at: http://www.swartlandwineroute.co.za/message-manager.htm

Randle, T. (2005). Brief historical timeline for the Dwars River Valley for the last 2000 years. A report produced for the Boschendal Estates Heritage Impact Assessment.

Robert Jacob Gordon (nd). Accessed on 13 June 2013 at: http://en.wikipedia.org/wiki/Robert_Jacob_Gordon

Sleigh, D. (2004). Die Buiteposte: VOC-Buiteposte onder kaapse bestuur 1652-1795. Pretoria: Protea Boekhuis.

Smidt, I. (2013). Saron: Valued heritage: final draft of MPhil in Conservation of the Built Environment, UCT.

Western Cape Provincial Heritage Sites (Previously National Monuments) (nd). Accessed on 8 May 2013 at:

http://www.westerncape.gov.za/other/2010/11/provincial_heritage_sites_2002_09_19_-_old_national_monuments.pdf

Wilson, F. (1975). Farming, 1866-1966. In The Oxford History of South Africa Vol. II. South Africa 1870-1966. Oxford: Oxford University Press.

Wilson, M. and Thompson, L. editors (1975). The Oxford History of South Africa Vol. II. South Africa 1870-1960. Oxford: Oxford University Press.

Worden, N. and Crais, C. (1994). Breaking the Chains: Slavery and its Legacy in the Nineteenth-Century Cape Colony. Johannesburg: Witwatersrand University Press.

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BRIDGET O’DONOGHUE & SALLY TITLESTAD HERITAGE CONSULTANTS IN ASSOCIATION

THE PROPOSED KAPPA OMEGA 2ND 765KV TRANSMISSION POWERLINE AND SUBSTATIONS UPGRADE, WESTERN CAPE (NEAS REFERENCE: DEA/EIA/0001266/2012 DEA REFERENCE: 14/12/16/3/3/2/352) VISUAL IMPACT ASSESSMENT

PREPARED FOR:

NZUMBULULO HERITAGE SOLUTIONS CONTACT PERSON: KELEBOGILE MOGAJANE CONTACT NO.: 011 021 4937 E-MAIL: [email protected] ON BEHALF OF:

ESKOM (Pty) Ltd Megawatt Park Maxwell Drive Sunninghill Sandton

PREPARED BY:

AXIS LANDSCAPE ARCHITECTS (CC) 226 Odendaal Street Meyerspark Pretoria 0184

March 2013 AXIS REF:KAP2012

Copyright Warning- Copyright in all text and other matter, including the manner of presentation, is the exclusive property of the author. It is a criminal offence to reproduce and/or use, without written consent, any matter, technical procedure and/or technique contained in this document. Criminal and civil proceedings will be taken as a matter of strict routine against any person and/or institution infringing the copyright of the author and/or proprietors.

i VISUAL IMPACT ASSESSMENT

EXECUTIVE SUMMARY Nzumbululo (Pty) Limited was appointed by Eskom (Pty) Ltd, as the independent environmental consultant to undertake the Environmental Impact Assessment (EIA) for the proposed establishment of the second Kappa Omega 765kV transmission line and substations upgrade. It is located between the Koruson (Kappa) Substation near Ceres to Sterekus (Omega) Substation near Koeberg.

Axis Landscape Architecture cc was appointed by Nzumbululo (Pty) Limited as a sub-consultant to complete a Visual Impact Assessment. This Visual Impact Assessment (VIA) is a specialist study that forms part of the EIA and addresses the visual affects of the proposed transmission line on the receiving environment.

Three alternative routes have been proposed to connect to the two substations. The proposed routes stretch over approximately 415km. The study area contains the extent of the alignments and includes an approximate 5 km buffer area around the alignments.

PROJECT DESCRIPTION The following project components will occur during the construction and operational phases of the project and are identified as elements that may cause a potential landscape and/or visual impact:

• Construction camps and lay-down yards; • Access roads • Substations; and • Transmission Line. • Of the four project components, the towers of the transmission line are expected to cause the greatest impacts. A brief description of the tower characteristics, the three alternatives and their individual routes are discussed in the following tables.

Guyed Cross Rope Self Supporting Double Circuit Suspension Suspension Tower Self supporting Type tower tower Suspension tower Maximum 33 m 48m 30 m 36 m Height Span 450 m 450 m 450 m 260 m Servitude 95 m 110 m 94 m 55m width

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DESCRIPTION OF ALTERNATIVE ALIGNMENTS ALTERNATIVES DESCRIPTION Route 1 is proposed to run in a south westerly direction from the Kappa Substation north of Route 1 Ceres, passing through Ceres continuing straight until it reaches the Omega Substation. Deviation Route 1a is proposed to run from Wellington city centre and run in a North-Western Deviation Route 1a direction until it joins up with Route 2 East of Hermon. Deviation Route 1b diverts 15km after Deviation 1a from Route 1. It runs for about 18km in a Deviation Route 1b North Eastern direction from Wellington city centre until it joins up with Route 2 South - East of Malmesbury. Route 2 is proposed to run in a westerly direction with Route 1 until Piketberg Mountain and Route 2 then deviates from Route 1 in a South-Western direction until the Omega Substation Route 3 is proposed to run in a westerly direction from the Kappa Substation North of Ceres Route 3 until Aurora substation. It then continues from Aurora substation to the Omega substation following the coastline. Route 3a is proposed to run in a south easterly direction from the Aurora substation to the Deviation Route 3a Omega substation following the coastline. Route 3b is proposed to run in a south easterly direction from the Aurora substation to the Deviation Route 3b Omega substation following the coastline. Route 3c is proposed to run in a south easterly direction from the Aurora substation to the Deviation Route 3c Omega substation following the coastline.

DESCRIPTION OF THE AFFECTED ENVIRONMENT The study area is consists of vacant and uninterrupted land as well as cultivated, residential, subsistence farming, and game farms. Extensive game faming and small stock farming activities is located more to the central northern side of the study area and agricultural activities to the south.

Subsistence farming activities are concentrated around the small towns. Human settlements are scattered throughout the study area and the landscape are degraded around these settlements. The landscape character changes through the study area. The study area is divided into distinct landscape types which are areas within the study area that are relatively homogenous in character (Swanwick, 2002). Landscape types are distinguished by differences in topographical features, vegetation communities and patterns, land use and human settlement patterns.

The assessment is done on a macro-scale and discusses the predominant landscape conditions and visual characteristics found in a particular landscape type. Each landscape type is given a descriptive name which relates to the vegetation type, topography and/or land use of the region (Adapted from Van Riet et al, 1997);

· Ceres Karoo Region;

· Ceres Mountain Region; and

· Swartland Region.

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FINDINGS AND RECOMMENDATIONS LANDSCAPE CHARACTER SENSITIVITY The sensitivity of the landscape character is an indication of “…the degree to which a particular landscape can accommodate change from a particular development, without detrimental effects on its character” (GLVIA, 2002). The majority of the study area is considered to have a moderate landscape character sensitivity due to the undulating topography and relative undeveloped condition of the landscape, the generally high visual quality and the related tourism value that is placed on the visual resource. Moderate terrain variability mainly occurs through the study area where a moderately low VAC can be expected. Generally the vegetation cover is shrubland and scattered trees which will provide very little visual screening for the proposed transmission line. The landscape character is considered moderately susceptible to change, whether it is a low intensity change over an extensive area or an acute change over a limited area. Generally, the vegetation occurring in the study area is rigid and recovers very slowly from surface disturbances. SIGNIFICANCE OF LANDSCAPE IMPACTS Landscape impacts are alterations to the fabric, character, visual quality and/or visual value which will either positively or negatively affect the landscape character. During the construction and operational phases, the project components are expected to impact on the landscape character of the landscape types it traverses.

The following table provides a summary of the anticipated landscape impacts that may occur as a result of the construction of the transmission line.

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LANDSCAPE IMPACT Significance Significance Extent of Duration Severity of Probability Level of Activity Nature of Impact without with Impact of Impact Impact of Impact Confidence Mitigation Mitigation Construction phase

Route 1 Moderate Definite Moderate Low High

Deviation Route 1a Moderate Definite Moderate Low High

Deviation Route 1b Moderate Definite Moderate Low High Negative – Impacting on the Route 2 visual quality of High Definite High Moderate High Permanent the landscape due Local if not to the presence of mitigated Route 3 foreign elements High Definite High Moderate High and a loss of Deviation vegetation cover. Route 3a High Definite High Moderate High

Deviation Route 3b Moderate Definite Moderate Low High

Deviation Route 3c Moderate Definite Moderate Low High

Operational phase Route 1 Low Definite Low Low High Deviation Route 1a Low Definite Low Low High

Deviation Route 1b Low Definite Low Low High Negative – Route 2 Impacting on the High Definite High Moderate High visual quality of Local Permanent Route 3 the landscape due High Definite High Moderate High the presence of a Deviation power line. Route 3a High Definite High Moderate High

Deviation Route 3b Moderate Definite Moderate Low High

Deviation Route 3c Moderate Definite Moderate Low High

Construction phase The activities that are expected to cause landscape impacts and that are associated with the construction phase, are the establishment of the construction camps, construction of access roads and the clearance of the site. These activities will create surface disturbances which will result in the removal of vegetation and the exposure of the underlying soil.

The extent of the disturbances will generally affect a relative large footprint area. Access roads to the towers are expected to be a two-track dirt road which will create the minimum disturbance. During construction, the area around the individual towers will be disturbed.

The construction camps and lay-down yards are anticipated to disturb a much larger area. The size and location of the construction camps will play a major role in the severity of the landscape impact. Due to a lack of technical information, two options are considered namely; the location of construction camps in remote, virgin land, or in/adjacent existing settlements. The initial presence of a construction camp in a undeveloped landscape will cause a temporary and localised alteration to the landscape character. A construction camp located in or adjacent to an existing town or settlement will be easily associated with the town and therefore the presence of the town, mitigates the impact. The mitigating result is most effective, the bigger the town or settlement is.

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The exposed soil and change in texture will contrast severely with the intact vegetation around the disturbance footprint and servitudes. Considering the moderately low VAC throughout most of the study area, the undisturbed condition of parts of the landscape and the recovery rate of the endemic vegetation, the severity of landscape impact during the construction stage is expected to be moderate for Route 1, Deviation Route 1a and 1b and high for all the other alternatives. The impact will extend over the entire length of the different alignments and may vary in degrees of severity along the linear length as it transects landscape types of varying VAC. Surface disturbances are also minimised through, for example, utilising existing roads. Operational phase Surface disturbances created during construction may remain for an extended period during the operational phase. These are seen as residual affects carried forward from the construction phase and can be completely or substantially mitigated if treated appropriately during the construction phase. An additional impact will be caused as a result of the presence of the completed transmission line, i.e. that of the evenly spaced towers of the lines, buildings and structures. The industrial character and the near monumental vertical scale of the towers will contrast with the diverse landscape character that prevails through most of the study area. VIEWER SENSITIVITY Within the receiving environment, specific viewers (visual receptors) experience different views of the visual resource and value it differently. They will be affected because of alterations to their views due to the proposed project. The visual receptors are grouped according to their similarities. The visual receptors included in this study are:

• Residents; • Tourists; and • Motorists. To determine visual receptor sensitivity a, commonly used rating system is utilised. This is a generic classification of visual receptors and enables the visual impact specialist to establish a logical and consistent visual receptor sensitivity rating for viewers who are involved in different activities without engaging in extensive public surveys. The sensitivity of the identified visual receptors is discussed in Section 5.2.1. SIGNIFICANCE OF VISUAL IMPACTS Empirical research indicates that the visibility of a transmission tower, and hence the severity of visual impact, decreases as the distance between the observer and the tower increases. The landscape type, through which the transmission line crosses, can mitigate the severity of visual impact through topographical or vegetative screening. Bishop et al (1988) noticed that in some cases the tower may dominate the view for example, silhouetted against the skyline, or in some cases be absorbed in the landscape. A complex landscape setting with a diverse land cover and topographical variation has the ability to decrease the severity of visual impact more than a mundane landscape (Bishop et al, 1985). The following tables summarise the visual impacts on residents, tourists and motorists.

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VISUAL IMPACTS ON RESIDENTS VISUAL IMPACT ON RESIDENTS Significance Significance Extent of Duration Severity of Probability Level of Activity Nature of Impact without with Impact of Impact Impact of Impact Confidence Mitigation Mitigation Construction phase

Route 1 Moderate Definite Low Low High

Deviation Route 1a Moderate Definite Low Low High

Deviation Route 1b Moderate Definite Low Low High Negative – Route 2 Construction Moderate Definite Low Low High camp and lay- Local Temporary Route 3 down yard may cause unsightly Low Definite Low Low High views. Deviation Route 3a Low Definite Low Low High

Deviation Route 3b Low Definite Low Low High

Deviation Route 3c Low Definite Low Low High

Operational phase

Route 1 Moderate Definite Low Low High

Deviation Route 1a Moderate Definite Low Low High

Deviation Route 1b Moderate Definite Low Low High Negative – The presence of a Route 2 power line Moderate Definite Low Low High intrudes on Local Permanent existing views and Route 3 spoils the open Low Definite Low Low High panoramic views Deviation of the landscape. Route 3a Low Definite Low Low High

Deviation Route 3b Low Definite Low Low High

Deviation Route 3c Low Definite Low Low High

Generally, the study area is sparsely populated except around the human settlements, farms and towns. These communities are normally situated along main transportation routes, near agricultural areas or adjacent rivers or water resources

Residential areas and farm residents will experience an intrusion on their views due to the presence of the proposed Transmission Line. It is unpractical to discuss all, but they are recognised as the general population of the study area and are identified as affected visual receptors.

Considering the distribution of residents across the study area, it can be concluded that the entire study area has a low density of residents with the exception of higher concentrations of residents in the towns and human settlements.

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Construction phase During the construction phase, unsightly views may be created by the presence of construction camps and the lay-down yards. The duration of the potential visual impact will be temporary which will result in an anticipated moderately low significance of visual impact for all the alternatives. The visual exposure to the construction activity will initially be limited and only local residents will experience views of the site preparation activity. As the structures increase in scale and height, the ZVI increases, resulting in a greater number of affected viewers and a subsequent increase in visual exposure. The cleared sites, construction camps and material lay-down yard will appear unsightly and out of character. Large scale construction elements such as cranes, will be highly visible and increase awareness of the construction activity over a considerable area. The visual intrusion caused during the construction stage will be moderate, but will be temporary in nature. Operational phase The residents of the residential areas and farming communities next to the power lines may experience a moderate degree of visual intrusion due to their proximity to all the Alternatives. The presence of a transmission line in the visual field of the residents in this part of the study area will spoil the uncluttered panoramic views they currently experience. The silhouette of a transmission line on the horizon will be visible from a great distance and thus increase the ZVI considerably, potentially impacting on more residents.

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VISUAL IMPACTS ON TOURISTS VISUAL IMPACT ON TOURISTS Significance Significance Extent of Duration Severity of Probability Level of Activity Nature of Impact without with Impact of Impact Impact of Impact Confidence Mitigation Mitigation Construction phase

Route 1 Moderate Definite Moderate Low High

Deviation Route 1a Moderate Definite Moderate Low High

Deviation Moderate Definite Moderate Low High Route 1b Negative – Construction camp and lay- Route 2 At a High Definite High Moderate High down yard may number of cause unsightly Temporary point views and spoil Route 3 locations High Definite High Moderate High the undisturbed views over the Deviation landscape. Route 3a High Definite High Moderate High

Deviation Route 3b High Definite High Moderate High

Deviation Route 3c High Definite High Moderate High

Operational phase

Route 1 Moderate Definite Moderate Low High

Deviation Route 1a Moderate Definite Moderate Low High

Deviation Route 1b Moderate Definite Moderate Low High Negative – The Route 2 presence of a High Definite High Moderate High power line Local Permanent intrudes on Route 3 existing views High Definite High Moderate High of the landscape Deviation Route 3a High Definite High Moderate High

Deviation Route 3b High Definite High Moderate High

Deviation Route 3c High Definite High Moderate High

The study area is renowned for its karoo and mountainous landscapes especially in the central and northern regions. These characteristics provide the basis for the tourism industry which plays a role in the economy of the Western Cape Province. The entire study area is considered to have a moderately high tourism potential.

The type of tourist that visits this area is expected to travel considerably through the study area by vehicle. This implies that they will experience a large part of the study area in a relative short time span. Construction phase The temporary duration of the construction phase is expected to cause moderately high visual impacts, especially Route 2 and 3 with it’s deviations. The location and size of the construction camps and lay-down yards will be crucial in regulating the impact. Detail information is not available and it is anticipated that the visual impact will occur localised and that a small number of tourists will be adversely affected by these project components during construction.

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Their exposure to possible unsightly views of the construction camps and the associated activity will however be minimal and localised. The potential visual impact on tourists during the construction phase of the proposed project can be mitigated with relative ease except for Route 2 and 3 with its deviations. The greatest factor to consider is the location of the construction camps from potential views that may be experienced from scenic routes or tourist hotspots. Operational phase Considering the extent of the proposed alternatives, a number of tourists will be affected during their visit to the study area. Although it is difficult to pinpoint particular locations in the study area that are of specific tourist value, since the entire study area bares some value, the most obvious concentration of tourists can be expected in the northern central part of the study area. For these tourists, Route 2 and 3 with its deviations will create alterations to their views. The presence of a transmission line in this undeveloped landscape will spoil the views that are experiencing. It can be concluded that Route 2 and 3 with its deviations will cause a high visual intrusion in the views expected by tourists travelling through the study are.

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VISUAL IMPACTS ON MOTORISTS VISUAL IMPACT ON MOTORISTS Significance Significance Extent of Duration Severity of Probability Level of Activity Nature of Impact without with Impact of Impact Impact of Impact Confidence Mitigation Mitigation Construction phase Route 1 Moderate Definite Low Low High Deviation Route 1a Moderate Definite Low Low High Deviation Route 1b Moderate Definite Low Low High

Route 2 Negative – At a Moderate Definite Low Low High Intruding on number of Route 3 Short period existing views of point Moderate Definite Low Low High Deviation the landscape. locations Route 3a Moderate Definite Low Low High

Deviation Route 3b Moderate Definite Low Low High Deviation Route 3c Moderate Definite Low Low High Operational phase Route 1 Moderate Definite Low Low High Deviation Route 1a Moderate Definite Low Low High

Deviation Route 1b Moderate Definite Low Low High

Route 2 Negative – Moderate Definite Low Low High Intruding on Short period Local Route 3 existing views of Moderate Definite Low Low High the landscape. Deviation Route 3a Moderate Definite Low Low High

Deviation Route 3b Moderate Definite Low Low High Deviation Route 3c Moderate Definite Low Low High

The major routes in the study area are the N7, R45, R315, R27, R311, R44, R304, R312, R46, R303, R43 and R355 connecting the towns and informal settlements. The secondary road network in the study area carries a much lower volume of motorists. Many of the roads are gravel roads which are mostly utilised by the local residents. Their duration of views will be temporary and it is expected that the visual intrusion that they will experience will be moderately low. Construction phase The potential visual impact that may be experienced by motorists during the construction phase is considered to be minimal. Limited information is available and the number, location and size of the construction camps and lay-down yards are essential for accurately assessing the visual impact. It is anticipated that views of the construction camps and lay-down yards of all the alternative routes will be visible from the major roads. The possibility that a construction camp will be established at this location is high and can be motivated from an accessibility point of view, due to the proximity to a major route.

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Operational phase The N7, R27, R47, R44 and R46 are the most prominent, carrying the highest volume of traffic. Route 3 with its deviations will be the most visible from the R27. The severity and significance of visual impact for all the proposed routes on motorists will be moderate.

RECOMMENDED MITIGATION MEASURES In most cases, the landscape and visual impacts occurring during the construction phase can be mitigated relatively effectively. Rehabilitation of the disturbed areas will prevent the exposure of soil, which may cause a reduction in the visual quality of the study area. Sensitive positioning of the construction camps and lay-down yards should take advantage of the natural screening capacity of the study area by locating the camps outside of the views of sensitive visual receptors.

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CONCLUSION The three alternative Routes have been evaluated against international accepted criteria to determine the impact they will have on the landscape character and the viewers that have been identified in the study area.

The alternatives are rated according to preference by using a eight-point rating system in Table 10, eight (8) being the least preferred, to one (1) being the most preferred. The preference rating is informed by the impact assessment discussions in Section 5 and the overall performance of each alternative with regards to the impact on the landscape character and the identified viewers.

Evaluation of alternative alignments

ALTERNATIVES PREFERENCE RATING Route 1 1

Deviation Route 1a 2

Deviation Route 1b 3

Route 2 4

Route 3 6

Deviation Route 3a 8

Deviation Route 3b 7

Deviation Route 3c 5

Route 1 is regarded as the most preferred alternative. Its alignment along the existing transmission line and transmission servitude is considered to cause the least impact on the landscape character due to the reduced sensitivity of the landscape along the roads and servitudes. The impact of Route 1 on visual receptors varies between residents, tourists and motorists. Route 1’s great advantage lies in the less significant visual impact on tourists and residents as compared to the other alternatives. The public association with transmission lines and major public roads is a common perception which makes the co-existence of these two features more acceptable.

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TABLES OF CONTENTS Page EXECUTIVE SUMMARY ...... i PROJECT DESCRIPTION ...... i DESCRIPTION OF THE AFFECTED ENVIRONMENT ...... ii FINDINGS AND RECOMMENDATIONS ...... iii LANDSCAPE CHARACTER SENSITIVITY ...... iii SIGNIFICANCE OF LANDSCAPE IMPACTS ...... iii VIEWER SENSITIVITY ...... v SIGNIFICANCE OF VISUAL IMPACTS ...... v VISUAL IMPACTS ON RESIDENTS ...... vi VISUAL IMPACTS ON TOURISTS ...... viii VISUAL IMPACTS ON MOTORISTS ...... x RECOMMENDED MITIGATION MEASURES ...... xi CONCLUSION ...... xii TABLES OF CONTENTS ...... xiii LIST OF FIGURES ...... xv LIST OF TABLES ...... xv LIST OF ABBREVIATIONS ...... xvi 1. INTRODUCTION ...... 1 1.1. BACKGROUND AND BRIEF ...... 1 1.2. STUDY AREA ...... 1 2. STUDY APPROACH ...... 3 2.1. INFORMATION BASE ...... 3 2.2. ASSUMPTIONS AND LIMITATIONS ...... 3 2.3. LEVEL OF CONFIDENCE ...... 3 2.4. METHOD ...... 3 3. PROJECT DESCRIPTION ...... 4 3.1. OVERVIEW OF DEVELOPMENT ...... 4 3.2. ALTERNATIVE ALIGNMENTS ...... 4 3.3. PROJECT COMPONENTS AND ACTIVITIES ...... 4 3.3.1. SUBSTATIONS ...... 4 3.3.2. CONSTRUCTION CAMPS AND LAY-DOWN YARDS ...... 5 3.3.3. ACCESS ROADS ...... 5 3.3.4. TRANSMISSION LINE ...... 5 3.4. VISUAL CHARACTERISTICS OF PROJECT COMPONENTS ...... 6 4. DESCRIPTION OF THE AFFECTED ENVIRONMENT ...... 10 4.1. VISUAL RESOURCE ...... 10 4.1.1. LANDSCAPE CHARACTER ...... 10 4.1.2. VISUAL CHARACTER ...... 14 KAPPA OMEGA 765kV LINE AND SUBSTATIONS UPGRADE KAP2012_KAPPA OMEGA VIA_2013-03-31 PREPARED BY AXIS LANDSCAPE ARCHITECTS

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4.1.2.1 Visual Quality ...... 14 4.1.2.2 Visual absorption capacity ...... 14 5. IMPACT ASSESSMENT ...... 35 5.1. SIGNIFICANCE OF LANDSCAPE IMPACT ...... 35 5.1.1. LANDSCAPE CHARACTER SENSITIVITY ...... 35 5.1.2. SEVERITY OF POTENTIAL LANDSCAPE IMPACTS ...... 37 5.2. SIGNIFICANCE OF VISUAL IMPACTS ...... 39 5.2.1. VIEWER SENSITIVITY ...... 39 5.2.1.1 Residents ...... 39 5.2.1.2 Tourists ...... 39 5.2.1.3 Motorists ...... 39 5.2.2. SEVERITY OF POTENTIAL VISUAL IMPACTS ...... 40 5.2.2.1 Potential visual impacts on residents ...... 41 5.2.2.2 Potential visual impacts on tourists ...... 43 5.2.2.3 Potential visual impacts on motorists ...... 45 6. RECOMMENDED MITIGATION MEASURES ...... 47 6.1. GENERAL ...... 47 6.2. ACCESS ROUTES ...... 47 6.3. TRANSMISSION TOWERS ...... 47 6.4. CLEARED SERVITUDES ...... 48 6.5. CONSTRUCTION CAMPS AND LAY DOWN YARDS ...... 48 7. CONCLUSION ...... 49 APPENDIX 1 ...... 50 LEVEL OF CONFIDENCE ...... 59 VISUAL RECEPTOR SENSITIVITY ...... 60 REFERENCES ...... 61

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LIST OF FIGURES Figure 1: Locality Plan ...... 2 Figure 2: Example of a construction camp ...... 7 Figure 3: Typical construction equipment ...... 8 Figure 4: Tower Types ...... 9 Figure 5: Landscape types ...... 12 Figure 6: Landscape types ...... 13 Figure 7: Landscape character of study area ...... 16 Figure 8: Landscape character of study area ...... 17 Figure 9: Landscape character of study area ...... 18 Figure 10: Landscape character of study area ...... 19 Figure 9: Photo Reference Map ...... 20 Figure 12: Photo plate 1 ...... 21 Figure 13: Photo plate 2 ...... 22 Figure 14: Photo plate 3 ...... 23 Figure 15: Photo plate 4 ...... 24 Figure 16: Photo plate 5 ...... 25 Figure 17: Photo plate 6 ...... 26 Figure 18: Photo plate 7 ...... 27 Figure 19: Photo plate 8 ...... 28 Figure 20: Photo plate 9 ...... 29 Figure 21: Photo plate 10 ...... 30 Figure 22: Photo plate 11 ...... 31 Figure 23: Photo plate 12 ...... 32 Figure 24: Photo plate 13 ...... 33 Figure 25: Photo plate 14 ...... 34 Figure 26: Alternative 1...... 51 Figure 27: Alternative 1A ...... 52 Figure 28: Alternative 1B ...... 53 Figure 29: Alternative 3 A ...... 54 Figure 30: Alternative 3 B ...... 55 Figure 31: Alternative 3 C ...... 56

LIST OF TABLES Table 1: Description of alternative alignments ...... 4 Table 2: Types and typical characteristics of proposed towers ...... 5 Table 3: Criteria of Visual Quality (FHWA, 1981) ...... 14 Table 4: Visual Quality of the regional landscape ...... 14 Table 5: Regional Visual Absorption Capacity evaluation ...... 15 Table 6: Significance of impacts ...... 35 Table 7: Landscape character sensitivity rating (Adapted from GOSW, 2006) ...... 35 Table 8: Landscape character sensitivity ...... 36 Table 9: Landscape impact – Altering the landscape character ...... 37 Table 10: Evaluation of alternative alignments ...... 49 Table 11: Confidence level chart and description ...... 59 Table 12: Visual receptor sensitivity ...... 60

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LIST OF ABBREVIATIONS

EIA Environmental Impact Assessment. FHWA Federal Highway Administration of the United States Department of Transportation. The publishers of the guide “Visual Impact Assessment for High Projects” 1981. LCA Landscape Character Assessment. LT Landscape Type VAC Visual Absorption Capacity VIA Visual Impact Assessment. ULI Urban Land Institute ZVI Zone of Visual Influence.

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1. INTRODUCTION Nzumbululo (Pty) Limited was appointed by Eskom (Pty) Ltd, as the independent environmental consultant to undertake the Environmental Impact Assessment (EIA) for the proposed establishment of the second Kappa Omega 765kV transmission line and substations upgrade. It is located between the Koruson (Kappa) Substation near Ceres to Sterekus (Omega) Substation near Koeberg. Axis Landscape Architecture cc was appointed by Nzumbululo (Pty) Limited as a sub- consultant to complete a Visual Impact Assessment. This Visual Impact Assessment (VIA) is a specialist study that forms part of the EIA and addresses the visual affects of the proposed transmission line on the receiving environment.

1.1. BACKGROUND AND BRIEF This VIA will conform to the requirements of a level three assessment which requires the realisation of the following objectives (Adapted from Oberholzer (2005)):

• Determination of the extent of the study area; • Description of the proposed project and the receiving environment; • Identification and description of the landscape character of the study area; • Identification of the elements of particular visual value and -quality that could be affected by the proposed project; • Identification of landscape- and visual receptors in the study area that will be affected by the proposed project and assess their sensitivity; • Indication of potential landscape- and visual impacts; • Assessment of the significance of the landscape- and visual impacts; • Recommendations of mitigation measures to reduce and/or alleviate the potential adverse landscape- and visual impacts.

1.2. STUDY AREA The study area includes the entire area covered by the alternative routes. The study area stretches from the Koruson (Kappa) Substation north of Ceres to Sterekus (Omega) Substation near Koeberg in Western Cape Province (Figure 1).

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Figure 1: Locality Plan

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2. STUDY APPROACH

2.1. INFORMATION BASE This assessment was based on information from the following sources:

• Topographical maps and GIS generated data were sourced from the Surveyor General, Surveys and Mapping in Mowbray, Cape Town and ECOGIS (2013) respectively; • Observations made and photographs taken during site visits; • Technical information received from Eskom Transmission; • Professional judgement based on experience gained from similar projects; and • Literature research on similar projects.

2.2. ASSUMPTIONS AND LIMITATIONS This assessment was undertaken during the conceptual stage of the project and is based on information available at the time.

• An exact commencement date for the construction phase is unknown. Construction is expected to commence as soon as approval is received from the relevant authorities; • The exact location, size of construction camps and material lay-down yards are not yet specified at this stage of the project. It is anticipated that construction camps will be set up on farms at central locations next to the preferred alignment. The construction camps will consist of temporary structures such as tents or temporary buildings. Ablution facilities will also be associated with a construction camp and are expected to be portable toilets and temporary shower facilities;

2.3. LEVEL OF CONFIDENCE The level of confidence assigned to the findings of this assessment is based on:

• The level of information available and/or understanding of the study area (rated 2); and • The information available and/or knowledge and experience of the project (rated 3). This visual impact assessment is rated with a general confidence level of 6. This rating indicates that the author’s general confidence in the accuracy of the findings is high (Table 11). Where the confidence level of specific findings is not regarded as high, it is noted in the last column of each impact assessment table.

2.4. METHOD A broad overview of the approach and methodology used in this assessment is provided below:

• The extent of the study area is determined and indicated in Figure1; • The site is visited to establish a photographic record of the site, views and areas of particular visual quality and or -value; • The project components and activities are described and assessed as potential elements of visual and landscape impacts; • The receiving environment is described in terms of its prevailing landscape- and visual character; • Landscape- and visual receptors that may be affected by the proposed project are identified and described; • The sensitivity of the landscape- and visual receptors is assessed; • The severity of the landscape- and visual impacts is determined; • The significance of the visual and landscape impacts is assessed; KAPPA OMEGA 765kV LINE AND SUBSTATIONS UPGRADE KAP2012_KAPPA OMEGA VIA_2013-03-31 PREPARED BY AXIS LANDSCAPE ARCHITECTS

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• Mitigation measures are proposed to reduce adverse impacts; and • The findings of the study are documented in this Visual Impact Assessment. 3. PROJECT DESCRIPTION

3.1. OVERVIEW OF DEVELOPMENT The project involves the construction of a 765kV transmission line from the Kappa Substation to the Omega Substation as well as the upgrade of the two substations. The servitude required for the development along the route is 80m wide and approximately 415km in length between the origin and the end of the line.

3.2. ALTERNATIVE ALIGNMENTS Table 1: Description of alternative alignments

ALTERNATIVES DESCRIPTION (Refer to Figure 1) Route 1 is proposed to run in a south westerly direction from the Kappa Substation north Route 1 of Ceres, passing through Ceres continuing straight until it reaches the Omega Substation. Deviation Route 1a is proposed to run from Wellington city centre and run in a North- Deviation Route 1a Western direction until it joins up with Route 2 East of Hermon. Deviation Route 1b diverts 15km after Deviation 1a from Route 1. It runs for about 18km Deviation Route 1b in a North Eastern direction from Wellington city centre until it joins up with Route 2 South - East of Malmesbury. Route 2 is proposed to run in a westerly direction with Route 1 until Piketberg Mountain Route 2 and then deviates from Route 1 in a South-Western direction until the Omega Substation Route 3 is proposed to run in a westerly direction from the Kappa Substation North of Route 3 Ceres until Aurora substation. It then continues from Aurora substation to the Omega substation following the coastline. Route 3a is proposed to run in a south easterly direction from the Aurora substation to Deviation Route 3a the Omega substation following the coastline. Route 3b is proposed to run in a south easterly direction from the Aurora substation to Deviation Route 3b the Omega substation following the coastline. Route 3c is proposed to run in a south easterly direction from the Aurora substation to Deviation Route 3c the Omega substation following the coastline.

3.3. PROJECT COMPONENTS AND ACTIVITIES Each project component and activity will affect the receiving environment differently and is therefore discussed separately. The following project components will occur during the construction and operational phases of the project and are identified as elements that may cause a potential landscape and/or visual impact:

3.3.1. SUBSTATIONS The two existing Substations, Kappa and Omega will be upgraded to accommodate the new 765kV Line. Each substation site will require a 765kV feeder bay, 400MVAr line reactors and extend the existing bus bar if necessary.

A level or stepped platform will be created with a buffer zone inside the fence. On the outskirts of this area will be several terminal gantries which are the termination points for the lines entering or leaving the substation. These structures will be approximately 45 meters tall.

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3.3.2. CONSTRUCTION CAMPS AND LAY-DOWN YARDS The construction phase is expected to continue for 12 months from the commencement date. Temporary construction camps will be present for the duration of the construction period. The appointed contractor will set up construction camps next to the proposed alignment where practical. The material lay-down yards is expected to be located adjacent the construction camps and will serve as storage areas for the construction material and equipment (Figure 2). Various types of construction equipment will be required to erect the transmission towers and suspend the electrical cables between them. A TLB, cement truck and mobile crane will be used during the const\ruction phase in conjunction with between 10 and 40 labourers (Figure 3).

3.3.3. ACCESS ROADS Where no access roads are available and vehicular access is required, roads will be constructed. Access may be by means of a two-track dirt road or a cleared corridor. It is expected that roads will be rehabilitated after the construction phase or maintained to facilitate access during periodic maintenance visits (Figure 2).

3.3.4. TRANSMISSION LINE The completed transmission line will connect the Kappa and Omega Substations. The direct linear distance between the two substations is approximately 415 km (Figure 1).

Four types of towers might be used depending on the terrain being crossed. The towers will consist of a lattice steel framework reaching a maximum height of 48 m with electrical cables suspended between them. The average spacing between the towers will be approximately 400 m. A working area of 100 m x 50 m will be cleared for each of the proposed towers. The Crossrope Suspension tower will be the preferred tower and the self-supporting strain tower will only be used where the alignment changes direction (Figure 4).

Table 2: Types and typical characteristics of proposed towers Guyed Cross Rope Self Supporting Double Circuit Suspension Suspension Tower Self supporting Type tower tower Suspension tower Maximum 33 m 48m 30 m 36 m Height Span 450 m 450 m 450 m 260 m Servitude 95 m 110 m 94 m 55m width

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3.4. VISUAL CHARACTERISTICS OF PROJECT COMPONENTS Visual character is based on human perception and the observer’s response to the relationships between and composition of the visible project components. The transmission line, i.e. the towers and the cables suspended between each tower, is the most visible and permanent project component and is discussed in this section. The towers have an industrial character enforced by the double steel pole and the electrical cables between the towers. It has a near monumental scale if compared to the predominantly rural and agricultural landscape. The entire transmission line will be perceived as a rhythmic arrangement of vertical towers forming a linear element through the landscape. The electrical cables emphasise the linear character of the transmission line but are easily absorbed in the background when viewed from distances greater than 10 km.

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Figure 2: Example of a construction camp

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Figure 3: Typical construction equipment

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Figure 4: Tower Types

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4. DESCRIPTION OF THE AFFECTED ENVIRONMENT Landscape and visual impacts may result from changes to the landscape. A distinction should be made between impacts on the visual resource (landscape) and on the viewers. The former are impacts on the physical landscape that may result in changes to landscape character while the latter are impacts on the viewers themselves and the views they experience.

4.1. VISUAL RESOURCE Visual resource is an encompassing term relating to the visible landscape and its recognisable elements, which through their co-existence, result in a particular landscape character.

4.1.1. LANDSCAPE CHARACTER The study area is consists of vacant and uninterrupted land as well as cultivated, residential, subsistence farming, and game farms. Extensive game faming and small stock farming activities is located more to the central northern side of the study area and agricultural activities to the south.

Subsistence farming activities are concentrated around the small towns. Human settlements are scattered throughout the study area and the landscape are degraded around these settlements.

The landscape character changes through the study area. The study area is divided into distinct landscape types which are areas within the study area that are relatively homogenous in character (Swanwick, 2002). Landscape types are distinguished by differences in topographical features, vegetation communities and patterns, land use and human settlement patterns.

· Ceres Karoo Region; · Ceres Mountain Region; and

· Swartland Region

Ceres Karoo Region The vegetation consists of the Lowland Succulent Karoo of the Succulent Karoo Biome. This represents an extremely arid vegetation type. The very low vegetation is dominated by the Vygie family. The lack of summer rains results in almost no grasses being prevalent in the vegetation type (Low and Rebelo, 1996).

The land use of this region are predominantly farming practices such as stock grazing and game farming.

Ceres Mountain Region

The Ceres Mountain Region consists primarily of very steep sided high mountains with lower valleys between them. The vegetation falls within the Mountain Fynbos of the Fynbos Biome (Low and Rebelo, 1996). The vegetation is generally low except where it has been replaced with orchards and agro-forestry activities.

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Human intrusion is limited to the valleys that have been largely modified from natural vegetation to agricultural lands for grazing and fruit production.

Swartland Region

The Swartland Region consist of a broad, extensive horizontal scale with little vertical definition due to the flat to gently sloping topography covered with arable lands, shrubs and grassland. The vegetation falls within the Fynbos Biome. It consists of a mixture of West Coast Renosterveld and Sand Plain Fynbos (Low and Rebelo, 1996). Most of this vegetation has been ploughed up for wheat and viticulture. The views within this landscape are extensive and only interrupted in the east by the Cape Mountains. The rolling and undulating landscape interrupts these views at a local level when viewed from localised depressions.

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Figure 5: Landscape types

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Figure 6: Landscape types

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4.1.2. VISUAL CHARACTER Visual character is based on human perception and the observer’s response to the relationships between and composition of the landscape, the land uses and identifiable elements in the landscape. The description of the visual character includes an assessment of the scenic attractiveness regarding those landscape attributes that have aesthetic value and contribute significantly to the visual quality of the views, vistas and/or viewpoints of the study area.

4.1.2.1 Visual Quality Visual quality is a qualitative evaluation of the composition of landscape components and their excellence in scenic attractiveness. Many factors contribute to the visual quality of the landscape and are grouped under the following main categories (Table 4) that are internationally accepted indicators of visual quality (FHWA, 1981):

Table 3: Criteria of Visual Quality (FHWA, 1981) INDICATOR CRITERIA The memorability of the visual impression received from contrasting landscape elements as they Vividness combine to form a striking and distinctive visual pattern. The integrity of visual order in the natural and man-built landscape, and the extent to which the Intactness landscape is free from visual encroachment. The degree to which the visual resources of the landscape join together to form a coherent, Unity harmonious visual pattern. Unity refers to the compositional harmony of inter-compatibility between landscape elements.

The landscape is allocated a rating from an evaluation scale of 1 to 7 and divided by 3 to get an average. The evaluation scale is as follows: Very Low =1; Low =2; Moderately Low =3; Moderate =4; Moderately High =5; High =6; Very High =7;

The regional landscape is assessed against each indicator separately. All three indicators should be high to obtain a high visual quality. The evaluation is summarised in Table 4.

Table 4: Visual Quality of the regional landscape LANDSCAPE VIVIDNESS INTACTNESS UNITY VISUAL QUALITY TYPE Ceres Karoo Region 4 4 4 Moderate

Ceres Mountain Region 6 5 6 Moderately High

Swartland Region 5 4 4 Moderate

The higher visual quality can be attributed to areas with less human intervention and with undisturbed natural features. The scattered agricultural practices and the informal settlements are impacting the regional visual quality.

4.1.2.2 Visual absorption capacity Visual Absorption Capacity (VAC) signifies the ability of the landscape to accept additional human intervention without serious loss of character and visual quality or value. VAC is founded on the characteristics of the physical environment such as:

• Degree of visual screening: ° A degree of visual screening is provided by landforms, vegetation cover and/or structures such as buildings. For example, a high degree of visual screening is present in an area that is mountainous and is covered with a forest compared to an undulating an mundane landscape covered in grass;

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• Terrain variability: ° Terrain variability reflects the magnitude of topographic elevation and diversity in slope variation. A highly variable terrain will be recognised as one with great elevation differences and a diversity of slope variation creating talus slopes, cliffs and valleys. An undulating landscape with a monotonous and repetitive landform will be an example of a low terrain variability; • Land cover: ° Land cover refers to the perceivable surface of the landscape and the diversity of patterns, colours and textures that are presented by the particular land cover (i.e. urbanised, cultivated, forested, etc.); A basic rating system is used to evaluate the three VAC parameters. The values are relative and relate to the type of project that is proposed and how it may be absorbed in the landscape (Table 5). A three value range is used; three (3) being the highest potential to absorb an element in the landscape and one (1) being the lowest potential. The values are counted together and categorised in a high, medium or low VAC rating.

Table 5: Regional Visual Absorption Capacity evaluation LANDSCAPE TYPE VISUAL TERRAIN LAND VAC SCREENING VARIABILITY COVER Ceres Karoo Region 1 2 1 low

Ceres Mountain Region 2 2 2 moderate

Swartland Region 1 1 1 low

The VAC of the study area is considered to be moderately low and provides some visual screening capacity for this project. The moderately low VAC relates to the topography and vegetation. The regular forms and associated vertical posture of the proposed alignment are unlike the undulating and horizontal appearance of the topography.

The less prominent project components such as access roads are expected to be visually absorbed to a greater degree in the landscape. The relative modest scale and extent of the project components are more readily accepted and will not create major alterations to the landscape character.

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Figure 7: Landscape character of study area

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Figure 8: Landscape character of study area

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Figure 9: Landscape character of study area

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Figure 10: Landscape character of study area

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Figure 11: Photo Reference Map

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Figure 12: Photo plate 1

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Figure 13: Photo plate 2

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Figure 14: Photo plate 3

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Figure 15: Photo plate 4

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Figure 16: Photo plate 5

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Figure 17: Photo plate 6

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Figure 18: Photo plate 7

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Figure 19: Photo plate 8

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Figure 20: Photo plate 9

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Figure 21: Photo plate 10

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Figure 22: Photo plate 11

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Figure 23: Photo plate 12

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Figure 24: Photo plate 13

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Figure 25: Photo plate 14

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5. IMPACT ASSESSMENT The significance of impacts is a comparative function relating to the severity of the identified impacts on the respective receptors. The significance of an impact is considered high should a highly sensitive receptor be exposed to a highly severe impact (Table 6).

Table 6: Significance of impacts

RECEPTOR IMPACT SEVERITY SENSITIVITY LOW MEDIUM HIGH

LOW No significance Low Low

MEDIUM Low Medium Medium

HIGH Low Medium High

5.1. SIGNIFICANCE OF LANDSCAPE IMPACT

5.1.1. LANDSCAPE CHARACTER SENSITIVITY The sensitivity of the landscape character is an indication of “…the degree to which a particular landscape can accommodate change from a particular development, without detrimental effects on its character” (GLVIA, 2002). A landscape with a high sensitivity would be one that is greatly valued for its aesthetic attractiveness and/or have ecological, cultural or social importance through which it contributes to the inherent character of the visual resource. The assessment of the landscape is substantiated through professional judgement and informed reasoning which is based on the landscape character assessment in Section 4. A landscape sensitivity rating was adapted from GOSW (2006) (Table 7) and applied in the classification of the study area into different sensitivity zones.

Table 7: Landscape character sensitivity rating (Adapted from GOSW, 2006)

DESCRIPTION These landscapes are likely to: ° Have distinct and well-defined landforms; ° Have a strong sense of enclosure; Low sensitivity ° Provide a high degree of screening; ° Have been affected by extensive development or man-made features; ° Have reduced tranquillity; ° Are likely to have little inter-visibility with adjacent landscapes; and ° Exhibit no or a low density of sensitive landscape features that bare visual value. These landscapes are likely to: ° Have a moderately elevated topography with reasonably distinct landforms that Moderately sensitivity provides some sense of enclosure; ° Have been affected by several man-made features; ° Have limited inter-visibility with adjacent landscapes; and ° Exhibit a moderate density of sensitive landscape features that bare visual value. These landscapes are likely to: ° Consist mainly of undulating plains and poorly defined landforms; Highly sensitivity ° Be open or exposed with a remote character and an absence of man-made features; ° Are often highly visible from adjacent landscapes; and ° Exhibit a high density of sensitive landscape features that bare visual value.

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The majority of the study area is considered to have a moderate landscape character sensitivity due to the undulating topography and relative undeveloped condition of the landscape, the generally high visual quality and the related tourism value that is placed on the visual resource. Moderate terrain variability mainly occurs through the study area where a moderately low VAC can be expected. Generally the vegetation cover is shrubland and scattered trees which will provide very little visual screening for the proposed transmission line. The landscape character is considered moderately susceptible to change, whether it is a low intensity change over an extensive area or an acute change over a limited area. Generally, the vegetation occurring in the study area is rigid and recovers very slowly from surface disturbances.

Table 8: Landscape character sensitivity PREVAILING LOCALISED LANDSCAPE AREA OF DISTURBANCE IN REDUCTION LANDSCAPE TYPE (LT) CHARACTER LT OF SENSITIVITY SENSITIVITY Ceres Karoo Region Moderate • Existing Power lines Low • Degraded areas around settlements Ceres Mountain Region High Degraded areas around settlements Low

Swartland Region Moderate • The agricultural fields Low • Informal Settlements

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5.1.2. SEVERITY OF POTENTIAL LANDSCAPE IMPACTS Landscape impacts are alterations to the fabric, character, visual quality and/or visual value which will either positively or negatively affect the landscape character. During the construction and operational phases, the project components are expected to impact on the landscape character of the landscape types. The magnitude/severity of this intrusion is measured against the scale of the project, the permanence of the intrusion and the loss in visual quality, -value and/or VAC.

Table 9: Landscape impact – Altering the landscape character

Extent Significance Significance Nature of Duration of Severity of Probability Level of Activity of without with Impact Impact Impact of Impact Confidence Impact Mitigation Mitigation Construction phase

Route 1 Moderate Definite Moderate Low High

Deviation Route 1a Moderate Definite Moderate Low High Negative – Deviation Impacting on Moderate Definite Moderate Low High Route 1b the visual quality of the Route 2 landscape due High Definite High Moderate High to the Permanent if Local presence of not mitigated Route 3 foreign High Definite High Moderate High elements and Deviation a loss of Route 3a vegetation High Definite High Moderate High cover. Deviation Route 3b Moderate Definite Moderate Low High

Deviation Route 3c Moderate Definite Moderate Low High

Operational phase

Route 1 Low Definite Low Low High

Deviation Route 1a Low Definite Low Low High Deviation Low Definite Low Low High Route 1b Negative – Impacting on Route 2 the visual High Definite High Moderate High quality of the Local Permanent landscape due Route 3 the presence High Definite High Moderate High of a power Deviation line. Route 3a High Definite High Moderate High

Deviation Route 3b Moderate Definite Moderate Low High

Deviation Route 3c Moderate Definite Moderate Low High

The extent of the disturbances will generally affect a relative large footprint area. Access roads to the towers are expected to be a two-track dirt road which will create KAPPA OMEGA 765kV LINE AND SUBSTATIONS UPGRADE KAP2012_KAPPA OMEGA VIA_2013-03-31 PREPARED BY AXIS LANDSCAPE ARCHITECTS

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the minimum disturbance. During construction, the area around the individual towers will be disturbed.

Servitudes will generally be cleared of higher growing and dense vegetation to reduce biomass that may cause a fire hazard if ignited. The complete removal of high growing vegetation and scrubs will result in disturbed areas of exposed soil and difference in texture. The exposed soil and change in texture will contrast severely with the intact vegetation around the disturbance footprint and servitudes.

Considering the moderately low VAC throughout most of the study area, the undisturbed condition of parts of the landscape and the recovery rate of the endemic vegetation, the severity of landscape impact during the construction stage is expected to be moderate for Route 1, Deviation Route 1a and 1b and high for all the other alternatives. The impact will extend over the entire length of the different alignments and may vary in degrees of severity along the linear length as it transects landscape types of varying VAC. Surface disturbances are also minimised through, for example, utilising existing roads. Operational phase Surface disturbances created during construction may remain for an extended period during the operational phase. These are seen as residual affects carried forward from the construction phase and can be completely or substantially mitigated if treated appropriately during the construction phase. An additional impact will be caused as a result of the presence of the completed transmission line, i.e. that of the evenly spaced towers of the lines, buildings and structures. The industrial character and the near monumental vertical scale of the towers will contrast with the diverse landscape character that prevails through most of the study area.

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5.2. SIGNIFICANCE OF VISUAL IMPACTS

5.2.1. VIEWER SENSITIVITY Within the receiving environment, specific viewers (visual receptors) experience different views of the visual resource and value it differently. They will be affected because of alterations to their views due to the proposed project. The visual receptors are grouped according to their similarities. The visual receptors included in this study are:

• Residents; • Tourists; and • Motorists. To determine visual receptor sensitivity a commonly used rating system is utilised. This is a generic classification of visual receptors and enables the visual impact specialist to establish a logical and consistent visual receptor sensitivity rating for viewers who are involved in different activities without engaging in extensive public surveys.

5.2.1.1 Residents Residents of the affected environment are classified as visual receptors of high sensitivity owing to their sustained visual exposure to the proposed development as well as their attentive interest towards their living environment.

5.2.1.2 Tourists Tourists are regarded as visual receptors of exceptional high sensitivity. Their attention is focused towards the landscape which they essentially utilise for enjoyment purposes and appreciation of the quality of the landscape.

5.2.1.3 Motorists Motorists are generally classified as visual receptors of low sensitivity due to their momentary view and experience of the proposed development. As a motorist’s speed increases, the sharpness of lateral vision declines and the motorist tends to focus on the line of travel (USDOT, 1981). This adds weight to the assumption that under normal conditions, motorists will show low levels of sensitivity as their attention is focused on the road and their exposure to roadside objects is brief.

Motorists on the scenic routes in the study area will present a higher sensitivity. Their reason for being in the landscape is similar to that of the tourists and they will therefore be categorised as part of the tourist viewer group.

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5.2.2. SEVERITY OF POTENTIAL VISUAL IMPACTS Severity of visual impact refers to the magnitude of change to specific visual receptor’s views and/or experience of the landscape. Severity of visual impact is influenced by the following factors:

• The viewer’s exposure to the project: ° Distance of observers from the proposed project; ° The visibility of the proposed project (ZVI); ° Number of affected viewers; and ° Duration of views to development experienced by affected viewers. • Degree of visual intrusion created by the project. Empirical research indicates that the visibility of a transmission tower and hence the severity of visual impact, decreases as the distance between the observer and the tower increases. The landscape type, through which the transmission line crosses, can mitigate the severity of visual impact through topographical or vegetative screening. Bishop et al (1988) noticed that in some cases the tower may dominate the view for example, silhouetted against the skyline, or in some cases be absorbed in the landscape. A complex landscape setting with a diverse land cover and topographical variation has the ability to decrease the severity of visual impact more than a mundane landscape (Bishop et al, 1985).

The Zone of Visual Influence (ZVI) is determined through a Geographical Information System (GIS). The result reflects a shaded pattern which identifies the areas that are expected to experience views of the proposed alignments. The ZVI is limited to 5 km from the proposed locations. A visibility analysis has been completed for each of the three alternative alignments and deviation routes (APPENDIX 1). According to Bishop et al (1988), visual receptors within 1 km from the alignment are most likely to experience the highest degree of visual intrusion, hence contributing to the severity of the visual impact. This is considered as the zone of highest visibility after which the degree of visual intrusion decreases rapidly at distances further away. In order to assess the extent and degree of visibility in the visual envelope, a Geographical Information System (GIS) was utilised. A visibility analysis was performed which provides the following information (Figure 26 - Figure 31).

• The areas within the visual envelope that may experience views of the proposed project; and • The degree of visibility in terms of the percentage of the proposed project that will be visible from a specific location. The GIS performs an analysis for a series of elevated observer points which represents the height of the entire power line in a digital elevation model (DEM). This results in a visibility map with the degree of visibility illustrated by a colour.

The visibility analyses consider worst-case scenarios, using line-of-sight, based on topography alone. The screening capability of vegetation is not captured in the base model of the DEM and is therefore not considered in these results.

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5.2.2.1 Potential visual impacts on residents Extent Significance Significance Nature of Duration of Severity Probability Level of Activity of without with Impact Impact of Impact of Impact Confidence Impact Mitigation Mitigation Construction phase

Route 1 Moderate Definite Low Low High

Deviation Route 1a Moderate Definite Low Low High

Deviation Moderate Definite Low Low High Route 1b Negative – Construction Route 2 camp and Moderate Definite Low Low High lay-down Local Temporary yard may Route 3 cause Low Definite Low Low High unsightly Deviation views. Route 3a Low Definite Low Low High

Deviation Route 3b Low Definite Low Low High

Deviation Route 3c Low Definite Low Low High

Operational phase

Route 1 Moderate Definite Low Low High

Deviation Route 1a Moderate Definite Low Low High Negative – Deviation The Moderate Definite Low Low High Route 1b presence of a power line Route 2 intrudes on Moderate Definite Low Low High existing Local Permanent views and Route 3 spoils the Low Definite Low Low High open Deviation panoramic Route 3a views of the Low Definite Low Low High landscape. Deviation Route 3b Low Definite Low Low High

Deviation Route 3c Low Definite Low Low High

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The cleared sites, construction camps and material lay-down yard will appear unsightly and out of character. Large scale construction elements such as cranes, will be highly visible and increase awareness of the construction activity over a considerable area. The visual intrusion caused during the construction stage will be moderate, but will be temporary in nature. Operational phase The residents of the residential areas and farming communities next to the power lines may experience a moderate degree of visual intrusion due to their proximity to all the Alternatives.

The presence of a transmission line in the visual field of the residents in this part of the study area will spoil the uncluttered panoramic views they currently experience. The silhouette of a transmission line on the horizon will be visible from a great distance and thus increase the ZVI considerably, potentially impacting on more residents.

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5.2.2.2 Potential visual impacts on tourists Extent Significance Significance Nature of Duration of Severity Probability Level of Activity of without with Impact Impact of Impact of Impact Confidence Impact Mitigation Mitigation Construction phase

Route 1 Moderate Definite Moderate Low High

Deviation Route 1a Moderate Definite Moderate Low High Negative – Deviation Route Construction 1b camp and Moderate Definite Moderate Low High lay-down yard may Route 2 At a cause High Definite High Moderate High number unsightly Temporary of point Route 3 views and locations High Definite High Moderate High spoil the Deviation Route undisturbed 3a views over High Definite High Moderate High the Deviation Route landscape. 3b High Definite High Moderate High

Deviation Route 3c High Definite High Moderate High Operational phase

Route 1 Moderate Definite Moderate Low High

Deviation Route 1a Moderate Definite Moderate Low High Deviation Route 1b Negative – Moderate Definite Moderate Low High The Route 2 presence of a power line High Definite High Moderate High intrudes on Local Permanent Route 3 existing High Definite High Moderate High views Deviation Route of the 3a landscape High Definite High Moderate High

Deviation Route 3b High Definite High Moderate High Deviation Route 3c High Definite High Moderate High

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Their exposure to possible unsightly views of the construction camps and the associated activity will however be minimal and localised.

The potential visual impact on tourists during the construction phase of the proposed project can be mitigated with relative ease except for Route 2 and 3 with its deviations. The greatest factor to consider is the location of the construction camps from potential views that may be experienced from scenic routes or tourist hotspots. Operational phase Considering the extent of the proposed alternatives, a number of tourists will be affected during their visit to the study area. Although it is difficult to pinpoint particular locations in the study area that are of specific tourist value, since the entire study area bares some value, the most obvious concentration of tourists can be expected in the northern central part of the study area. For these tourists, Route 2 and 3 with its deviations will create alterations to their views. The presence of a transmission line in this undeveloped landscape will spoil the views that are experiencing. It can be concluded that Route 2 and 3 with its deviations will cause a high visual intrusion in the views expected by tourists travelling through the study area.

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5.2.2.3 Potential visual impacts on motorists Extent Significance Significance Nature of Duration Severity Probability Level of Activity of without with Impact of Impact of Impact of Impact Confidence Impact Mitigation Mitigation Construction phase

Route 1 Moderate Definite Low Low High

Deviation Route 1a Moderate Definite Low Low High Deviation Route 1b Moderate Definite Low Low High

Negative – Route 2 At a Intruding on Moderate Definite Low Low High number existing Short period of point Route 3 views of the locations Moderate Definite Low Low High landscape. Deviation Route 3a Moderate Definite Low Low High Deviation Route 3b Moderate Definite Low Low High Deviation Route 3c Moderate Definite Low Low High Operational phase

Route 1 Moderate Definite Low Low High

Deviation Route 1a Moderate Definite Low Low High

Deviation Route 1b Moderate Definite Low Low High

Route 2 Negative – Intruding on Moderate Definite Low Low High Short period existing Local

Route 3 views of the Moderate Definite Low Low High landscape. Deviation Route 3a Moderate Definite Low Low High

Deviation Route 3b Moderate Definite Low Low High

Deviation Route 3c Moderate Definite Low Low High

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The presence of the construction camp and lay-down yards may create unsightly views. Motorists’ visual exposure to the impact will be brief and the severity of visual impact will be moderately low. The significance of potential visual impact is expected to be low. Operational phase The N7, R27, R47, R44 and R46 are the most prominent, carrying the highest volume of traffic. Route 3 with its deviations will be the most visible from the R27. The severity and significance of visual impact for all the proposed routes on motorists will be moderate.

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6. RECOMMENDED MITIGATION MEASURES The aim of mitigation is to reduce or alleviate the intrusive contrast between the proposed project components and activities, and the receiving landscape to a point where it is acceptable to visual and landscape receptors.

6.1. GENERAL • Proceed with construction of the substation during the off peak tourism season; • Where areas are going to be disturbed through the destruction of vegetation, for example the establishment of the construction camp, the vegetation occurring in the area to be disturbed must be salvaged and kept in a controlled environment such as a nursery, for future re-planting in the disturbed areas as a measure of rehabilitation;

6.2. ACCESS ROUTES • Make use of existing access roads where possible; • Where new access roads are required, the disturbance area should be kept as small as possible. A two-track dirt road will be the most preferred option; • Locate access routes so as to limit modification to the topography and to avoid the removal of established vegetation; • Avoid crossing over or through ridges, rivers, pans or any natural features that have visual value. This also includes centres of floral endemism and areas where vegetation is not resilient and takes extended periods to recover; • Maintain no or minimum cleared road verges; • Access routes should be located on the perimeter of disturbed areas such as cultivated/fallow lands as not to fragment intact vegetated areas; and • If it is necessary to clear vegetation for a road, avoid doing so in a continuous straight line. Alternatively, curve the road in order to reduce the visible extent of the cleared corridor.

6.3. TRANSMISSION TOWERS • Avoid crossing over or through ridges, rivers, pans or any natural features that have visual value. This also includes centres of floral endemism and areas where vegetation is not resilient and takes extended periods to recover; • The preferred type of tower is the compact cross-rope or the cross-rope suspension tower. These two tower types are the most visually permeable and create an extremely low degree of visual obstruction; • Avoid changing the alignment’s direction too often in order to minimise the use of the self- supporting strain tower. This tower type is the most visually intrusive as the steel lattice structure is more dense than the other two tower types, hence creating more visual obstruction; • Plan the route so that the route crosses existing main routes as close to 90° as possible as this will reduce the time that the line is in the viewshed of the passing motorist / viewer; • Where practically possible, provide a minimum of 1 km buffer area between the transmission line and sensitive visual receptors; and • Rehabilitate disturbed areas around pylons as soon as practically possible after construction. This should be done to restrict extended periods of exposed soil. • Align the route along the footslopes of hills, mountains and ridges. This is to maximise the backdrop screening effect of the topography that will reduce presenting the Transmission line in silhouette. • Plan the route so that the route crosses existing main routes as close to 90° as possible as this will reduce the time that the line is in the viewshed of the passing motorist / viewer.

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• Align the route through areas of existing visual clutter and disturbance such as alongside railway lines, existing Transmission lines, roads and other visible infrastructure, rather than through pristine or undisturbed areas where possible. However, the cumulative effect of adding to the visual clutter prior to the final placement should be evaluated • Avoid areas where the current land uses, such as game farm, lodges, etc. often rely on the absence of human visual intrusion. • The galvanising of the pylon should be allowed to weather to a matt grey finish rather than be painted silver, as is often the case. This allows the structures to blend in with the existing environmental colours more readily than the silver that is highly reflective especially early morning and late afternoon. Should it be necessary to paint, it is recommended that a neutral matt finish be used.

6.4. CLEARED SERVITUDES • Locate the alignment and the associated cleared servitude so as to avoid the removal of established vegetation; and • Avoid a continuous linear path of cleared vegetation that would strongly contrast with the surrounding landscape character. Feather the edges of the cleared corridor to avoid a clearly defined line through the landscape.

6.5. CONSTRUCTION CAMPS AND LAY DOWN YARDS • If practically possible, locate construction camps in areas that are already disturbed or where it isn’t necessary to remove established vegetation like for example, naturally bare areas; • Utilise existing screening features such as dense vegetation stands or topographical features to place the construction camps and lay-down yards out of the view of sensitivity visual receptors; • Keep the construction sites and camps neat, clean and organised in order to portray a tidy appearance; and • Screen the construction camp and lay-down yards by enclosing the entire area with a dark green or black shade cloth of no less than 2 m height.

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7. CONCLUSION The three alternative Routes have been evaluated against international accepted criteria to determine the impact they will have on the landscape character and the viewers that have been identified in the study area.

Table 10: Evaluation of alternative alignments

ALTERNATIVES PREFERENCE RATING Route 1 1

Deviation Route 1a 2

Deviation Route 1b 3

Route 2 4

Route 3 6

Deviation Route 3a 8

Deviation Route 3b 7

Deviation Route 3c 5

Route 1 is regarded as the most preferred alternative. Its alignment along the existing transmission line and transmission servitude is considered to cause the least impact on the landscape character due to the reduced sensitivity of the landscape along the roads and servitudes.. The impact of Route 1 on visual receptors varies between residents, tourists and motorists. Route 1’s great advantage lies in the less significant visual impact on tourists and residents as compared to the other alternatives. The public association with transmission lines and major public roads is a common perception which makes the co- existence of these two features more acceptable.

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APPENDIX 1 Figure 26 - Figure 31 reflects the results of a visibility assessment, carried out using GIS software. The results provide a clear interpretation of the extent of the visual influence and also provide an indication of the land use that can be expected in the affected areas. Through the integration of different GIS datasets it is possible to identify areas along the alternative alignments that may cause higher impacts.

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Figure 26: Alternative 1

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Figure 27: Alternative 1A

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Figure 28: Alternative 1B

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Figure 29: Alternative 3 A

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Figure 30: Alternative 3 B

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Figure 31: Alternative 3 C

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GLOSSARY OF TERMS

Aesthetics The science or philosophy concerned with the quality of sensory experience. (ULI, 1980) Horizon contour A line that encircles a development site and that follows ridgelines where the sky forms the backdrop and no landform is visible as a background. This is essentially the skyline that when followed through the full 360- degree arc as viewed from a representative point on the site defines the visual envelope of the development. This defines the boundary outside which the development would not be visible. Landscape This covers the gathering of information during the desktop study and characterisation/ field survey work relating to the existing elements, features, and extent of character the landscape (character). It includes the analysis and evaluation of the above and the supporting illustration and documentary evidence. Landscape Refers to the state of the landscape of the area making up the site and condition that of the study area in general. Factors affecting the condition of the landscape can include the level maintenance and management of individual landscape elements such as buildings, woodlands etc and the degree of disturbance of landscape elements by non-characteristics elements such as invasive tree species in a grassland or car wrecks in a field. Landscape impact Changes to the physical landscape resulting from the development that include; the removal of existing landscape elements and features, the addition of new elements associated with the development and altering of existing landscape elements or features in such as way as to have a detrimental affect on the value of the landscape. Landscape unit A landscape unit can be interpreted as an “outdoor room” which are enclosed by clearly defined landforms or vegetation. Views within a landscape unit are contained and face inward. Sense of place That distinctive quality that makes a particular place memorable to the visitor, which can be interpreted in terms of the visual character of the landscape. A more emotive sense of place is that of local identity and attachment for a place “which begins as undifferentiated space [and] becomes place as we get to know it better and endow it with value” (Tuan 1977)1. Viewer exposure The extent to which viewers are exposed to views of the landscape in which the proposed development will be located. Viewer exposure considers the visibility of the site, the viewing conditions, the viewing distance, the number of viewers affected, the activity of the viewers (tourists or workers) and the duration of the views. Viewer sensitivity The assessment of the receptivity of viewer groups to the visible landscape elements and visual character and their perception of visual quality and value. The sensitivity of viewer groups depends on their activity and awareness within the affected landscape, their preferences, preconceptions and their opinions. Visual absorption The inherent ability of a landscape to accept change or modification to capacity (VAC) the landscape character and/or visual character without diminishment of the visual quality or value, or the loss of visual amenity. A high VAC rating implies a high ability to absorb visual impacts while a low VAC implies a low ability to absorb or conceal visual impacts.

1 Cited in Climate Change and Our 'Sense of Place', http://www.ucsusa.org/greatlakes/glimpactplace.html KAPPA OMEGA 765kV LINE AND SUBSTATIONS UPGRADE KAP2012_KAPPA OMEGA VIA_2013-03-31 PREPARED BY AXIS LANDSCAPE ARCHITECTS

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Visual amenity The notable features such as hills or mountains or distinctive vegetation cover such as forests and fields of colour that can be identified in the landscape and described. Also included are recognised views and viewpoints, vistas, areas of scenic beauty and areas that are protected in part for their visual value. Visual character This addresses the viewer response to the landscape elements and the relationship between these elements that can be interpreted in terms of aesthetic characteristics such as pattern, scale, diversity, continuity and dominance. Visual contour The outer perimeter of the visual envelope determined from the site of the development. The two dimensional representation on plan of the horizon contour. Visual contrast The degree to which the physical characteristics of the proposed development differ from that of the landscape elements and the visual character. The characteristics affected typically include: • Volumetric aspects such as size, form, outline and perceived density; • Characteristics associated with balance and proportion such scale, diversity, dominance, continuity; • Surface characteristics such as colour, texture, reflectivity; and • Luminescence or lighting. Visual envelope The approximate extent within which the development can be seen. The extent is often limited to a distance from the development within which views of the development are expected to be of concern. Visual impact Changes to the visual character of available views resulting from the development that include: obstruction of existing views; removal of screening elements thereby exposing viewers to unsightly views; the introduction of new elements into the view shed experienced by visual receptors and intrusion of foreign elements into the view shed of landscape features thereby detracting from the visual amenity of the area. Visual impact A specialist study to determine the visual effects of a proposed assessment development on the surrounding environment. The primary goal of this specialist study is to identify potential risk sources resulting from the project that may impact on the visual environment of the study area, and to assess their significance. These impacts include landscape impacts and visual impacts.

Visual quality An assessment of the aesthetic excellence of the visual resources of an area. This should not be confused with the value of these resources where an area of low visual quality may still be accorded a high value. Typical indicators used to assess visual quality are vividness, intactness and unity. For more descriptive assessments of visual quality attributes such as variety, coherence, uniqueness, harmony, and pattern can be referred to. Visual receptors Includes viewer groups such as the local community, residents, workers, the broader public and visitors to the area, as well as public or community areas from which the development is visible. The existing visual amenity enjoyed by the viewers can be considered a visual receptor such that changes to the visual amenity would affect the viewers. Zone of visual The extent of the area from which the most elevated structures of the influence proposed development could be seen and may be considered to be of interest (see visual envelope).

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LEVEL OF CONFIDENCE Table 11: Confidence level chart and description

CONFIDENCE LEVEL CHART

Information, knowledge and experience of the project 3b 2b 1b

3a 9 6 3

2a 6 4 2 study area study Information, and Information, and knowledge of the of knowledge 1a 3 2 1

3a – A high level of information is available of the study area in the form of recent aerial photographs, GIS data, documented background information and a thorough knowledge base could be established during site visits, surveys etc. The study area was readily accessible. 2a – A moderate level of information is available of the study area in the form of aerial photographs GIS data and documented background information and a moderate knowledge base could be established during site visits, surveys etc. Accessibility to the study area was acceptable for the level of assessment.

1a – Limited information is available of the study area and a poor knowledge base could be established during site visits and/or surveys, or no site visit and/or surveys were carried out.

3b – A high level of information and knowledge is available of the project in the form of up-to-date and detailed engineering/architectural drawings, site layout plans etc. and the visual impact assessor is well experienced in this type of project and level of assessment.

2b – A moderate level of information and knowledge is available of the project in the form of conceptual engineering/architectural drawings, site layout plans etc. and/or the visual impact assessor is moderately experienced in this type of project and level of assessment. 1b – Limited information and knowledge is available of the project in the form of conceptual engineering/architectural drawings, site layout plans etc. and/or the visual impact assessor has a low experience level in this type of project and level of assessment. (Adapted from Oberholzer. B, 2005)

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VISUAL RECEPTOR SENSITIVITY Table 12: Visual receptor sensitivity

VISUAL DEFINITION RECEPTOR ND SENSITIVITY (BASED ON THE GLVIA 2 ED PP90-91)

Views from major tourist or recreational attractions or viewpoints promoted for or related to Exceptional appreciation of the landscape, or from important landscape features.

Users of all outdoor recreational facilities including public and local roads or tourist routes whose attention or interest may be focussed on the landscape; High Communities where the development results in changes in the landscape setting or valued views enjoyed by the community; Residents with views affected by the development. Moderate People engaged in outdoor sport or recreation (other than appreciation of the landscape); People at their place of work or focussed on other work or activity; Low Views from urbanised areas, commercial buildings or industrial zones; People travelling through or passing the affected landscape on transport routes. Negligible Views from heavily industrialised or blighted areas (Uncommon)

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REFERENCES

BLM (Bureau of Land Management). (1986). Handbook H-8431-1, Visual Resource Contrast Rating. U.S. Department of the Interior BLM. http://www.blm.gov/nstc/VRM/vrmsys.html

Government Office of the South West - England (2006). Using landscape sensitivity for renewable energy. REvision 2010 – Empowering the region [Online]. http://www.oursouthwest.com/revision2010/lca_methodology_windbiomass.doc [Accessed 8 November 2006]

Landscape Institute and the Institute of Environmental Assessment and Management. (2002). Guidelines for Landscape and Visual Impact Assessment (GLVIA). Second Edition, E & FN Spon Press.

M. Hill, J. Briggs, P. Minto, D. Bagnall, K. Foley, A.Williams. (March 2001). Guide to Best Practice in Seascape Assessment. Maritime (Ireland / Wales) INTERREG Programme- Building Bridges.

Oberholzer, B. (2005). Guideline for involving visual and aesthetic specialists in EIA processes: Edition 1. CSIR Report No ENV-S-C 2005 053 R. Republic of South Africa, Provincial Government of the Western Cape, Department of Environmental Affairs and Development Planning, Cape Town.

Swanwick, C. Department of Landscape, University of Sheffield and Land Use Consultants. (2002). Landscape Character Assessment:: Guidance for England and Scotland. The Countryside Agency / Scottish Natural Heritage.

Van Riet, W., Claassens, P., Van Rensburg, J., Van Viegen, T., Du Plessis, L. 1997. Environmental Potential Atlas for South Africa. The Department of Environmental Affairs and Tourism in conjunction with The Geographic Information Systems Laboratory CC and the University of Pretoria. J.L. van Schaik.

Van Rooyen, M.W. 2002. Management of the old field vegetation in the Namaqua National Park, South Africa: conflicting demands of conservation and tourism. Published paper from The Geographical Journal, Vol. 168, No.3, September 2002, pp. 211-223.

U.S.D.O.T., Federal Highway Administration, Office of Environmental Policy. (March 1981). Visual Impact Assessment for Highway Projects. U. S. Department of Transportation Washington D. C.

Urban Land Institute, 1980. Visual Resource Management 0510-1: Environmental Comment (May 1980). Washington D.C.

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No. Issue Raised by Response 79. Dear Shawn, Richard Summers BSocSci LLB Dear Richard, Please find attached hereto the comments we LLM (Environmental Law) Thank you for your e-mail and submission on the Eskom 2nd have prepared on behalf of our client. The smith • ndlovu • summers 765kV transmission line DEIR. I hereby acknowledge receiving comments relate to the DEIR (dated May 2014) attorneys, acting for Elandsberg your comments and the two independent reviews conducted prepared by Nzumbululo Sustainable, Energy Farms Stewardship Project, by your specialist team. I will keep you informed about the and Environmental Solutions for the proposed comment by e-mailed letter, submission of the FSR and the availability of the FSR once it Kappa Omega 2nd 765kV power line. independent visual impact has been completed. assessment and heritage We also attach two independent reviews reviews, 11 August 2014. Sincerely, (marked Annexure A and Annexure B) of the Shawn Johnston heritage impact assessment and the visual impact assessment, respectively. These reviews form part of our client’s comments and should be expressly incorporated as such. I shall be most grateful if you will acknowledge receipt hereof. Kind regards,

Richard Summers BSocSci LLB LLM (Environmental Law) smith • ndlovu • summers attorneys

See FEIR appendices submitted for letter and appendic A and B. 80. 29. Whilst the Guideline for Involving Heritage Richard Summers BSocSci LLB Acknowledged. This is stated as a limitation of the ‘Cultural Specialists quoted above identifies heritage LLM (Environmental Law) Landscape report’, and was raised in initial meetings with the indicators and constraints as key criteria for the smith • ndlovu • summers EAP. BoD and ST, November 2014. selection of alternatives, the Built Environment, attorneys, acting for Elandsberg Spatial History and Cultural Landscape Report Farms Stewardship Project, (“Cultural Landscape Report”) notes that: comment by e-mailed letter, independent visual impact “ESKOM Transmission determined route assessment and heritage alternatives before the beginning of the project, reviews, 11 August 2014. based on existing ESKOM lines and servitudes, No. Issue Raised by Response feedback from the first 765kV line application and the need to extend electrical power supply to the Western Cape. Specialists were not involved in route selection.”33 [Own underlining]. 81. 30. As a result of Eskom’s predetermined Richard Summers BSocSci LLB Heritage specialist studies were conducted as directed by HWC alternative routes, the study area itself was LLM (Environmental Law) on 2km study corridors either side of the proposed lines. The geographically limited. Specialists were limited smith • ndlovu • summers remainder of the comment is acknowledged. BoD and ST, to study corridors of 1 kilometre on either side attorneys, acting for Elandsberg November 2014. of the proposed routes.34 At the outset, Farms Stewardship Project, therefore, studies undertaken by the specialists comment by e-mailed letter, did not inform the route selection. The effect of independent visual impact this is that the route selection has not been assessment and heritage informed by an assessment of information on reviews, 11 August 2014. the anticipated impacts of the proposed power line. The assessment of alternatives does not therefore respond to specialist input generated through the EIA process which would enable an appropriate response to particular environmental constraints or the significance of impacts. 82. CUMULATIVE IMPACTS Richard Summers BSocSci LLB The “Cultural Landscape Report” has assessed but not LLM (Environmental Law) described every cumulative impact where it occurs at local 48. Regulation 31(2)(l) of the EIA Regulations smith • ndlovu • summers scale. BoD and ST, November 2014. requires that environmental impact assessment attorneys, acting for Elandsberg reports must include an assessment of each Farms Stewardship Project, identified potentially significant impact including, comment by e-mailed letter, inter alia, a description and assessment independent visual impact cumulative impacts. assessment and heritage reviews, 11 August 2014. 83. 60.3. With regard to the potential impact on the Richard Summers BSocSci LLB Acknowledged, refer to revised Cultural Landscape Report, Elandsberg Nature Reserve the assessment of LLM (Environmental Law) November 2014, BoD and ST, November 2014. cumulative visual impacts is a critical enquiry smith • ndlovu • summers that must be undertaken, particularly given the attorneys, acting for Elandsberg impact of the proposed power lines on the sense Farms Stewardship Project, of place and the aesthetic qualities of this comment by e-mailed letter, No. Issue Raised by Response predominantly rural and wilderness landscape. independent visual impact Without a detailed cumulative visual impact assessment and heritage assessment, it is not possible to draw any reviews, 11 August 2014. defensible conclusions regarding visual impacts. 84. 60.5. The cumulative heritage impacts Richard Summers BSocSci LLB The ‘Cultural Landscape Report’ recommendation of the associated with the project. The primary basis LLM (Environmental Law) preferred route Option 1 and 1a is based on the combination for assessing Alternative Route 1 as the smith • ndlovu • summers of developed heritage indicators and the assessment of preferred route in the draft Heritage Impact attorneys, acting for Elandsberg negative impacts on heritage resources on regional, sub Assessment Report (“draft HIA Report”)60 and Farms Stewardship Project, regional and local scales. This report also does not limit the the Cultural Landscape Report is the presence of comment by e-mailed letter, recommended option to route 1, based on the above, BoD and an existing 400kV transmission line and an independent visual impact ST, November 2014. approved 765kV transmission line which already assessment and heritage impacts landscapes and settlements along the reviews, 11 August 2014. greater distance of Alternative Route 1. For the reasons set out elsewhere in these comments the level of analysis in the DEIR and specialist reports does not substantiate the selection of Alternative Route 1 based on a credible analysis of heritage related impacts in the various heritage studies. 85. 95.3. The combination of both cultural and Richard Summers BSocSci LLB Acknowledged, BoD and ST November 2014. natural heritage makes the Elandsberg Nature LLM (Environmental Law) Reserve a property of considerable heritage smith • ndlovu • summers significance. attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 86. 95.4. The Bosplaas and Bartholomeus Klip Richard Summers BSocSci LLB The site is assessed as rare and representative, not ‘very homesteads situated on the Elandsberg Nature LLM (Environmental Law) rare’. Reserve are considered to be excellent examples smith • ndlovu • summers In 2006 the Drakenstein Heritage survey (Baumann and of an early Swartland (Bosplaas) and Victorian attorneys, acting for Elandsberg Winter) assessed Bartholomeusklip as a Grade IIIa, and homestead (Bartholomeus Klip). The additional Farms Stewardship Project, Bosplaas as a Grade 2 (Baumann and Winter, 2009, p80). No. Issue Raised by Response survival of the old landscape context makes the comment by e-mailed letter, In Baumann and Winter, 2009, Bartholomeusklip is property a very rare part of the cultural independent visual impact recommended as a Grade IIIa (p80), and Bosplaas as a Grade landscape. assessment and heritage 2 (p80), referencing the Drakenstein Heritage survey of 2006. reviews, 11 August 2014. They recommended the cultural and natural landscapes as Grade 2 (p80).

Winter and Oberholzer (2012), in the Draft Provincial Spatial Development Framework (DPSDF) report recommend the Elandsberg Landscape as a local (grade III) heritage resource on the mapping appendices, but do not refer to or evaluate the Elandsberg or its component parts (Bosplaas, Bartholomeusklip, Langhoogte and de Rust) within the report or inventory. The closest citing of Elandsberg in the Provincial framework (which specifically identifies heritage resources significant at Provincial level) is a reference to Voelvlei Dam (under water landscapes). Winter and Oberholzer cite over 40 urban and rural sites that were previous National Monuments, and they cite five new declared Provincial Heritage sites (draft PSDF, Appendix A, p8). The report does not cite recommended Provincial Heritage sites. HWC provided a list of Provincial sites and these resources were not listed. As far as we are aware the site has not ever been proposed to HWC as a Provincial site.

Winter and Oberholzer (2012) recommended the Elandsberg landscape as a Grade III, locally significant landscape, a clear review of the 2006 and 2009 recommendations.

The impacts on Bosplaas and Bartholomeusklip in the 2009 specialist assessment of the initial 765kV line were reported a ‘medium to high heritage hotspot’ (Baumann and Winter, 2009, p 129) While we were aware of the recommendations of the 2006 and No. Issue Raised by Response 2009 studies, the fact that this cultural and natural landscape was not proposed by the same practitioner in 2013 as a Provincial landscape of significance, in addition to the fact that it has not in 9 years following the initial recommendations been nominated as such, indicated that the review assessed this as a locally rather than provincially significant resource. Given this confusion, which was brought to our attention by the 2014 ‘review report’ commissioned by the owner of the land, a site visit was conducted and the report has been revised and recommends the Elandsberg farms (Bartholomeusklip, Bosplaas, Langhoogte and de Rust) as Grade II sites as a collection (as Bosplaas is a reconstructed farmstead, it is not individually assessed by the current authors as an individual Grade II site). Assessments and recommendations for the proposed line in relation to these sites have been further clarified. BoD and ST, November 2014. 87. 96. The review also identifies the following Richard Summers BSocSci LLB The Cultural Landscape assessment methodology incorporated critical concerns with the heritage impact LLM (Environmental Law) numerous site visits at landscape, settlement and individual assessment undertaken to date as part of the smith • ndlovu • summers site scales. The assessment is detailed and cannot be EIA process: attorneys, acting for Elandsberg considered course grained. It is acknowledged that not all Farms Stewardship Project, farmsteads were visited across the route options. The use of 96.1. The landscape assessment undertaken in comment by e-mailed letter, previous reports, historical data and GIS data rendered the the Cultural Landscape Report is coarse grained independent visual impact assessment consistent. BoD and ST, November 2014. and inconsistent in terms of its scale of analysis. assessment and heritage reviews, 11 August 2014. 88. 96.2. The natural and cultural landscape Richard Summers BSocSci LLB Acknowledged, this has been revised following a detailed site associated with the Elandsberg Nature Reserve LLM (Environmental Law) visit. BoD and ST, November 2014. and Alternative Route 1 is ungraded in the smith • ndlovu • summers Cultural Landscape Report. attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage No. Issue Raised by Response reviews, 11 August 2014. 89. 96.3. There has been no recognition of the Richard Summers BSocSci LLB See above comprehensive response number 209. BoD and ST, specific heritage issues and concerns which were LLM (Environmental Law) November 2014. raised with respect to potential impacts on the smith • ndlovu • summers Elandsberg Nature Reserve and its suggested attorneys, acting for Elandsberg Grade 2 status in the Built Environment and Farms Stewardship Project, Landscape Report prepared by Winter and comment by e-mailed letter, Baumann (dated March 2009) for the Kappa independent visual impact Omega 1st 765kV power line. assessment and heritage reviews, 11 August 2014. 90. 96.4. With regard to the Kappa Omega 1st Richard Summers BSocSci LLB This site was identified as a “medium to high level heritage 765kV power line, the southern route alternative LLM (Environmental Law) hotspot’ and not a no-go zone in the 2009 report. Impacts on was proposed to follow the alignment of an smith • ndlovu • summers Bartholomeusklip were cited as low, and on Bosplaas as existing 400kV power line through the attorneys, acting for Elandsberg medium to high (not high). We are in agreement that the Elandsberg Nature Reserve. The Winter and Farms Stewardship Project, impacts of the proposed new line are “High” and that the line Baumann Report (2009) identified the comment by e-mailed letter, should not be built in its proposed position in relation to these cumulative impacts of this alignment as highly independent visual impact resources, as stated in the mitigation measures of the report problematic from a heritage perspective. assessment and heritage reviewed by the Summers’ specialists. It should be noted that Contrary to this recommendation, the Cultural reviews, 11 August 2014. the review conducted was on a draft ‘Cultural Landscape Landscape Report for the proposed Kappa- report’ and not the final ‘Cultural Landscape report’ dated April Omega 2nd 765kV power line concludes that the 2014. heritage impacts associated with Alternative However, in the summary of assessment, it is stated that this Route 1 through the Elandsberg Nature Reserve route is preferable to others, where multiple resources would can be mitigated by its realignment close to the be negatively impacted on a sub regional as opposed to local existing 400kV power lines. No reasons are scale. provided in the Cultural Landscape Report to This has been clarified and the recommendations clearly made justify its variance with the findings of the in the revision of the report. BoD and ST, 2014. Winter and Baumann Report. 91. 96.5. There is an over-reliance in the draft HIA Richard Summers BSocSci LLB Acknowledge that we were appointed to assess alternative Report and Cultural Landscape Report on LLM (Environmental Law) routes, and where impacts are high to propose mitigation. In mitigation measures being resolved once the smith • ndlovu • summers cases where multiple resources would be significantly preferred alternative route is determined. For attorneys, acting for Elandsberg negatively impacted, the proposed mitigation was to use an the reasons stated elsewhere in these Farms Stewardship Project, alternate route. BoD and ST, November 2014. comments, the reliance upon mitigation comment by e-mailed letter, No. Issue Raised by Response measures as a means of addressing each independent visual impact potentially significant impact undermines one of assessment and heritage the primary purposes of the EIA process, which reviews, 11 August 2014. is to ensure that significant adverse impacts are avoided. 92. 96.6. The integration of visual and heritage Richard Summers BSocSci LLB Acknowledged. This was stated in the limitations of the report. specialist studies from a cultural landscape LLM (Environmental Law) BoD and ST, 2014. perspective has been inadequate. This is smith • ndlovu • summers acknowledged in the Cultural Landscape Report attorneys, acting for Elandsberg which notes that “meetings of the specialists Farms Stewardship Project, have only occurred twice during the study comment by e-mailed letter, period, resulting in minimal cross reference of independent visual impact specialist inputs”75 and “visual impact assessment and heritage assessment and public participation are separate reviews, 11 August 2014. specialist studies and have not been available to the built environment and cultural landscape specialists”.76 In order to adequately determine visual impacts on landscapes and settlements of heritage value, the visual and heritage specialist studies should have been appropriately integrated during the scoping and impact assessment phases. 93. 97. There is insufficient information in the DEIR Richard Summers BSocSci LLB Specialists were not able to make these integrations as the and the specialist reports to be able to support LLM (Environmental Law) visual analysis was conducted parallel to EIA processes and the contention that placing new large scale smith • ndlovu • summers not to specialist HIA studies. BoD and ST, November 2014. power line infrastructure within the existing attorneys, acting for Elandsberg corridors impacted by existing power line Farms Stewardship Project, infrastructure is defensible from a heritage comment by e-mailed letter, perspective. The specialist reports have failed to independent visual impact test this contention across various scales of assessment and heritage analysis, which would be required before any reviews, 11 August 2014. defensible conclusions can be made from a heritage perspective. 94. 98. The review commissioned by our client also Richard Summers BSocSci LLB The ‘Cultural Landscape’ specialist assessment of the preferred No. Issue Raised by Response confirms that insufficient consideration has been LLM (Environmental Law) alternative routes have taken cumulative impacts into account given to the cumulative impacts of introducing a smith • ndlovu • summers and have weighed them against cutting new infrastructure second 765kV power line within significant attorneys, acting for Elandsberg corridors through pristine landscapes. BoD and ST, November natural and cultural landscapes associated with Farms Stewardship Project, 2014. Alternative Route 1. Given the heritage comment by e-mailed letter, significance of our client’s property, it could be independent visual impact argued that the combined cumulative impacts of assessment and heritage an additional 765kV power line through our reviews, 11 August 2014. client’s property, the greater Tulbagh Valley and other significant local landscapes associated with Alternative Route 1 outweigh (in terms of significant adverse heritage impacts) the equivalent impacts associated with Alternative Routes 2 and 3. However, there is insufficient information in the draft HIA Report and the Cultural Landscape Report to enable an appropriate interrogation of this. 95. 100. The failure to appropriately assess site Richard Summers BSocSci LLB Impacts were assessed at site levels, and recommendations to specific heritage impacts renders the LLM (Environmental Law) deal with possible negative site specific impacts have been assessment deficient. The deficiencies in the smith • ndlovu • summers undertaken for every identified site over 60 years old. BoD and assessment of heritage-related impacts attorneys, acting for Elandsberg ST, November 2014. effectively means that the requirements of Farms Stewardship Project, section 38 of the National Heritage Resources comment by e-mailed letter, Act have not been complied with in connection independent visual impact with the minimum requirements for the assessment and heritage assessment of heritage impacts. reviews, 11 August 2014. 96. CONCLUSIONS Richard Summers BSocSci LLB Site specific impacts will be considered in the site specific EMP. LLM (Environmental Law) 111. The DEIR is materially deficient in several smith • ndlovu • summers respects, and most notably in connection with attorneys, acting for Elandsberg the failure to identify, consider, evaluate and/or Farms Stewardship Project, assess potentially significant sitespecific comment by e-mailed letter, impacts (including cumulative impacts) independent visual impact associated with the proposed power line. assessment and heritage No. Issue Raised by Response reviews, 11 August 2014.

PROPOSED ESKOM 2ND KAPPA-OMEGA 765KV TRANSMISSION LINE EIA & ASSOCIATED INFRASTRUCTURE, WESTERN CAPE PROVINCE Final Environmental Impact Assessent Report November 2014

ESKOM 2ND KAPPA-OMEGA 765KV TRANSMISSION LINE ENVIRONMENTAL IMPACT ASSESSMENT COMMENTS AND RESPONSES REPORT

Issue Raised by Response Objections Against 2nd Kappa-Omega 765kV Transmission Line Focus Group Meeting Objections Agri Witzenberg Focus Group 1. Cordre Smith: Thank you for providing the Cordre Smith, Agri Shawn Johnston: Comment noted. five farmers associations with an overview Witzenberg, commnet at of the 2nd765kv DEIR. We appreciate it. focus group, 22 May 2014. We are aware of the 1st 765kV transmission line route. 2. Cordre Smith: Can you please provide each Cordre Smith, Agri Shawn Johnston: Comment noted. Yes we have CD of the five farmers associations with a copy Witzenberg, commnet at copies for each of the farmers associations available at of the DEIR? focus group, 22 May 2014. the meeting. 3. Heinie du Toit. As Agri Witzenberg we have Heinie du Toit, Agri Shawn Johnston: Comment noted. At provincial roads received numerous complaints from Witzenberg, commnet at you can speak to Lars Starke at Provincial Roads in farmers about the quality of the farm and focus group, 22 May 2014. Ceres. access road to the Kappa substation. Who can we contact at Eskom and Provincial Ahmed Hansa: I can provide you with the Eskom Roads contact person. 4. Heinie du Toit: Each of the farmers Heinie du Toit, Agri Shawn Johnston: Comment noted. associations in the Witzenberg area will Witzenberg, commnet at review the DEIR and provide you with focus group, 22 May 2014. feedback. CapeNature, Cape Pine, MTO & Department of Agriculture, Forestry and Fisheries Focus Group 5. Dirk Nortje: MTO object against the Dirk Nortje, MTO, comment Shawn Johnston: Comment noted. proposed 2nd 765kV transmission line at focus group, 22 May

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route. This is the same route you proposed 2014. for the 1st 765kV transmission route in 2006 when Eskom did the first EIA for the first route. Then it was show that the route was extremely sensitive and of very high conservation vale. How is it that eight years later things have changed? The area is very high critical biodiversity area and will be given over to CapeNature as part of a new stewardship area linking in with Elandsberg Stewardship on the Berg River Valley. 6. Dirk Nortje: There is no way MTO will allow Dirk Nortje, MTO, comment Shawn Johnston: Comment noted. Eskom to force a line through this area as at focus group, 22 May this current option which Eskom has put on 2014. the table once more was rejected and appealed against in 2006 during the 1st 765kV EIA process. We object and will appeal any environmental authorisation from the Department of Environmental Affairs and the Minister. 7. Alana Duffell-Canham: Can you provide us Alana Duffell-Canham, Shawn Johnston: Comment noted. I will request the with a map of the approved 1st 765kV CapeNature, comment at data and information and send it on to all present in this transmission line and the environmental focus group, 22 May 2014. meeting. authorisation for that line? 8. Joel Syphus: I find it very difficult to Joel Syphus, Department of Thank you for your comment. We hereby acknowledge understand why a route that was shot down Agriculture, Forestry and your concerns and you have been registered you as an and removed from a previous EIA has now Fisheries, comment at focus interested and affected party. I further register your suddenly become a viable preferred group, 22 May 2014. opposition to the proposed Eskom 2nd 765kV

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alternative. We object to the preferred transmission line through your area. alternative as this route will cut through active forestry plantations, wetlands and critical biodiversity areas. 9. Jan Truter: We will have to review the DEIR Jan Truter, Cape Pine, Comment noted. I will forward the requested and obtain all relevant maps and the comment at focus group, 22 information as soon as I receive it. The DEIR is available environmental authorisations from the May 2014. now on CD. previous EIAs to comment. Mainstream Renewable Energy South Africa Paardekraal East Wind Energy Facility Focus Group 10. Mike Mangnall: We are concerned about the Mike Mangnall, Mainstream, Shawn Johnston: Comment noted. servitudes and alignment of the proposed comment at focus group, 23 2nd 765kV transmission line. Will the 2nd May 2014. 765KV line cut through the Mainstream wind energy facility? 11. Mike Mangnall: We cannot afford to stand Mike Mangnall, Mainstream, Shawn Johnston: Comment noted. off additional servitudes to Eskom. We have comment at focus group, 23 already provided Eskom with the required May 2014. servitude during the 1st 765kV transmission line now under construction. 12. Hein Reyneke: Please provide us with the Hein Reyneke, Mainstream, Shawn Johnston: Comment noted. I will forward the up to date shape files and maps so that we comment at focus group, 23 requested information. can clarify how the proposed line would May 2014. impact on the Mainstream wind energy facility. 13. Mike Mangnall: We would like to discuss the Mike Mangnall, Mainstream, Shawn Johnston: Comment noted. servitude with Eskom further. Our concerns comment at focus group, 23 are around the impact on our turbine layout May 2014. and the distance from the transmission

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lines. We would be keen to have follow-up sessions with the Eskom planning team. Elandsberg Farms Stewardship Project Focus Group 14. Mike Gregor: Elandsberg is a conservation Mike Gregor, Elandsberg Shawn Johnston: Comment noted. area linked to the CapeNature Stewardship Stewardship Project, Programme. The area is a registered comment at focus group, 12 stewardship area and a critical biodiversity June 2014. area (CBA). 15. Mike Gregor: In 2006 Eskom wanted to Mike Gregor, Elandsberg Shawn Johnston: Comment noted. bring the 1st 765kV transmission line Stewardship Project, through here and all of the landowners comment at focus group, 12 objected against the 1st 765kV June 2014. transmission coming through the area. We have proof of all the meetings we attended. In the end the alternative was removed. All of the EIA studies highlighted the areas as an extremely sensitive area with critical species. How can Eskom now come back in 2014 and state the a route that was rejected in the 1st 765kV EIA is now a preferred alternative. 16. Mike Gregor: We object against the Mike Gregor, Elandsberg Shawn Johnston: Comment noted. proposed 2nd 765kV transmission line Stewardship Project, alternative. This alternative should never comment at focus group, 12 been considered as an alternative as it was June 2014. rejected by specialist and the community in 2006 during the 1st 765kV EIA. 17. Mike Gregor: I would like to inform Eskom Mike Gregor, Elandsberg Thank you for your comment. We hereby acknowledge

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and the Department of Environmental Stewardship Project, your concerns and you have been registered you as an Affairs Pretoria that we object for all comment at focus group, 12 interested and affected party. I further register your reasons stated and that we will appoint our June 2014. opposition to the proposed Eskom 2nd 765kV legal team and specialist to review the DEIR transmission line through your area. You are also very and that we will appeal and fight this welcomed to appoint your legal team and specialists, to alternative. assist you.

18. Mike Gregor: The current DEIR should be Mike Gregor, Elandsberg Shawn Johnston: Comment noted. rejected as all alternative were not Stewardship Project, considered. The current DEIR is incomplete comment at focus group, 12 and has many gaps and misinformation and June 2014. the current DEIR did not into account the rejection of the current preferred route alternative. This route was rejected in 2006 due to its environmental sensitive nature. Renosterveld Conservancy Focus Group 19. Frank Turner: The area falls with in a Frank Turner, Renosterveld Shawn Johnston: Comment noted. conservancy with linkages to CapeNature Conservancy, comment at and the Elandsberg Stewardship focus group, 07 July 2014. Programme. 20. Frank Turner: We object to the 2nd 765kV Frank Turner, Renosterveld Shawn Johnston: Comment noted. transmission line EIA. In 2006 Eskom Conservancy, comment at wanted to bring the 1st 765kV transmission focus group, 07 July 2014. line through here and all of the landowners objected against the 1st 765kV transmission coming through the area. We have proof of all the meetings we attended. In the end the alternative was removed. All

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of the EIA studies highlighted the areas as an extremely sensitive area with critical species. How can Eskom now come back in 2014 and state a route that was rejected in the 1st 765kV EIA is now a preferred alternative. 21. Frank Turner: We object against the Frank Turner, Renosterveld Thank you for your comment. We hereby acknowledge proposed 2nd 765kV transmission line Conservancy, comment at your concerns and you have been registered you as an alternative. focus group, 07 July 2014. interested and affected party. I further register your opposition to the proposed Eskom 2nd 765kV transmission line through your area. 22. Frank Turner: I would like to inform Eskom Frank Turner, Renosterveld Thank you for your comment. We hereby acknowledge and the Department of Environmental Conservancy, comment at your concerns and you have been registered you as an Affairs Pretoria that we object and that we focus group, 07 July 2014. interested and affected party. I further register your will appeal any positive environmental opposition to the proposed Eskom 2nd 765kV authorisation. transmission line through your area. 23. Frank Turner: We will provide you with our Frank Turner, Renosterveld Shawn Johnston: Comment noted. comments on the matter. Conservancy, comment at focus group, 07 July 2014. Hermon Farmers Association Focus Group 24. Deon Steyn: The Hermon Farmers Deon Steyn, Chairperson Thank you for your comment. We hereby acknowledge Association hereby objects against the Hermon Farmers your concerns and you have been registered you as an construction of the proposed Eskom 2nd Association, comment at interested and affected party. 765kV transmission over the Elandsberg focus group, 21 July 2014. and Bontebok Ridge Farms. 25. Deon Steyn: Is Eskom aware of the Deon Steyn, Chairperson Shawn Johnston: Comment noted. national key point on this proposed route. Hermon Farmers The route will cut through the DENEL Association, comment at

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ammunitions factory. This area is regarded focus group, 21 July 2014. as a national key point. 26. Deon Steyn: It seems Eskom want to bully Deon Steyn, Chairperson Shawn Johnston: Comment noted. a route through the area. An alternative Hermon Farmers that was rejected in 2006 during the 1st Association, comment at 765kV EIA. Why is the Department of focus group, 21 July 2014. Environmental Affairs in Pretoria allowing this to happen? A route that was declared null and void in a previous EIA should not be considered again in the future. 27. Lauire Terblanche: The proposed line will Laurie Terblance, Hermon Shawn Johnston: Comment noted. change our sense of place, the cultural Farmers Association, landscape and impact on the critical comment at focus group, 21 biodiversity of the area. July 2014. 28. Lauire Terblanche: As members of the Laurie Terblanche, Hermon Thank you for your comment. We will await for your Hermon Farmers Association we object Farmers Association, reasons. against the proposed Eskom 2nd 765kV comment at focus group, 21 transmission line and will submit our July 2014. reasons once we have reviewed the DEIR. Draft Environmental Impact Assessment Report Objections CapeNature Concervation Objections 29. Dear Shawn, Alana Duffell-Canham, Dear Alana, CapeNature Scientific Please will you pass on the attached Services, Jonkerskoek, Thank you for your e-mails and comments on the Eskom comments to Nzumbulelo Heritage comment by e-mailed letter, Gamma-Kappa and Kappa-Omega DEIR. I hereby solutions. 11 July 2014. acknowledge receiving both e-mails Please note that whilst some examples of and attached comment letters. errors and omissions have been provided in

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our comments, we cannot provide a Sincerely, comprehensive list of all the factual, Shawn Johnston grammatical and other errors evident throughout the report. Suffice it to say that the report needs a significant amount of review and editing by the consultants. Kind regards, Alana 30. CapeNature would like to thank you for the Alana Duffell-Canham, Thank you for your comment. With regards to your opportunity to comment on this proposed CapeNature Scientific comment on our vegetation types being incorrect. We activity and wish to make the following Services, Jonkerskoek, appointed a specialist, in which their report was comments: comment by e-mailed letter, attached as an appendix. As we are not ecological 11 July 2014. specialists, we made our point generic, however also Overview: stipulated that you will need to refer to the specialist report attached. We wouldn’t have appointe a specialist, 1. The information provided regarding the had we believed that we were ecological specialists. description of the study area is generalised and contains numerous errors. For example the vegetation types listed on page 37 of the main report are not correct – please refer to the CAPE fine-scale vegetation maps as well as the South African vegetation maps for the correct names of the vegetation types found within the study area. These include but are not limited to several types of sandstone Fynbos, alluvium Fynbos, sand Fynbos granite Renosterveld, shale Renosterveld, Flats Strandveld, Granite Strandveld, Dune

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Strandveld, Tanqua karoo, riverine vegetation etc. Incorrect names/spellings of vegetation types are also found later in the report such as “Bre Shale Renosterveld” (p 76). 31. 2. The report does not provide a description Alana Duffell-Canham, Eskom selects lines that are technically and of how the three route alternatives to be CapeNature Scientific environmentally viable on their side, however they investigated were decided upon. Services, Jonkerskoek, appoint environmental specialists to also look at the Furthermore, the report does not provide a comment by e-mailed letter, environmental impacts of their selected alternatives. step by step explanation of how route 11 July 2014. Within the report, we had a table from page 168 to 171. alternative 1 was decided upon as the This table includes all the recommendations from the preferred alternative. A table should be specialists assessments. This however is not the final provided clearly outlining the pros, cons decision, as it still needs to be reviewed by the and fatal flaws for each route alternative. In Department of Environemtal Affairs. addition, no explanation has been provided as to why a corridor following the same alignment as the corridor approved for the first 765kV line is not being considered. 32. 3. The main report also only provides a Alana Duffell-Canham, This can only be done once the final alignments have very general discussion of impacts. The CapeNature Scientific been selected and tower positions have been finalized. information provided is insufficient to draw Services, Jonkerskoek, Site specific impacts will be considered during the walk any conclusions regarding the significance comment by e-mailed letter, down and incoperated in the site specific EMP. of site specific impacts of the preferred 11 July 2014. route and of the other route alternatives. This basically results in the Environmental It is not the objective of this report to attempt to Impact Report (EIR) being no more demarcate all sections of power line for all the informative than the Scoping Report. The alternative corridors that would need to be mitigated. Scoping Report should have provided This can only be done once the final alignments have

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sufficient information to determine the been selected and tower positions have been finalized. preferred corridor. The EIA phase of the Site specific impacts will be considered during the walk project should have investigated the down preferred corridor in detail.

CapeNature notes that it is the applicant’s intention to conduct a walk-down and to conduct negotiations with the landowners regarding the final positions of the pylons and access roads only after environmental authorisation has been received. However, the footprint of the roads and pylons is significant and it is necessary to assess these impacts at a much finer-scale than what has currently been done. Our previous comments specifically requested that the entire development footprint including access routes, stockpiling areas, parking and turning areas be assessed. Decision- makers need to be aware of site-specific issues regardless of the length of powerline being assessed. 33. 4. Some of the recommendations made on Alana Duffell-Canham, The assessment approach was aimed at identification p173 of the report are confusing and CapeNature Scientific and prioritisation of portions along the various questionable. For example recommendation Services, Jonkerskoek, alternatives that are considered most likely to be able to number 6 states that the line should be comment by e-mailed letter, sustain the most diverse and sensitive faunal and floral patrolled annually and areas where 11 July 2014. populations and where more care would be required in collisions have occurred then be marked the planning, construction and operational phases of the

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reactively. Note that bird carcasses which project. It has been made clear in the reports developed may be present as a result of collisions and that as part of the planning phase of the development a electrocutions quickly decompose or are walk down be undertaken of all areas considered of scavenged and disappear within days, how higher ecological importance identified within the will collision sites be determined if the line baseline 2report for the selected route within the is not patrolled for months at a time? With selected corridor. By so doing areas of least concern can regard to point 9 “avoid sensitive habitats”, be identified for the construction of support structures. the level of detail and the scale of maps provided for the sensitivity assessment is not adequate to accurately determine all areas of high sensitivity. Sensitive areas must be groundtruthed and mapped in detail. 34. 5. There is a general lack of discussion Alana Duffell-Canham, This can only be done once the final alignments have regarding cumulative impacts of additional CapeNature Scientific been selected and tower positions have been finalized. powerlines through the landscape and at Services, Jonkerskoek, Site specific impacts will be considered during the walk particular sensitive sites. See comments comment by e-mailed letter, down and incoperated in the site specific EMP. under Site Specific Considerations below for 11 July 2014. further discussion in this regard. 35. 6. The maps provided in the report are at a Alana Duffell-Canham, We included a soft copy, along with the hard copy so broad scale, several with too many labels to CapeNature Scientific that you can be able to zoom in and out. The maps give see the route indicated below. Some of the Services, Jonkerskoek, a brief overlaying of the flora sites. Its not meant to be maps indicating specific features are not comment by e-mailed letter, specific. Such maps, are included in specialist studies. linked to specific text in the report nor do 11 July 2014. they provide any explanation of the importance or relevance of the features in terms of how they influenced the selection of the route alternatives For example, the

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“Flora Sites Map” shows “key vegetation community”, “special habitat location” and “spring flowers” but no explanation is provided is provided as to the importance of these sites. Spring flower sites may be important for tourism but not necessarily for conservation of species of conservation concern, although the areas indicated could be important for more than one reason. Contour and river maps are also not useful at the scale provided as specific landscape features and sizes of features cannot be identified. The Natural features map also requires more explanation in the report, what is the importance of these features and how did they impact on the powerline route selection, why are the “Natural features” as indicated in the title and map legend also “Scenic Landscape Features” as indicated by the labels on the map? Spelling and typos of maps also need to be checked and corrected e.g. “Contous Map” should be Contours Map. 36. 7. A concerning omission in that the main Alana Duffell-Canham, Thank you for your comment. Appendixes are part of report does not provide maps indicating CapeNature Scientific the report, so we believe that the specialst studies are Critical Biodiversity Areas (CBAs), aquatic Services, Jonkerskoek, part of the main report. CBAs or Freshwater Ecosystem Priority comment by e-mailed letter, Areas (FEPAs). CBAs, FEPAs and protected 11 July 2014.

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areas are key biodiversity informants that should be used to inform site/route selection. Although some of the specialist reports contain maps indicating these features, the main report should also contain these maps and reference to their importance. 37. 8. Another important map that should be Alana Duffell-Canham, Comment noted. provided is one indicating Important Bird CapeNature Scientific Areas (IBAs). Services, Jonkerskoek, comment by e-mailed letter, 11 July 2014. 38. 9. In future, please provide the correct Alana Duffell-Canham, shapefiles digitally early on in the process CapeNature Scientific so we can overlay these onto our Services, Jonkerskoek, information. The correct shapefiles were comment by e-mailed letter, only received fairly late in the commenting 11 July 2014. period. 39. Ecology Specialist Study: Alana Duffell-Canham, Thank you for your comment. 10. The ecology study is largely desk-top CapeNature Scientific based with minimal ground-truthing Services, Jonkerskoek, All available and regionally known faunal and floral conducted. Whilst CapeNature understands comment by e-mailed letter, reference databases were considered or assessed in that the specialists had time and budgetary 11 July 2014. order to assure that the assessments take as many of constraints, we remain of the opinion that the potential species as well as important habitats into more groundtruthing should have been consideration as possible given the extent of the various done especially within CBAs. A large part of alternatives. the routes is transformed thus not requiring detailed groundtruthing hence the However, consideration should be given to extreme

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consultants should have focused their extent each of the proposed alternatives cover that resources on the natural areas. Remnants resulted in the likelihood of all documented species as of intact Critically Endangered and well as a vast variety of different habitats being present Endangered vegetation should be mapped along portions of the routes. It should also be noted that and avoided in planning the powerline the study was aimed at assessing 2km wide corridor routes. Using information for plants and alternatives and as such detailed assessments are not fauna at a quarter degree scale has only practicable at this stage of the investigations. limited usefulness and species lists are The assessment approach was aimed at identification certainly not comprehensive and we and prioritisation of portions along the various question the use of this as a key informant alternatives that are considered most likely to be able to for determining route sensitivity. The sustain the most diverse and sensitive faunal and floral ecology study is sufficient to indicate that populations and where more care would be required in possibly route alternative 1 will have less the planning, construction and operational phases of the impact than the other route alternatives but project. It has been made clear in the reports developed there is insufficient information regarding that as part of the planning phase of the development a site specific impacts and mitigation walk down be undertaken of all areas considered of measures to determine if this route is higher ecological importance identified within the acceptable in terms of impacts on baseline 2report for the selected route within the biodiversity or whether additional route selected corridor. alternatives (other than those alternatives already provided) should be sought and By so doing areas of least concern can be identified for investigated. the construction of support structures. It should further be noted that where portions of routes were identified that where considered ‘no go’ areas, it has been highlighted in the report and where possible alternative alignment has been proposed or recommended.

The client has been provided with the GIS files

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indicating areas considered to be of very high and high sensitivity identified using all desktop information available with special mention of fine scale plans as well as site visits. It is the opinion of the specialists that alternative route alignment be considered around these areas and that CBAs be avoided as far as possible regardless of what faunal or floral species are found within them. By so doing the site specific impacts associated with be developed for areas where re- alignment is not an option, however this would require detailed site assessments of all these areas; possibly as a ‘second phase’ assessment that can inform the EIA prior to final submission or prior to finalisation of the EMP for the project. This will allow for the furtherdevelopment of site specific construction and operational mitigation measures.

It should be noted that the assessment was based on a worst case scenario and are therefore considered indicative of the significance of impact that could result due to vegetation clearing and construction related activities within each sensitivity class. 40. 11.The ecology study gives some Alana Duffell-Canham, It has been made clear in the reports developed that as consideration to general mitigation of CapeNature Scientific part of the planning phase of the development a walk construction related impacts but does not Services, Jonkerskoek, down be undertaken of all areas considered of higher adequately consider impacts that may occur comment by e-mailed letter, ecological importance identified within the baseline during the operational phase of the 11 July 2014. 2report for the selected route within the selected

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powerline. Brushcutting under powerlines in corridor. many instances occurs too frequently and the vegetation is cut too low resulting in severe loss of species over time. Some areas of natural vegetation require burning within a certain time period which ideally needs to be planned for. However, fires are not permitted under the powerlines which also results in loss of species. In addition areas that are not burnt for a very long time sometimes experience wild fires which burn out of control resulting in significant damage to property and loss of biodiversity. 41. Avifaunal Specialist Study: Alana Duffell-Canham, Thank you for your comment and information provided. 12. Impacts on birds are of high concern for CapeNature Scientific any large powerline project. However, there Services, Jonkerskoek, is sufficient information and research to comment by e-mailed letter, indicate that if the lines are aggregated, 11 July 2014. they will be more visible and birds will be able to more easily navigate around the powerlines which suggests that the preferred alignment should closely follow the first 765kV line route. The findings of the avifaunal specialist support this. However, the cumulative loss of habitat resulting from having more than one powerline in close proximity should also be taken into account.

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42. Wetland and River Assessment: Alana Duffell-Canham, Site specfic impacts will be considered during work 13. A broad status quo investigation of the CapeNature Scientific down surveys for the selcted route. The proposed significant wetland clusters has been Services, Jonkerskoek, powerline corridor is 2km which means the technical provided. Ground-truthing was also very comment by e-mailed letter, team has enough room to avoid or minimise any limited for this study and no maps 11 July 2014. impacts. We are further confident that our team used indicating specific areas of concern have appropriate methodology to assess the alternatives of been provided and there is no indication of the entire development. Specific impacts will be covered the feasibility of avoiding certain wetland when the final route selection is concluded. areas which has been provided as a recommendation in the main report. Other mitigation measures provided with regard to impacts on wetlands are also generic and do not highlight site specific issues and implications for planning. 43. Tourism Impact Assessment: Alana Duffell-Canham, Thank you for your comment. All issues with 14.This study was of potential interest to CapeNature Scientific paragraphs, has been fixed. CapeNature as the powerlines could have a Services, Jonkerskoek, The TIAS does not identify permanent negative or potential impact on our protected areas, comment by e-mailed letter, prohibitive barrier to the developing the proposed especially visual impacts as well as impacts 11 July 2014. powerline in any of the alternative servitudes. As such, on biodiversity. Unfortunately, this report this study supports the preferred route subject to it provided as Appendix 12 is completely being the most suitable from other impact and illegible as the words in each paragraph are technical recommendations. joined. 44. Environmental Management Plan: Alana Duffell-Canham, This can only be done once the final alignments have 15. The EMP needs to be updated to include CapeNature Scientific been selected and tower positions have been finalized. inter alia a map clearly indicating areas of Services, Jonkerskoek, Site specific impacts will be considered during the walk high sensitivity/no-go areas, more comment by e-mailed letter, down and incoperated in the site specific EMP. information regarding site rehabilitation 11 July 2014.

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after construction as well as operational management measures for on-going alien clearing and fire management. 16. Note that should certain plant species need to be removed or translocated this may require a permit from CapeNature. As the exact footprint of the infrastructure is unknown and has therefore not been assessed in detail at this stage it is unknown whether any of the relevant species will be affected. This may cause delays later on. 45. Site Specific Considerations: Alana Duffell-Canham, Thank you for your comment. When Eskom is doing the Note that this is not a comprehensive list of CapeNature Scientific final EMP they will have to take note of the nature sites of concern and inputs regarding Services, Jonkerskoek, Reserves in detail. And put forward site specific sensitive areas and desired management comment by e-mailed letter, mitigations forward. objectives from landowners and other 11 July 2014. interested and affected parties must also be taken into consideration: 17.Route Alternative 1 crosses several protected areas including Elandsberg Nature Reserve, Waterval Nature Reserve and Hawequa State Forest. Elandsberg Nature Reserve and the property to the south which is known as Kranskop support two Critically Endangered vegetation types, namely Swartland Alluvium Fynbos and Swartland Shale Renosterveld. These

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properties have been determined as Critical Biodiversity Areas (CBAs) and contain several Ecological Support Areas (ESAs) as well. 46. 18. Elandsberg Nature Reserve contains Alana Duffell-Canham, Comment has been noted. many threatened and endemic plant CapeNature Scientific species. It also supports the Critically Services, Jonkerskoek, Endangered geometric tortoise, which is comment by e-mailed letter, now the third most endangered tortoise in 11 July 2014. the world and has been listed by the IUCN as one of the top 100 most threatened species on earth. 47. 19. Cumulative impacts of a third powerline Alana Duffell-Canham, Thank you for your comment, and please be adviced within the Elandsberg Nature Reserve and CapeNature Scientific that your comment has been noted. surrounding properties must be considered. Services, Jonkerskoek, Two 400kV powerlines already traverse the comment by e-mailed letter, Nature Reserve and construction of a third 11 July 2014. larger powerline will cause additional habitat loss and disturbance. As discussed in point 11 above, fire plays an important role in ensuring survival of certain plant species. Past experience has shown that it has been impossible to implement block burns underneath powerlines due to the perceived impact it would have in terms of interrupted service. The addition of a third powerline will increase the area that will not be able to be included in a planned burning

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regime. CapeNature strongly suggests that an alternative route that avoids Elandsberg be investigated. 48. 20. From the information provided it is not Alana Duffell-Canham, Please refer to the maps provided for further details clear whether the preferred powerline route CapeNature Scientific about the powerline route. We are confident that our will be going through the area known as Services, Jonkerskoek, wetland specialists put your observation into Suurvlak. If the proposed powerline needs comment by e-mailed letter, considerations. Certainly the powerline will not be to be moved to allow for sufficient distance 11 July 2014. allowed to impact on such significant wetlands. As between it and the existing 400kV line, the environmentalists we are equal concerned about powerline may intercept the Suurvlak. The protecting the environment. Suurvlak area contains many wetland and seepage areas and is considered sensitive for this reason. More groundtruthing of this area is required pre-authorisation. Information regarding this site can also be obtained from Working for Wetlands. 49. 21. Route alternatives 2 and 3 also cut Alana Duffell-Canham, Thank you for your comment. through several areas of high conservation CapeNature Scientific It should be noted that where portions of routes were importance including the Groot Winterhoek. Services, Jonkerskoek, identified that where considered ‘no go’ areas, it has Not only is a most of this area a nature comment by e-mailed letter, been highlighted in the report and where possible reserve but there are also important 11 July 2014. alternative alignment has been proposed or ecological corridors to consider. This area is recommended. considered a no-go area from a biodiversity perspective and a deviation around this area will have to be considered. 50. 22. The route alternatives which run in a Alana Duffell-Canham, Thank you for your comment and it has been noted. north-south direction down the West Coast CapeNature Scientific The assessment approach was aimed at identification are also not preferred from a biodiversity Services, Jonkerskoek, and prioritisation of portions along the various

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perspective as they will affect the West comment by e-mailed letter, alternatives that are considered most likely to be able to Coast National Park, the Dassenberg 11 July 2014. sustain the most diverse and sensitive faunal and floral Coastal Catchment Partnership (DCCP) and populations and where more care would be required in possibly several stewardship sites. Note the planning, construction and operational phases of the that the DCCP corridor has not been taken project. It has been made clear in the reports developed into consideration in any of the studies. that as part of the planning phase of the development a walk down be undertaken of all areas considered of higher ecological importance identified within the baseline 2report for the selected route within the selected corridor. By so doing areas of least concern can be identified for the construction of support structures.

51. Conclusion: Alana Duffell-Canham, Site specific mitigation measures can be developed for 23. Despite specialist studies been CapeNature Scientific areas where re-alignment is not an option, however this undertaken during the EIA phase of this Services, Jonkerskoek, would require detailed site assessments of all these project, very little groundtruthing or comment by e-mailed letter, areas; possibly as a ‘second phase’ assessment that can detailed investigation of site specific 11 July 2014. inform the Eskom prior to construction or prior to impacts has been done. Whilst CapeNature finalisation of the EMP for the project. This will allow for understands that perhaps there were time the further development of site specific construction and budget constraints, there should still and operational mitigation measures. have been a greater focus on areas of high - It should be noted that the assessment was based on sensitivity and efforts to precisely map a worst case scenario and are therefore considered these as no-go areas and determine if they indicative of the significance of impact that could result can be avoided or whether completely new due to vegetation clearing and construction related corridors need to be investigated. activities within each sensitivity class.

52. Objection: Alana Duffell-Canham, Objection noted. 24. Whilst the information provided does CapeNature Scientific Site specific mitigation measures can be developed for

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indicate that powerline route alternative 1 Services, Jonkerskoek, areas where re-alignment is not an option, however this may have fewer impacts than the other comment by e-mailed letter, would require detailed site assessments of all these route alternatives, there is too little 11 July 2014. areas; possibly as a ‘second phase’ assessment that can information to determine if these impacts inform the Eskom prior to constructionor or prior to can be avoided or adequately mitigated as finalisation of the EMP for the project. This will allow for the EIR places too much reliance on post- the further development of site specific construction authorisation measures such as walk downs and operational mitigation measures. of the preferred route at which stage issues, which should have been discovered and dealt with during the EIA, could be discovered and cause major delays to the project. Alternatively these issues could be overlooked as authorisation will have already been obtained. Issues and requirements identified by commenting authorities and I&APs during the Scoping phase have been largely skimmed over in the Draft EIR. CapeNature therefore objects to this application and is of the opinion that a decision to authorise this application should not be made based on the inadequate, incorrect (and in places illegible) report and appendices provided. 53. CapeNature reserves the right to revise Alana Duffell-Canham, Thank you and noted. initial comments and request further CapeNature Scientific information based on any additional Services, Jonkerskoek, information that may be received. comment by e-mailed letter, 11 July 2014.

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City of Cape Town Objections PROPOSED KAPPA OMEGA 2ND 765Kv Morne Theron, Senior Thank you for your comment. POWERLINE AND SUBSTATIONS UPGRADE Environmental Practioner IN WESTERN CAPE – DRAFT and Pat Titmuss Regional ENVIRONMENTAL IMPACT REPORT Manager: Enviornmental and [NEAS Ref: DEA/EIA/0001266/2012] Heritage Management: [DEA Ref: 14/12/16/3/3/2/352] District B & C, City of Cape Town, comment by e-mailed The abovementioned draft Environmental letter, 11 August 2014. Impact Report (Draft EIR), dated May 2014, submitted under the Nzumbululo Heritage Solutions’ coverletter, dated 31 May 2014, refer.

Eskom proposes a new transmission line to bring power generated elsewhere into the Western Cape, in order to supply increasing electricity demands in the Cape Town area. The proposed new transmission line will link the Kappa substation near Ceres to the Omega substation near Koeberg (approximately 415km long). It appears that three (3) main routes alternatives are proposed with secondary deviation options being considered for main Routes 1 and 3.

As was mentioned during the draft scoping stage of this project the City of Cape Town

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technical comment is limited to the 2nd Kappa Omega 765kV line only as it traverses the City’s municipal jurisdiction. 54. Public Participation Process Morne Theron, Senior 1. The Draft scoping report, which was sent to you, Environmental Practioner allowed you to comment on any issues you had. All the 1. Appendix 2 of the draft EIR includes and Pat Titmuss Regional issues and concerns, which you raised where the Competent Authority’s approval, dated Manager: Enviornmental and acknowledged in the Final Scoping report which was 18/08/2013, of the final scooping report Heritage Management: submitted to the Department. and proposed plan of study. The EAP was District B & C, City of Cape reminded to comply with the requirements Town, comment by e-mailed of regulations 56 and 57 in regards to the letter, 11 August 2014. allowance of a commenting period for 2. All alternatives, were assessed. The specialists, then interested and affected parties on all recommended which alternative would be less harmful reports submitted. to the environment. The assessment approach was aimed at identification Notwithstanding the above the City of Cape and prioritisation of portions along the various Town was not informed of the availability of alternatives that are considered most likely to be able to the final Scoping Report or afforded an sustain the most diverse environment and where more opportunity to comment thereon as care would be required in the planning, construction and required in terms of regulation 56(6). operational phases of the project. It has been made clear in the reports developed that as part of the 2. Subsequent to the notification from planning phase of the development a walk down be Nzumbululo Heritage Solutions, dated 31 undertaken of all areas considered of higher ecological May 2014, the City of Cape Town received importance identified within the baseline report for the the attached letter, dated 2 June 2014, selected route within the selected corridor. By so doing from Sustainable Futures (as Process areas of least concern can be identified for the Facilitator) entitled: Update on Eskom’s 2nd construction of support structures. The final decision, 765kV Transmission Line. According to the as to which route is appropriate, will be made by the

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said Sustainable Futures update letter all Department of Environmental Affairs. the Alternatives Route Options except Alternative 1 have been discarded and that only Alternative 1 is to be taken forward for assessment.

It is highly unusual to only have 1 option to consider during the draft EIR stage of an EIA process. The said update is furthermore problematic in that it indicates a ‘pre- emptive’ discarding of all the alternatives (except for Alternative 1) even before the final PPP for the draft EIR process has been concluded.

There appears to be contradictory information being communicated to I&APs between the EAP and the Process Facilitator. It is cautioned that this uncertainty might be grounds for rendering the PPP flawed. 55. Public Participation Process Morne Theron, Senior Comment noted. Nzumbululo Heritage Solutions as the 1. Appendix 2 of the draft EIR includes Environmental Practioner environmental impact assessment practitioner the Competent Authority’s approval, dated and Pat Titmuss Regional interacted directly with the commenting authorities and 18/08/2013, of the final scooping report Manager: Enviornmental and the public participation team with the broader intereated and proposed plan of study. The EAP was Heritage Management: and affected parties. reminded to comply with the requirements District B & C, City of Cape of regulations 56 and 57 in regards to the Town, comment by e-mailed

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allowance of a commenting period for letter, 11 August 2014. interested and affected parties on all reports submitted.

Notwithstanding the above the City of Cape Town was not informed of the availability of the final Scoping Report or afforded an opportunity to comment thereon as required in terms of regulation 56(6). 56. 2. Subsequent to the notification from Morne Theron, Senior Comment noted. An instruction was given by Nzumbululo Heritage Solutions, dated 31 Environmental Practioner Nzumbululo Heritage Solutions to the public May 2014, the City of Cape Town received and Pat Titmuss Regional participation team to inform all interested and affected the attached letter, dated 2 June 2014, Manager: Enviornmental and parties of the current status of the environmental from Sustainable Futures (as Process Heritage Management: impact assessment and what alternatives are the Facilitator) entitled: Update on Eskom’s 2nd District B & C, City of Cape preferred alternative being taken forward in the draft 765kV Transmission Line. According to the Town, comment by e-mailed environmental impact report in cooperation of specialist said Sustainable Futures update letter all letter, 11 August 2014. studies which was released for public comment. This the Alternatives Route Options except letter was submitted as an update during the comments Alternative 1 have been discarded and that period of the draft environmental impact report and only Alternative 1 is to be taken forward for provided details of what alternatives where disgarded by assessment. It is highly unusual to only specialist and the environmental impact assessment have 1 option to consider during the draft practitioner and referred to the availability of the draft EIR stage of an EIA process. The said environmental impact assessment report and the public update is furthermore problematic in that it participation process. indicates a ‘pre-emptive’ discarding of all the alternatives (except for Alternative 1) even before the final PPP for the draft EIR process has been concluded. There appears

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to be contradictory information being communicated to I&APs between the EAP and the Process Facilitator. It is cautioned that this uncertainty might be grounds for rendering the PPP flawed. Notwithstanding the contradictory notifications mentioned in point 2 above, the following comment is made on the written text of the draft Environmental Impact Assessment Report (Draft EIR) and the draft EMPr pertaining to all 3 route alternatives including their respective deviation options (1a, 1b, 3a, 3b and 3c): 57. Draft Environmental Impact Assessment Morne Theron, Senior Thank you for your comment and it has been noted. Report Environmental Practioner 1. It was indicted during the draft and Pat Titmuss Regional scoping stage that “Section 5 Statutory Manager: Enviornmental and requirements should list applicable local Heritage Management: municipal spatial development frameworks District B & C, City of Cape and assess the compatibility of the Town, comment by e-mailed proposed powerlines to the strategies, and letter, 11 August 2014. / or guidelines of the said spatial development frameworks. In this regard source the approved City of Cape Town Spatial Development Framework (2012), as well as the Blaauwberg and Northern District Plans (2012) from the City of Cape Town website

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(www.capetown.gov.za/environment)”;

And

“Be advised that the proposed Routes 1 and 2 appears to traverse cultural and recreational resource zones, notably the Koeberg Farms Cultural Landscape and the Swartland Farms Cultural Landscape, as identified in both the Blaauwberg and Northern District Plans (2012). Sections of Route 3 traverse the Blaauwberg District’s Archaeological zone which included areas of high potential archaeological and paleontological value. The routes’ impact in the aforementioned zones and their management priorities should be unpacked.” 58. Notwithstanding the above, the draft EIR Morne Theron, Senior Thank you for your comment, please note the the study completely ignored the aforementioned. Environmental Practioner did not ignore any frameworks of the municipalities. Spatial Development Framework and and Pat Titmuss Regional Everyframework and city by laws were take into Environmental Management Framework Manager: Enviornmental and consideration.Hence all the municipalities along the relevance to this project are, amongst Heritage Management: powerline were contacted to assist and were invited to other, the following: District B & C, City of Cape comment where possible. Town, comment by e-mailed 1.1 In terms of Policy Statement 6 of letter, 11 August 2014. the CTSDF the City of Cape Town will proactively support initiatives aimed at

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enhancing the economic competitiveness of the city region by engaging with, amongst other, parastatals such as Eskom on issues of cross border significance including coordinating economic infrastructure; protecting regional assets (e.g. agricultural land, cultural landscapes, and biodiversity areas); and lobbying National Government on regional issues, including infrastructural investment. 59. As such the principle of establishing a 2nd Morne Theron, Senior All available and regionally known faunal and floral 765kV powerline in order to accommodate Environmental Practioner reference databases were considered or assessed in the region’s future energy demand is in and Pat Titmuss Regional order to assure that the assessments take as many of accordance with the CTSDF. However, the Manager: Enviornmental and the potential species as well as important habitats into proposed location of the 2nd 765kV Heritage Management: consideration as possible given the extent of the various powerline is problematic as will be District B & C, City of Cape alternatives. elaborated below. Town, comment by e-mailed However, consideration should be given to extreme letter, 11 August 2014. extent each of the proposed alternatives cover that 1.2 A number of the route alternatives, resulted in the likelihood of all documented species as including the proposed preferred alternative well as a vast variety of different habitats being present 1, of the 2nd 765kV powerline appear to be along portions of the routes. It should also be noted that inconsistent with the approved City of Cape the study was aimed at assessing 2km wide corridor Town: Spatial Development Framework alternatives and as such detailed assessments are not (CTSDF) as well as the Northern District practicable at this stage of the investigations because Plan and Environmental Management you will be studying a wider corider. Hence the walk Framework (EMF) for the following reasons: downs will be done to assist further where the pylons will be place and where the developer should avoid. • In terms of Policy Statement 25 of The assessment approach was aimed at identification

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the CTSDF all levels of government should and prioritisation of portions along the various increase efforts to protect and enhance alternatives that are considered most likely to be able to biodiversity networks. In terms of Policy sustain the most diverse and sensitive faunal and floral Guideline P25.1 the impact of proposed populations and where more care would be required in powerlines (i.e. development) on critical the planning, construction and operational phases of the biodiversity areas must be carefully project. It has been made clear in the reports developed assessed, and decisions related to the city’s that as part of the planning phase of the development a biodiversity network must be based, walk down be undertaken of all areas considered of amongst other, on the most up-to-date higher ecological importance identified within the mapping of the city’s biodiversity network. baseline 2report for the selected route within the In this regard, and as further elaborated in selected corridor. By so doing areas of least concern can paragraph 6 below, the environmental be identified for the construction of support structures. practitioner does not refer to the fine scale It should further be noted that where portions of routes systematic biodiversity plan (Biodiversity were identified that where considered ‘no go’ areas, it Network) for the City of Cape Town, which has been highlighted in the report and where possible prioritizes areas for conservation. alternative alignment has been proposed or recommended. • Alternative 1 aligns point-to-point cross-country over the R304 which is an identified scenic route according to the CTSDF and EMF. In terms of Policy Statement 48 of the CTSDF land uses and interventions (e.g. power lines) along identified scenic route, and in places of scenic and visual quality, must be carefully managed. The scenic route land use management guidelines include the following:

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o “All future buildings, roads and infrastructure, including power lines, alongside designated scenic routes, or that can be seen from scenic routes, should be positioned and designated according to relevant guidelines” o “Pipelines, transmission lines and telecommunication masts should be aligned with existing and proposed transport (road and/or rail) corridors, rather than along point-to-point cross-country routes (provided that this does not affect cultural and scenic landscapes)”

• In terms of the section 5.2.3 of the Northern District Plan and EMF the preferred Alternative 1 is located within the Philadelphia and surround Koeberg/Swartland Farms cultural and heritage area. Within this zone inappropriate utilities such as pylons and overhead cables are listed as ‘kinds of developments, land uses or activities that would be undesirable’. 60. Conversely it is worthy to note that the Morne Theron, Senior Thank you for your comment. alignment of the approved 1st 765kV power Environmental Practioner line is compatible with the above spatial and Pat Titmuss Regional

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development framework and district plan. Manager: Enviornmental and As such the alignment of the 2nd 765Kv Heritage Management: power line adjacent to the 1st 765kV power District B & C, City of Cape line once it traverse through the City of Town, comment by e-mailed Cape Town’s jurisdiction would be more letter, 11 August 2014. consistent with the approved CTSDF and EMF. In other words the positioning of the 2nd 765Kv power line within the City of Cape Town’s jurisdiction would thus be more consistent with the approved CTSDF and EMF policy statements, guidelines and management priorities from a purely spatial planning perspective if aligned along route Alternative 2 where the route intersects with Alternative 1 route deviation Option 1a and 1b. 61. 2. The draft EIR does not include the Morne Theron, Senior Thank you for your comment. The specialists terms of approved Plan of Study (PoS) and/or the Environmental Practioner reference, where included as table 8 in DEIR. terms of reference that the specialists were and Pat Titmuss Regional supposed to follow in compiling their Manager: Enviornmental and respective studies. The aforementioned, Heritage Management: and the fact that the final scoping report District B & C, City of Cape with POS was never circulated, renders if Town, comment by e-mailed difficult to ascertain what the specialists letter, 11 August 2014. based their recommendations on or how they assessed the various route alternatives.

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62. 3. Three (3) alternatives (Option 1, 2 Morne Theron, Senior Thank you for your comment. There are only 3 and 3) with a number of route diversions Environmental Practioner alternatives. These include alternative 1,2 and 3. 1a and (i.e. Routes options 1a, 1b and 3a, 3b and and Pat Titmuss Regional 1b for example, are just diversions, but are still part of 3c) are listed by the EAP. This effectively Manager: Enviornmental and alternative 1. We cannot call 1a an alternative on its means a total of 8 route variations, yet the Heritage Management: own, as its just a small portion of alternative 1. Had we EAP appears to completely ignore the route District B & C, City of Cape put 1a,1b,2a,2b,3a or 3b as different alternatives, then diversions in the final recommendation. Town, comment by e-mailed only that smal portion would be the line which needs to letter, 11 August 2014. be constructed by Eskom and that is not what we are trying to achieve. 63. 4. The draft EIR lists some rating Morne Theron, Senior A rating matrix has been included in the final report. All matrix for each potential impact, however Environmental Practioner our conclusions, where mostly based on the findings of the EAP fails to represent the various route and Pat Titmuss Regional the specialist. alternatives in a coherent table against the Manager: Enviornmental and said rating matrixes in a matter that clearly Heritage Management: compare the cumulative impact of the 8 District B & C, City of Cape route diversions. As such the conclusion by Town, comment by e-mailed the EAP indicating the preferred alternative letter, 11 August 2014. as Option 1 is questionable. 64. 5. It is of grave concern that the table Morne Theron, Senior Thank you for your comment. Comment noted and it entitled ‘Summary of findings regarding Environmental Practioner shall be addressed. route alternatives in the study area’ and Pat Titmuss Regional (Section 16: General conclusion, page 168 Manager: Enviornmental and – 171 of the draft EIR) incorrectly list the Heritage Management: preferred alternative under a number of the District B & C, City of Cape specialist studies. In a number of cases the Town, comment by e-mailed EAP merely refers to Alternative 1, yet the letter, 11 August 2014. route diversions 1a and 1b that the specialists often assessed as preferred

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alternatives are discarded by the EAP without any reason being provided. The incorrectly listed preferred alternatives are, notably the following:

Avifauna (the specialist listed Alternative 1b, yet the EAP listed Alternative 1);

Fauna and Flora (the specialist listed alternative 1 and 3 not just Alternative 1);

Heritage (the specialist listed a combination of Alternative 1, 1a and 2, yet the EAP merely highlighted Alternative 1);

Wetlands (the specialist actually concluded that “all proposed development routes crosses significant surface water resources and that no preferred alternative is provided in this report” yet the EAP listed Alternative 1 at the preferred alternative);

Visual Impact (the visual specialist Axis Landscaping Architect’s map’s Option 1 on page 2 of the specialist report, differs from the EAP’s map’s Option/Alternative 1 in Appendix 1 of the draft EIR!)

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Effectively the Visual specialist Option 1 is identical to the EAP (and other specialists) Alternative 1 with a diversion along route 1a in order to run along the existing approved 1st 765kV line. Yet the EAP merely listed his Alternative 1 (without the diversion along route 1a in order to run along the existing approved 1st 765kV line). This effectively means that the EAP is suggesting a completely different (and visually detrimental) southern alignment into the Omega/Sterrekus Substation) 65. 6. It is furthermore puzzling why a Morne Theron, Senior Thank you for your comment. Within the General number of specialist studies was conducted Environmental Practioner Conclusion , we included comments from the specialists and included as Appendices to the draft and Pat Titmuss Regional as well as the preferred alternative of the specialist. We EIR, yet the findings of the said specialists Manager: Enviornmental and also stated that the comparative assessment of were not included in (Section 16: General Heritage Management: specialist findings had highlighted alternative 1 as conclusion, page 168 – 171 of the draft District B & C, City of Cape preferred over 2 and 3. EIR)? It was indicted during the draft Town, comment by e-mailed scoping stage that “the consultant seems to letter, 11 August 2014. be unaware of the biodiversity planning initiatives for the Western Cape as the Cape Fine-Scale Biodiversity Plans are not mentioned, nor are the Succulent Karoo Ecosystem Plan or the fine-scale biodiversity plan for the City of Cape Town area (i.e. the Biodiversity Network) mentioned. These plans represent the

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Critical Biodiversity Areas and Ecological Support Areas that are the minimum required to meet national biodiversity conservation targets and to maintain biodiversity long-term. It is essential that these tools are used to devise potential alternative routes that avoid such areas. Information can be downloaded from the SANBI BGIS website, and for the latest City information from the City of Cape Town website (www.capetown.gov.za/environment) or by contacting the City of Cape Town: Biodiversity Management Branch directly.” 66. The draft EIR still fails to adequately Morne Theron, Senior Thank you for your comment. All the specialist reports, address the aforementioned. The consultant Environmental Practioner give a greater explanation of all the issues raised. does not refer to the fine scale systematic and Pat Titmuss Regional All available and regionally known faunal and floral biodiversity plan (Biodiversity Network) for Manager: Enviornmental and reference databases were considered or assessed in the City of Cape Town, which prioritizes Heritage Management: order to assure that the assessments take as many of areas for conservation. These fine-scale, District B & C, City of Cape the potential species as well as important habitats into systematic conservation plans (Cape fine- Town, comment by e-mailed consideration as possible given the extent of the various scale plans for neighbouring municipalities) letter, 11 August 2014. alternatives. are important as they represent Critical However, consideration should be given to extreme Biodiversity Areas (CBAs) and Ecological extent each of the proposed alternatives cover that Support Areas (ESAs) that are the resulted in the likelihood of all documented species as minimum required to meet national well as a vast variety of different habitats being present biodiversity conservation targets and to along portions of the routes. It should also be noted that maintain biodiversity long-term. This should the study was aimed at assessing 2km wide corridor

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be addressed in the FEIR and any portions alternatives and as such detailed assessments are not of the proposed transmission lines that practicable at this stage of the investigations. traverse CBAs or ESAs highlighted in the The assessment approach was aimed at identification report. and prioritisation of portions along the various alternatives that are considered most likely to be able to sustain the most diverse and sensitive faunal and floral populations and where more care would be required in the planning, construction and operational phases of the project. It has been made clear in the reports developed that as part of the planning phase of the development a walk down be undertaken of all areas considered of higher ecological importance identified within the baseline 2report for the selected route within the selected corridor. By so doing areas of least concern can be identified for the construction of support structures. It should further be noted that where portions of routes were identified that where considered ‘no go’ areas, it has been highlighted in the report and where possible alternative alignment has been proposed or recommended. CBA maps, have been included in the final report. 67. Concerns and mistakes pointed out from Morne Theron, Senior Thank you for your comment and comment has been the Draft Scoping Report have not been Environmental Practioner noted. addressed or corrected and should be and Pat Titmuss Regional amended in the FEIR (please refer to the Manager: Enviornmental and City comment on the draft scoping report Heritage Management: dated 7 May 2013). Examples include: Page District B & C, City of Cape 32 – ‘Apparently there is 31% increase of Town, comment by e-mailed

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threatened species in the Protea family…’ letter, 11 August 2014. [Refrain from speculative statements, i.e. apparently, and rather state factual information. Again proper referencing is warranted in this regard. Page 71, Specialist studies - The identification of “endangered” species, should be “threatened” species or “species of conservation concern”. It is not clear what is meant by “recommendations for clearing of plants”? Brushcutting and mowing of CFR ecosystems eliminates many species and is not supported. 68. Maps are not sufficiently detailed and are Morne Theron, Senior Thank you for your comment. The eletronic maps can be difficult to interrogate. Either shape files Environmental Practioner zoomed to a bigger number required. should be provided to the major and Pat Titmuss Regional commenting authorities or else fine-scale Manager: Enviornmental and After communication with the City of capetown the maps (to enable a zoom function to a Heritage Management: Protected Areas map has been updated. Thank you very minimum of 1:10,000) provided that District B & C, City of Cape much for your assistance overlays the proposed transmission line Town, comment by e-mailed route alternatives with the most detailed letter, 11 August 2014. Critical Biodiversity Area plans covering all municipalities (e.g. Biodiversity Network and Cape Fine-scale Plans) to indicate the proposed routes and extent of construction on biodiversity areas. The Protected Areas map (pg. 82, fig. 10) for the city area is outdated and the consultant should contact

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the City of Cape Town, Environmental Resource Management Department, for the most recent information. 69. [Note: The map pages contained in the Morne Theron, Senior Thank you for your comment. We have included the Built, Spatial History and Cultural Environmental Practioner maps you require, under appendix 1. However, we Landscape study as compiled by Bridget and Pat Titmuss Regional would like to believe that, if those maps are included in O’Donoghue/Sally Titlestad heritage Manager: Enviornmental and the specialist report then they are part of our report. All consultants were much more detailed and Heritage Management: the appendices included , are part of the report. This thus user friendly than those contained in District B & C, City of Cape includes, all the specialist reports attached. the main report of the draft EIR] Town, comment by e-mailed letter, 11 August 2014. 70. 7. The Floral and Faunal Assessment Morne Theron, Senior Thank you for your comment and it has been noted. indicated areas (within the City of Cape Environmental Practioner All available and regionally known faunal and floral Town boundaries) demarcated as CBAs as and Pat Titmuss Regional reference databases were considered or assessed in well as other areas with intact vegetation Manager: Enviornmental and order to assure that the assessments take as many of within threatened ecosystems located along Heritage Management: the potential species as well as important habitats into the west coast. It is agreed with the District B & C, City of Cape consideration as possible given the extent of the various specialist that successful search and rescue Town, comment by e-mailed alternatives. and translocation of floral species from letter, 11 August 2014. these areas would be very difficult. The specialist recommended that by re-routing options and alternatives to more disturbed areas inland, or follows the existing transmission line corridor, coastal floral habitat, CBAs and threatened ecosystems could be avoided. Option 1 and option 3 are consequently regarded by the specialist as the most

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ecologically viable options that are expected to have the least impact of the options considered.

The City of Cape Town is of the opinion that other route deviation options should be proposed that do not traverse CBAs and ESAs in this international biodiversity hotspot. Thus even for route option 1 there are sections traversing CBAs and ESAs that could be modified by deviations to have a lower biodiversity impact. 71. 8. City of Cape Town: Biodiversity Morne Theron, Senior Thank you for your comment. Network: When assessing the different Environmental Practioner route options, it is clear that all options will and Pat Titmuss Regional traverse Critical Biodiversity Areas (CBAs) Manager: Enviornmental and (see Figure 1 below). Of these it seems Heritage Management: options 1, 1a and 1b will traverse the District B & C, City of Cape fewest CBAs (see Figure 2 below). This Town, comment by e-mailed coincides with the Wetland/River, Bird and letter, 11 August 2014. Bat assessments which have option 1 as their preferred alternative.

Unfortunately power line infrastructure is not compatible with conserving biodiversity in fynbos biome ecosystems. This is because these ecosystems require periodic summer fires to maintain biodiversity.

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Without fire, fynbos and renosterveld biodiversity will be lost over time. To date there has been very little success by Eskom in applying appropriate ecological management in the fynbos biome. Vegetation continues to be mowed, brush cut and even ploughed under power lines in order to prevent fires, destroying much critical biodiversity. To this extent be advised that an approved Sivest Environmental Final BAR, dated March 2013 (DEA Reference: 12/12/20/2011) pertaining to the establishment of the 132kV Koeberg- Dassenberg powerline contained a Vegetation Management Plan, dd February 2013, that was specifically developed for that route and included in the EMPr to ensure minimal long term operational management impact of the indigenous vegetation underneath the power line. A similar Vegetation Management Plan should be compiled for this powerline, failure upon which, all power lines and their structures must be located off natural vegetation areas.

Furthermore, routes need to be assessed in

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relation to wetland features (including seasonal wetlands) which also form part of the Biodiversity Network. From the documentation perused if would appear that the wetland features were not assessed by the consultants. See referred map in attached letter. 72. 9. It is reiterated that, based on the Morne Theron, Senior All available and regionally known faunal and floral lack of detailed specialist investigation, it is Environmental Practioner reference databases were considered or assessed in problematic to support any of the proposed and Pat Titmuss Regional order to assure that the assessments take as many of alternatives from a biodiversity resource Manager: Enviornmental and the potential species as well as important habitats into and conservation perspective, as they all Heritage Management: consideration as possible given the extent of the various traverse CBAs and/or ESAs. It is imperative District B & C, City of Cape alternatives. that the consultants carefully examine the Town, comment by e-mailed However, consideration should be given to extreme fine-scale, systematic biodiversity plans letter, 11 August 2014. extent each of the proposed alternatives cover that that are available and consider alternative resulted in the likelihood of all documented species as routes that avoid all threatened and fire- well as a vast variety of different habitats being present prone vegetation remnants (fynbos and along portions of the routes. It should also be noted that renosterveld) and wetlands in this the study was aimed at assessing 2km wide corridor international biodiversity hotspot. In alternatives and as such detailed assessments are not addition, this basic assessment report must practicable at this stage of the investigations. be accompanied by more detailed maps or The assessment approach was aimed at identification the provision of shapefiles to allow and prioritisation of portions along the various commenting authorities to properly alternatives that are considered most likely to be able to interrogate the various alternatives that are sustain the most diverse and sensitive faunal and floral proposed in relation to the various populations and where more care would be required in environmental features. the planning, construction and operational phases of the project. It has been made clear in the reports developed

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Any residual negative impact on that as part of the planning phase of the development a biodiversity from any route option should walk down be undertaken of all areas considered of be mitigated and this mitigation proposed higher ecological importance identified within the by the consultants and written into the baseline 2report for the selected route within the environmental authorization as conditions selected corridor. By so doing areas of least concern can of approval once the final route has been be identified for the construction of support structures. selected. Such mitigation could include It should further be noted that where portions of routes biodiversity offsetting, strict local were identified that where considered ‘no go’ areas, it management plans to ensure maintenance has been highlighted in the report and where possible of biodiversity below power lines (e.g. no alternative alignment has been proposed or mowing but periodic, managed, summer recommended. fires on natural vegetation remnants), structures incorporated into design to deter birds and bats that are prone to collisions etc. 73. 10. It was indicted during the draft Morne Theron, Senior We acknowledge your contribution in this regard, the scoping stage that the potential impact of Environmental Practioner authrisation process will consider such impacts the proposed routes on existing urban and Pat Titmuss Regional especially when the final route is selected. The impact of development, as well as future township Manager: Enviornmental and the selected route will then be weighed against city of development currently being considered Heritage Management: Cape Town spatiall development plans. We are also within the City of Cape Town jurisdiction, District B & C, City of Cape confident that electricity suppy is a priority to the city must be assessed. Notable the current Town, comment by e-mailed and will certaily alighn its development with proposed Urban Edge amendment application for the letter, 11 August 2014. powerline development. proposed Wescape development between the R304 (Atlantis road) and M10 (Melkbosstrand road) is of relevance in this regard. This has still not been addressed. 74. 11. The draft EIR failed to identify the Morne Theron, Senior Generallly powerline developments are compartable with

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recently approved City of Cape Town: Environmental Practioner urban infrastructure developments such as landfills. Regional Landfill Site that was approved on and Pat Titmuss Regional Eskom technical team will consider the best compartable Cape Farm Bottelfontein. Manager: Enviornmental and option between the proposed powerline and landfill site. Heritage Management: Note that this is usually done when the final route Utilizing Map Page 1 and 27 of the Built, District B & C, City of Cape selection is concluded.Site specfic impacts will be Spatial History and Cultural Landscape Town, comment by e-mailed considered during walk down surveys for the selcted study as compiled by Bridget letter, 11 August 2014. route. The proposed powerline corridor is 2km which O’Donoghue/Sally Titlestad heritage means the technical team has enough room to avoid or consultants the approximate position of the minimise the impact by placing towers further away new City of Cape Town: Regional Landfill from the main activity area of the landfill site.and please Site in relation to the proposed route note the studies you are reffering they were given a go Alternative 1 and Alternative 2 (Note: ago ahead to study 4 km while the rest of the EIA team Alternative 2 co-align with route deviation were given 2 km to assess in such cases the corridor will option 1a and 1b which runs through the be able to avoid any feature and be able to put City of Cape Town’s jurisdiction) could be mitigation measures. mapped on Map 1 and Map 2 below. Further more, Eskom has protocols which they follow in When considering the physical beacons in terms land fills in relation to the powerlines. Which Map 2 (e.g. the raiwayl line), it would means they will certainly adhre to the impacts cause by appear that the preferred Alternative 1 the landfill site and powerlines built next to landfills (Option 1) falls within the 7,5km buffer of the City of Cape Town: Regional Landfill Site. The positioning of the power line along route Alternative 2 (i.e. the servitude corridor illustrated in blue that intersects with route deviation Option 1a and 1b) is not problematic as it is removed from the landfill site. However, the preferred

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Alternative 1 (Option 1) should be carefully considered and further investigation may be required to assess the compatibility with the landfill activities since it falls within the 7.5 km radius (Refer to the Map 1 below). In addition, depending on the height limitations of the servitude corridor, the impact of the landfill site will have to be assessed. The current assessment has not taken into account the establishment of the regional landfill site and the specialists need to apply their minds to this in order to ensure an inclusive assessment has been conducted. In this regard the following must be considered:

• Eskom should be concerned about potential windblown litter (e.g. plastic) blowing onto the power lines; • The proposed Eskom servitudes might result in undue height limitations for vehicles and mechanical equipment such as the crane offloading from the rail which could restrict the optimal airspace utilization of this strategic City landfill facility.

The City of Cape Town: Solid Waste

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Disposal Branch therefore also requested that Eskom provides adequate clearance for future rail sidings and access roads build for the regional site in the event of preferred Alternative 1 still being pursued. Planning of such access routes should be done at this stage to obviate future problems and ensure mitigatory measures are included in their environmental management programmes.

It is recommended that the project considers the compatibility of landfill activities with that of the alternatives provided. See attached maps 1 and 2: Location of the City of Cape Town: Regional Landfill Site in relation to 765kV route alternatives in letter submitted. 75. Draft EMPr Morne Theron, Senior Thank you for your comments. Environmental Practioner The following amendments to the draft and Pat Titmuss Regional EMPr are required: Manager: Enviornmental and Heritage Management: 1. Section 2.5.2 must indicate to whom District B & C, City of Cape the monthly progress and compliance Town, comment by e-mailed reports are to be sent; letter, 11 August 2014. 2. Section 4.1 refers to an Appendix C

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which is not attached as indicated; 3. Section 4.3.1.1 refers to an Appendix 4 which is not attached; 4. Section 5.1 refers to “mitigation provisions specific to the site in section 4.2 below” – This should read section 5.2 below; 5. Section 5.1.2 To include bins must have closed lids that are scavenger proof and to prohibit wind-blown pollution; 6. Section 5.1.2 To indicate that waste must be separated into waste streams and that recycling is to be encouraged; 7. Section 5.1.2 Toilet facilities to be discussed under separate heading; 8. Section 5.2.1 Refers to penalties being imposed – No penalty clause is included in the EMP – please ensure a separate penalty clause indicating penalties and fines and to how the payment thereof will be required; 9. Section 5.2.2 Point 2 Refers to site establishment not taking place within 30m, this should be 32m as per NEMA regulations; 10. Section 5.2.3 Sections are duplicated but not the information – please ensure each section for example “Batching

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Plants” include all necessary information under one heading; 11. Section 6 Refers to areas already disturbed – this is questioned as evidence is not provided and some areas may not have been disturbed; 12. The whole document has numerous spelling, grammar and editing mistakes. Spacing is incorrect which leads to difficulty in reading the document; 13. Please note the EMP is a legally binding working document and must provide for amendments as is needed. 76. Recommendation Morne Theron, Senior We cannot resubmit the Draft EIR. We will ensure that In light of the numerous mistakes in the Environmental Practioner all issues raised in the draft EIR, are adhered to in the report and the PPP inconsistencies the and Pat Titmuss Regional Final EIR. DEA will be looking at every comment, and all opinion is held that it might be warranted to Manager: Enviornmental and issues raised by interested and affected parties. Us not re-issue a revised draft EIR that sufficiently Heritage Management: rectifying these mistakes, would lead to our report not address all the above mentioned issues. District B & C, City of Cape being accepted as comments from interested and Town, comment by e-mailed affected partiies is very relevant. letter, 11 August 2014. 77. All of the comments, conditions and Morne Theron, Senior Comment noted concerns raised in this letter must be Environmental Practioner addressed in the revised draft EIR or Final and Pat Titmuss Regional EIR (as may be applicable) and submitted Manager: Enviornmental and to this office in the form of 1 hard copy and Heritage Management: 1 electronic CD version. District B & C, City of Cape Town, comment by e-mailed

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letter, 11 August 2014. Elandsberg Farms Stewardship Project & Smith Ndlovu and Summers Attorneys Objections 78. We already have 2 x 400kV lines which run Mike Gregor, Elandsberg Thank you for your comment. We hereby acknowledge through a highly threatened funbos area Farms Stewardship Project, your concerns and you have been registered you as an (2% left). We do noy believe it is in our comment by reply form, 13 interested and affected party. I further register your interest to have a third much bigger one. June 2014. opposition to the proposed Eskom 2nd 765kV Wehave briefed Richard Summers in this transmission line through your area. matter. 79. Dear Shawn, Richard Summers BSocSci Dear Richard, Please find attached hereto the comments LLB LLM (Environmental Thank you for your e-mail and submission on the Eskom we have prepared on behalf of our client. Law) 2nd 765kV transmission line DEIR. I hereby The comments relate to the DEIR (dated smith • ndlovu • summers acknowledge receiving your comments and the two May 2014) prepared by Nzumbululo attorneys, acting for independent reviews conducted by your specialist team. Sustainable, Energy and Environmental Elandsberg Farms I will keep you informed about the submission of the Solutions for the proposed Kappa Omega Stewardship Project, FSR and the availability of the FSR once it has been 2nd 765kV power line. comment by e-mailed letter, completed. independent visual impact We also attach two independent reviews assessment and heritage Sincerely, (marked Annexure A and Annexure B) of reviews, 11 August 2014. Shawn Johnston the heritage impact assessment and the visual impact assessment, respectively. These reviews form part of our client’s comments and should be expressly incorporated as such. I shall be most grateful if you will acknowledge receipt hereof. Kind regards,

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Richard Summers BSocSci LLB LLM (Environmental Law) smith • ndlovu • summers attorneys

See FEIR appendices submitted for letter and appendic A and B. 80. RE: PROPOSED KAPPA OMEGA 2ND 765kV Richard Summers BSocSci Thank you for your comment. POWER LINE – COMMENTS ON THE DRAFT LLB LLM (Environmental ENVIRONMENTAL IMPACT ASSESSMENT Law) REPORT DATED MAY 2014 DEA REF: smith • ndlovu • summers 14/12/16/3/3/2/352 attorneys, acting for 1. We act for Elandsberg Farms (Pty) Ltd Elandsberg Farms and Rapula Farming (Pty) Ltd. Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 81. 2. This letter contains comments, on behalf Richard Summers BSocSci Thank you for your comment. of our client, on the Draft Environmental LLB LLM (Environmental Impact Report (referred to as the “DEIR” in Law) this document) dated May 2014 prepared smith • ndlovu • summers by Nzumbululo Sustainable, Energy and attorneys, acting for Environmental Solutions for the proposed Elandsberg Farms Kappa Omega 2nd 765kV power line. Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014.

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82. 3. Elandsberg Farms (Pty) Ltd and Rapula Richard Summers BSocSci Thank you for your comment. Farming (Pty) Ltd are the registered owners LLB LLM (Environmental of the landholdings comprising Elandsberg Law) Farms1 and Elandsberg Farms (Pty) Ltd is smith • ndlovu • summers the registered owner of the landholdings attorneys, acting for comprising the Elandsberg Nature Reserve2 Elandsberg Farms (located near Hermon and in the vicinity of Stewardship Project, the preferred alternative route (Alternative comment by e-mailed letter, Route 1) for the proposed power line). As independent visual impact such, our client is interested in and affected assessment and heritage by the proposed power line. reviews, 11 August 2014.

83. 4. The purpose of this letter is to iterate our Richard Summers BSocSci Thank you for your comment. client’s concerns with the EIA process and LLB LLM (Environmental the level of assessment undertaken and Law) reflected in the DEIR. In particular, and for smith • ndlovu • summers the reasons set out in detail in these attorneys, acting for comments, we are instructed to record our Elandsberg Farms client’s opposition to the proposed power Stewardship Project, line based on the significant adverse impact comment by e-mailed letter, the power line will have on our client’s independent visual impact property. assessment and heritage reviews, 11 August 2014. 84. KEY AREAS OF CONCERN IN CONNECTION Richard Summers BSocSci Thank you for your comment. Please be aware of the WITH THE EIA PROCESS LLB LLM (Environmental fact that our team used appropriate methodology to Law) assess the alternatives of the entire development. 5. For the reasons set out in this letter, the smith • ndlovu • summers Specific impacts will be covered when the final route DEIR has failed to appropriately consider, attorneys, acting for selection is concluded.

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investigate and assess all the potential Elandsberg Farms consequences for or impacts on the Stewardship Project, environment associated with the proposed comment by e-mailed letter, power line. This includes the following: independent visual impact assessment and heritage reviews, 11 August 2014. 85. 5.1. The failure to describe appropriately all Richard Summers BSocSci Thank you for your comment. All these issues, have components of the project and associated LLB LLM (Environmental been addressed in the DEIR. However, as mentioned in infrastructure (this refers to the auxiliary Law) the DEIR these access road will be determined once we and ancillary developments such as access smith • ndlovu • summers get approval from the Departmetn of Environmental roads, construction and storage camps, etc. attorneys, acting for Affairs. The information about the access points and mentioned in the DEIR); Elandsberg Farms exact route for the access roads will be negotiated and Stewardship Project, finalised with landowners after completion and approval comment by e-mailed letter, of the EIA study. independent visual impact assessment and heritage At the same time, the construction company has not reviews, 11 August 2014. been appointed as yet. So we are not sure, whether they will have construction camps on site.

86. 5.2. The failure to assess the impacts Richard Summers BSocSci Thank you for your comment. All these issues, have associated with the auxiliary and ancillary LLB LLM (Environmental been addressed in the DEIR. However, as mentioned in developments associated with the project; Law) the DEIR these access road will be determined once we smith • ndlovu • summers get an approval from the Departmetn of Environmental attorneys, acting for Affairs. The information about the access points and Elandsberg Farms exact route for the access roads will be negotiated and Stewardship Project, finalised with landowners after completion and approval comment by e-mailed letter, of the EIA study. We did however make independent visual impact recommendations, on the maintenance so as to avoid

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assessment and heritage environmental impacts. The site specific EMP, will also reviews, 11 August 2014. have mitigation measures.

At the same time, the construction company has not been appointed as yet. So we are not sure, whether they will have construction camps on site. 87. 5.3. the failure to adequately identify and Richard Summers BSocSci Please note that the EAP and specialists are expected to assess alternatives; LLB LLM (Environmental provide an independent assessment of the project area Law) and we are confident that they are qualified and smith • ndlovu • summers experienced to conduct a report and studies for linear attorneys, acting for developments like powerlines. We are further confident Elandsberg Farms that our team used appropriate methodology to assess Stewardship Project, the alternatives of the entire development. Specific comment by e-mailed letter, impacts will be covered when the final route selection is independent visual impact concluded. As in the response above, over use of assessment and heritage absolute comments is not appreciated by the entire reviews, 11 August 2014. team. 88. 5.4. the failure to adequately address the Richard Summers BSocSci Thank you for your comment, the need and desirability issue of need and desirability; LLB LLM (Environmental was clearly described on the motivation of the project. Law) Therefore I still refer you to the same motivation from smith • ndlovu • summers ESKOM. Eskom Transmission are to honor its mandate attorneys, acting for and commitment to meet the increasing needs of the Elandsberg Farms end users, it has to establish and expand its Stewardship Project, infrastructure of Transmission power lines and comment by e-mailed letter, Substations on an ongoing basis. Due to substantial independent visual impact annual load growth, load shifts and step loads, it has assessment and heritage become necessary to reinforce the existing electrical reviews, 11 August 2014. infrastructure.

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89. 5.5. the failure to assess the impacts on Richard Summers BSocSci May you please specify the particular impacts you are heritage resources and, in particular, LLB LLM (Environmental referring to. Note that the consultation and review impacts on the natural and cultural Law) process is meant to ensure that significant heritage landscape (and the associated adverse smith • ndlovu • summers resources are protected. It is not a platform to insult impact on the visual and aesthetic qualities attorneys, acting for each other. Over use of absolute comments such as of our client’s property); Elandsberg Farms ‘failure’ is in itself failure to respect effort, qualifications Stewardship Project, and experience of dedicated heritage professionals. comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 90. 5.6. the failure to adequately assess the Richard Summers BSocSci Please note that specialist studies are expected to visual impacts of the project and the effects LLB LLM (Environmental provide an independent assessment of the project area of change on the landscape in terms of the Law) and we are confident that the specialist is qualified and heritage significance or sense of place of smith • ndlovu • summers experienced to conduct visual impact studies for linear our client’s property; attorneys, acting for developments like powerlines. We are further confident Elandsberg Farms that our specialist used appropriate methodology to Stewardship Project, assess the visual impact of the entire development. comment by e-mailed letter, Specific impacts will be covered when the final route independent visual impact selection is concluded. As in the response above, over assessment and heritage use of absolute comments is not appreciated by the reviews, 11 August 2014. entire team. The consultation and review process is meant to ensure that significant heritage resources are protected during any development. Your comments are expected to aid the process not to undermine and distort the process. The process is not a platform to trade insults. We respect your professional credibility and as a senior citizen we expect you to respect fellow

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professionals. 91. 5.7. the failure to consider and assess Richard Summers BSocSci appropriately all potential adverse impacts LLB LLM (Environmental All available and regionally known faunal and floral on biodiversity; Law) reference databases were considered or assessed in smith • ndlovu • summers order to assure that the assessments take as many of attorneys, acting for the potential species as well as important habitats into Elandsberg Farms consideration as possible given the extent of the various Stewardship Project, alternatives. comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 92. 5.8. the failure to appropriately assess the Richard Summers BSocSci Thank you for your comment. Your comment has been risks of fire and fire management issues LLB LLM (Environmental noted associated with the proposed power line; Law) smith • ndlovu • summers attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 93. 5.9. the failure to appropriately assess the Richard Summers BSocSci A report on EMF and EMI, was attached as an appendix risks of electromagnetic fields (EMF) and LLB LLM (Environmental and on the report it included the EMF and EMI electromagnetic interference (EMI) Law) associated with powerline.. As for electromegnatic associated with the proposed power line; smith • ndlovu • summers interference, despite extensive research including the attorneys, acting for WORLD HEALTH Organisation ( WHO), to date there is

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Elandsberg Farms no evidence to conclude that exposure to low level Stewardship Project, electromagnetic fields is harmful to human health comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 94. 5.10. the failure to assess the potential for Richard Summers BSocSci Thank you for your comment. Please be aware of the audible noise associated with the power LLB LLM (Environmental fact that,its not the first time that Eskom is doing a lines and the potential for such audible Law) project of such kind. We have addressed all noise noise to give rise to a nuisance; smith • ndlovu • summers impacts, through out the DEIR. We even included attorneys, acting for mitigation measures.. Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 95. 5.11. the failure to appropriately consider Richard Summers BSocSci Please note that the EAP and specialists are expected to and assess the cumulative impacts of this LLB LLM (Environmental provide an independent assessment of the project area project; Law) and we are confident that they are qualified and smith • ndlovu • summers experienced to conduct a report and studies for linear attorneys, acting for developments like powerlines. We are further confident Elandsberg Farms that our team used appropriate methodology to assess Stewardship Project, the alternatives of the entire development. Specific comment by e-mailed letter, impacts will be covered when the final route selection is independent visual impact concluded. As in the response above, over use of assessment and heritage absolute comments is not appreciated by the entire reviews, 11 August 2014. team.

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96. 5.12. the failure to assess each identified Richard Summers BSocSci Please note that the EAP and specialists are expected to potentially significant impact in a manner LLB LLM (Environmental provide an independent assessment of the project area that enables an appropriate consideration of Law) and we are confident that they are qualified and the nature, extent, and duration of the smith • ndlovu • summers experienced to conduct a report and studies for linear impact and the degree to which the impact attorneys, acting for developments like powerlines. We are further confident can be mitigated effectively; and Elandsberg Farms that our team used appropriate methodology to assess Stewardship Project, the alternatives of the entire development. Specific comment by e-mailed letter, impacts will be covered when the final route selection is independent visual impact concluded. As in the response above, over use of assessment and heritage absolute comments is not appreciated by the entire reviews, 11 August 2014. team. 97. 5.13. the failure to provide an accurate and Richard Summers BSocSci Please note that the EAP and specialists are expected to succinct comparative assessment of both LLB LLM (Environmental provide an independent assessment of the project area the positive and negative implications of Law) and we are confident that they are qualified and the preferred route for the power line and smith • ndlovu • summers experienced to conduct a report and studies for linear the alternative routes identified as part of attorneys, acting for developments like powerlines. We are further confident the EIA process. Elandsberg Farms that our team used appropriate methodology to assess Stewardship Project, the alternatives of the entire development. Specific comment by e-mailed letter, impacts will be covered when the final route selection is independent visual impact concluded. As in the response above, over use of assessment and heritage absolute comments is not appreciated by the entire reviews, 11 August 2014. team. 98. These concerns are motivated in more Richard Summers BSocSci Thank you for your comment. Please highligh the detail in the body of this letter. For the LLB LLM (Environmental numerous critical aspects for further consideration by reasons set out herein, the DEIR does not Law) our team satisfy the statutorily prescribed content smith • ndlovu • summers requirement for environmental impact attorneys, acting for assessment reports prepared in terms of Elandsberg Farms

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the NEMA EIA Regulations.3 The statement Stewardship Project, in the DEIR that an “in-depth comment by e-mailed letter, Environmental Impact Assessment has independent visual impact been undertaken to provide the assessment and heritage environmental authorities with sufficient reviews, 11 August 2014. information for the purpose of making an informed decision”4 is disputed. A perusal of the comments set out herein, as well as the comments submitted by other I&APs in connection with this project, clearly reveal that there is insufficient information regarding numerous critical aspects of the EIA process in order to enable defensible decision-making in terms of section 24 of NEMA. For this reason alone, the DEIR should be rejected. 99. DESCRIPTION AND ASSESSMENT OF ALL Richard Summers BSocSci Thank you for the clarification. COMPONENTS OF THE PROJECT LLB LLM (Environmental Law) 7. Section 2 of the National Environmental smith • ndlovu • summers Management Act5 (“NEMA”) contains attorneys, acting for principles which apply to the actions and Elandsberg Farms decisions of all organs of state which may Stewardship Project, significantly affect the environment,6 which comment by e-mailed letter, actions and decisions include any decision independent visual impact to grant or refuse an application for assessment and heritage environmental authorisation exercised in reviews, 11 August 2014. terms of section 24 of NEMA. Section

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2(4)(b) of NEMA provides the following: “Environmental management must be integrated, acknowledging that all elements of the environment are linked and interrelated, and it must take into account the effects of decisions on all aspects of the environment and all people in the environment by pursuing the selection of the best practicable environmental option.” [Own underlining]. 100. 8. Section 23 of NEMA promotes the Richard Summers BSocSci Comment noted, thank you. application of appropriate environmental LLB LLM (Environmental management tools in order to ensure the Law) integrated environmental management of smith • ndlovu • summers activities. The general objective of attorneys, acting for integrated environmental management is Elandsberg Farms to, inter alia: Stewardship Project, comment by e-mailed letter, “(b) identify, predict and evaluate the independent visual impact actual and potential impact on the assessment and heritage environment, socio- economic conditions reviews, 11 August 2014. and cultural heritage, the risks and consequences and alternatives and options for mitigation of activities, with a view to minimising negative impacts, maximising benefits, and promoting compliance with the principles of environmental management set out in section 2; [and]

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(c) ensure that the effects of activities on the environment receive adequate consideration before actions are taken in connection with them...”7 [Own emphasis]. 101. 9. In order to give effect to the general Richard Summers BSocSci Comment noted thank you. objectives of integrated environmental LLB LLM (Environmental management set out in sections 2 and 23 of Law) NEMA, section 24 of NEMA requires that the smith • ndlovu • summers potential consequences for or impacts on attorneys, acting for the environment of listed activities must be Elandsberg Farms considered, investigated, assessed and Stewardship Project, reported on to the competent authority comment by e-mailed letter, before environmental authorisation can be independent visual impact issued and the activity can commence. assessment and heritage reviews, 11 August 2014. 102. 10. Against the backdrop of the applicable Richard Summers BSocSci Thank you for your comment. legislative context for EIA processes LLB LLM (Environmental Site specific impacts will be considered during the walk undertaken in terms of NEMA, there are Law) down. several potentially significant consequences smith • ndlovu • summers It is not the objective of this report to attempt to for and impacts on the environment that attorneys, acting for demarcate all sections of power line for all the have not been dealt with in the DEIR. The Elandsberg Farms alternative corridors that would need to be mitigated. reason for this is that there are several Stewardship Project, This can only be done once the final alignments have critical components of the project which comment by e-mailed letter, been selected and tower positions have been finalized. have not been assessed now (as part of the independent visual impact current EIA process) but are rather being assessment and heritage left for investigation and assessment at reviews, 11 August 2014. some later (unidentified) stage. The DEIR

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makes it clear that several critical aspects of the project will only be evaluated and assessed “after completion and approval of the EIA study”.8 103. 11. In particular, the DEIR identifies that Richard Summers BSocSci Once the alternative has been accepted by the the following critical components of the LLB LLM (Environmental Department. A site specific EMP will be done, which will project are to be considered and finalised at Law) assist us in determining where a pylon will be placed so a later stage and only after environmental smith • ndlovu • summers as to avoid impact on the Environment. authorisation is obtained: attorneys, acting for Elandsberg Farms 11.1. the final position of pylons;9 Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 104. 11.2. the access points and routes for the Richard Summers BSocSci Noted, however we are still trying to determine which access roads;10 LLB LLM (Environmental route is feasible. The Department, still has to approve Law) one alternative from the 3. smith • ndlovu • summers attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 105. 11.3. the number and location of Richard Summers BSocSci We do not know whether the construction company, will construction camps;11 and LLB LLM (Environmental have construction camps or how will be on site. The

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Law) contractor, has not been appointed as yet, to be able to smith • ndlovu • summers determine all that information. attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 106. 11.4. whether or not the construction of Richard Summers BSocSci Construction team will determine, whether they will facilities or infrastructure for the storage of LLB LLM (Environmental require such material on site. So far our duty, is to equipment and/or material will be required Law) assess the environment. during the construction phase.12 smith • ndlovu • summers attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 107. 12. Each one of the above components of Richard Summers BSocSci Thank you for your comment. We are very much aware the project has the potential to give rise to LLB LLM (Environmental of the impacts. It is not that, these environmental significant adverse effects on the Law) impacts have not been assessed. You want us to do environment. Despite this fact, the smith • ndlovu • summers certain things, which are only done once the line has consequences of the above components of attorneys, acting for been approved. A site specific EMP will be produced, the project have not been assessed but Elandsberg Farms where all the specialist will suggest site specific have been excluded from the scope of the Stewardship Project, mitigations, so as to reduce environmental impacts. EIA process. comment by e-mailed letter, Please be adviced, that there are phases which are

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independent visual impact being followed. assessment and heritage reviews, 11 August 2014. 108. 13. Whilst the principal listed activity Richard Summers BSocSci All these issues, have been raised in the report. applied for in the context of this EIA is the LLB LLM (Environmental However, information as to where they will be placed is “construction of facilities or infrastructure Law) unknown as yet. for the transmission and distribution of smith • ndlovu • summers electricity...”13 it is also clear that the attorneys, acting for construction of access roads, construction Elandsberg Farms camps and storage facilities is recognised in Stewardship Project, the DEIR as an integral component of the comment by e-mailed letter, activities associated with the project. independent visual impact assessment and heritage reviews, 11 August 2014. 109. 14. Despite this fact the DEIR is devoid of Richard Summers BSocSci Thank you for your comment. At this point, we cannot any detailed information regarding what is LLB LLM (Environmental dictate where the access road will be. No alternative has described as “auxiliary infrastructure Law) been approved as yet, so we cannot say where they will development”.14 Using access roads as an smith • ndlovu • summers be. example, there is no indication in the DEIR attorneys, acting for as to the number of access roads which will Elandsberg Farms need to be constructed or the location of Stewardship Project, these access roads. Access roads, for comment by e-mailed letter, example, will on their own give rise to independent visual impact significant environmental effects such as assessment and heritage erosion, biodiversity impacts, visual impacts reviews, 11 August 2014. and heritage impacts. The DEIR simply states that the location of access roads will be determined in consultation with local

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communities and farmers. 110. 15. In order to satisfy the legal requirement Richard Summers BSocSci Thank you for your comment. The department is very in section 23(2)(c) of NEMA, the effects of LLB LLM (Environmental much aware of these activities. these ancillary activities on the Law) environment must receive adequate smith • ndlovu • summers consideration as part of this EIA process attorneys, acting for before actions are taken in connection with Elandsberg Farms them. Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 111. 16. The assessment of these auxiliary Richard Summers BSocSci Thank you for your comment. At this point, we cannot activities as incidental to, and as direct LLB LLM (Environmental dictate where the access road, camping site. etc, will be. consequences of, the construction of the Law) No alternative has been approved as yet, so we cannot proposed power line is required by section smith • ndlovu • summers say where they will be. 24 of NEMA and the principles of integrated attorneys, acting for environmental management (viz. that “the Elandsberg Farms effects of decisions on all aspects of the Stewardship Project, environment”15 be assessed, and that comment by e-mailed letter, these effects be assessed before independent visual impact environmental authorisation is granted16). assessment and heritage reviews, 11 August 2014. 112. 17. It cannot be suggested that these Richard Summers BSocSci Thank you for your concerns. activities can be separately assessed in LLB LLM (Environmental Once the final alignments have been selected and tower isolation of this EIA process. The approach Law) positions have been finalized, site specific mitigation adopted by the EAP and reported in the smith • ndlovu • summers measures willl then be developed. An independent DEIR gives rise to a ‘deferred assessment’ attorneys, acting for consultant is appointed, and further assessments are

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in terms of which critical aspects of project- Elandsberg Farms done. related environmental impacts are deferred Stewardship Project, for ‘assessment’ after the project has been comment by e-mailed letter, Site specific mitigation measures will then be developed approved. This type of ‘deferred independent visual impact for areas where re-alignment is not an option.This will assessment’ is not compatible with NEMA or assessment and heritage allow for the further development of sitespecific the EIA Regulations. reviews, 11 August 2014. construction and operational mitigation measures. 113. 18. This ‘deferred assessment’ approach Richard Summers BSocSci Thank you for your comment. Our EAP is highly adopted by the EAP undermines the LLB LLM (Environmental qualified, and has vast amount of experience. I doubt, objectives of the EIA process, which Law) that she would neglect her responsibility. include: smith • ndlovu • summers attorneys, acting for 18.1. To predict and evaluate impacts on Elandsberg Farms the environment with a view to minimising Stewardship Project, negative impacts.17 comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 114. 18.2. To limit negative impacts on the Richard Summers BSocSci Thank you for your comment. I would like to believe environment through adopting the Impact LLB LLM (Environmental that, such will be adhered to when producing the site Mitigation Hierarchy tool. This tool Law) specific EMP. Site specific mitigation measures can then considers different tiers of impact smith • ndlovu • summers be developed for areas where re-alignment is not an mitigation. The first tier is impact attorneys, acting for option. avoidance; then minimisation if impacts Elandsberg Farms . cannot be avoided; and then lastly (where Stewardship Project, impacts cannot be sufficiently avoided or comment by e-mailed letter, minimised), compensation for ecological independent visual impact loss to ensure the protection of equivalent assessment and heritage or greater ecological assets than those reviews, 11 August 2014.

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lost.18 115. 18.3. To ensure adequate public Richard Summers BSocSci Adequate public participation, was undertaken by the participation in all aspects of decisions that LLB LLM (Environmental EAP and the TEAM. Several meetings where held with may affect the environment.19 Law) farmers associations, departments and different smith • ndlovu • summers community members. Their concerns, have attorneys, acting for acknowledged and incoperated within this issues and Elandsberg Farms response report. Some of the issues, regarding the first Stewardship Project, 765kv line have been reported to Eskom. We made sure comment by e-mailed letter, that public issues, are taken serioulsy. independent visual impact assessment and heritage reviews, 11 August 2014. 116. 18.4. To select the option that will provide Richard Summers BSocSci Thank you for your comment. the most benefit and cause the least LLB LLM (Environmental damage to the environment in the short Law) and long term.20 smith • ndlovu • summers attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 117. 19. Without describing and assessing the Richard Summers BSocSci Thank you for your comment. At this point, we cannot impacts associated with these ancillary LLB LLM (Environmental dictate where the access road,construction camps will activities the DEIR fails to predict or Law) be. No alternative has been approved as yet, so we evaluate the impacts that such activities smith • ndlovu • summers cannot say where they will be. Public concerns are will have on the receiving environment. attorneys, acting for adhered to, even during construction and that is why

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Accordingly, the practical effect of this Elandsberg Farms Eskom appoints an ECO and CLO who will be there to ‘deferred assessment’ is that negative Stewardship Project, ensure that the people are protected during impacts cannot be avoided and effective comment by e-mailed letter, construction. public participation on these issues is independent visual impact prevented. Accordingly, the best practicable assessment and heritage environmental option cannot be achieved reviews, 11 August 2014. through such an approach in terms of which impacts are considered only after the project has been authorised. 118. 20. It is imperative that a proper Richard Summers BSocSci Thank you for your concerns. assessment of the impact of ancillary LLB LLM (Environmental Once the final alignments have been selected and tower activities associated with the power line be Law) positions have been finalized, site specific mitigation assessed as part of this EIA process and smith • ndlovu • summers measures willl then be developed. An independent before the competent authority renders a attorneys, acting for consultant is appointed, and further assessments are decision in connection with the application. Elandsberg Farms done. This must include the assessment of all Stewardship Project, impacts associated with the siting and comment by e-mailed letter, Site specific mitigation measures will then be developed location of pylons, access roads, independent visual impact for areas where re-alignment is not an option.This will construction camps and storage facilities. assessment and heritage allow for the further development of sitespecific The assessment must be predicated upon reviews, 11 August 2014. construction and operational mitigation measures. the requisite level of information regarding the auxiliary infrastructure development. It is also imperative that I&APs be afforded an opportunity, through the EIA public participation process, to comment on the applicant’s assessment of all such project- related impacts. 119. ALTERNATIVES Richard Summers BSocSci Thank you for your comment.

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21. The EIA Regulations provide that LLB LLM (Environmental alternatives to the proposed activity, Law) including the advantages and smith • ndlovu • summers disadvantages that the proposed activity or attorneys, acting for alternatives may have on the environment Elandsberg Farms and the community affected by the activity, Stewardship Project, must be considered and assessed as part of comment by e-mailed letter, the assessment phase of the EIA process independent visual impact which culminates in the production of such assessment and heritage information in an environmental impact reviews, 11 August 2014. report such as the DEIR.21 120. 22. The approach to the identification and Richard Summers BSocSci Thank you for your comment. assessment of alternatives in this project LLB LLM (Environmental Eskom’s mandate remains to provide electricity in an was constrained at the outset, as the Law) efficient and sustainable manner, including the applicant itself pre-determined the smith • ndlovu • summers generation, transmission and distribution of electricity, alternative routes.22 It is clear from the attorneys, acting for the latter including wholesale and retail sales. specialist reports that the specialists (and Elandsberg Farms Eskom is a critical and strategic contributor to the South the EAP) were not involved in the route Stewardship Project, African government’s goal of ensuring security of selection process or the identification of comment by e-mailed letter, electricity supply in the country as well as economic appropriate development alternatives.23 In independent visual impact growth and prosperity the result the EIA process has been assessment and heritage constrained. The statement in the DEIR that reviews, 11 August 2014. “this study includes describing the project, determining the project alternatives, environmental management plan for the proposed project attached in this Report”24 is, therefore, not correct. 121. 23. The DEIR records that all routes were Richard Summers BSocSci Thank you for your comment. We are not disputing the

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studied thoroughly by scientists in the EIA LLB LLM (Environmental fact that Eskom chose alternatives 1, 2, and 3 with process, leading to the selection of Law) deviations. However, when the specialists did their Alternative Route 1 as the preferred smith • ndlovu • summers assessments they also came up with the different route.25 This statement is also not correct. attorneys, acting for conclusion. That does not necessarily mean, they were Eskom determined the alternative routes Elandsberg Farms forced to go for that prefered alternative. Had it not before the EIA process commenced and the Stewardship Project, been, the better route then I doubt the specialists would EAP and specialists were constrained to a comment by e-mailed letter, have recommended that alternative. We strongly believe consideration of these pre-determined independent visual impact that our specialists, are highly qualified and would never alternative routes only.26 assessment and heritage put their jobs at risks.hence they are contracted to be reviews, 11 August 2014. independent and study the routes independently and please note that they were on site looking for differenrent aspects there was no at time when ESKOM told them which route they should choose between the 3 routes and the deviaitions. Eskom takes into consideration the techical issues costs and also the connections of these substations and powerlines all these are Eskom responsbility to connect these substations and it will not be technical, or environmental viable to take the longest route to connects the substation 122. 24. The competent authority is required, Richard Summers BSocSci Thank you for your comment. We appointed specialists, where appropriate, to consider “any LLB LLM (Environmental inorder to determine a more feasible alternative. reasonable and feasible alternatives to the Law) Physical changes( re-alignment) of pylons, will be activity which is the subject of the smith • ndlovu • summers conducted during the compilation of the site specific application and any feasible and reasonable attorneys, acting for EMP. modifications or changes to the activity that Elandsberg Farms may minimise harm to the environment”.27 Stewardship Project, Internationally-recognised best practice for comment by e-mailed letter,

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avoiding or reducing the environmental independent visual impact impacts of power lines recognises that assessment and heritage alternative routes must be determined with reviews, 11 August 2014. reference to the EIA process. In this sense, the EIA process is rendered ineffective if the role of the EIA process is limited to simply identifying the impacts associated with a pre-determined alternative. The reason being that this flawed methodology precludes the EIA process from being able to respond to significant adverse environmental impacts. 123. 25. The effect of the applicant pre- Richard Summers BSocSci Thank you for your comment. Before Eskom appointed determining the alternative routes has been LLB LLM (Environmental the independent consultants, they had their own team to constrain the ability of the specialists to Law) of specialists evaluating the alternatives. Including high respond to negative impacts identified smith • ndlovu • summers qualified engineers and environmentalist to assess the along the route corridors. As such, attorneys, acting for routes whether they are viable or note, and further specialists were not in a position to suggest Elandsberg Farms more the 765kv have been constructed in the country modifications or changes to the route to Stewardship Project, and all the impacts are known. avoid significant adverse environmental comment by e-mailed letter, impacts. independent visual impact assessment and heritage reviews, 11 August 2014. 124. 26. The Department of Environmental Richard Summers BSocSci Thank you. I would like to believe, that we aware of Affairs and Development Planning LLB LLM (Environmental these guidelines and hence we where appointed to do (“DEA&DP”) have published a number of Law) this assessment. EIA guidelines which are useful in smith • ndlovu • summers explaining the general legislative intent attorneys, acting for

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behind legal requirements under the EIA Elandsberg Farms Regulations. It is clear from the DEA&DP Stewardship Project, Guideline on Alternatives that the EIA comment by e-mailed letter, process itself can confirm an important role independent visual impact in the identification of alternatives. The assessment and heritage reason for this is that it is the assessment reviews, 11 August 2014. of potential impacts and the gathering of information during the assessment phase which should inform the alternative options. The following is quoted from the Guideline on Alternatives in support of this assertion:

“Every EIA process must therefore identify and investigate alternatives, with feasible and reasonable alternatives to be comparatively assessed.”28 [Own underlining].

“The identification of alternatives should be broad, objectively done and well documented.”29 [Own underlining].

“The “feasibility” and “reasonability” of and the need for alternatives must be determined by considering, inter alia, (a) the general purpose and requirements of the activity, (b) need and desirability, (c) opportunity costs, (d) the need to avoid

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negative impacts altogether, (e) the need to minimise unavoidable negative impacts, (f) the need to maximise benefits, and (g) the need for equitable distributional consequences.”30 [Own underlining]. 125. 27. With regard to the minimum Richard Summers BSocSci We are confident that our heritage specialists adhered requirements for heritage impact LLB LLM (Environmental to minimum requirements of both SAHRA and Heritage assessment, section 38(2)(f) of the Law) Western Cape. The heritage team has vast experience in National Heritage Resources Act 31 smith • ndlovu • summers Heritage Impact Assessments. (“NHRA”) states the following: attorneys, acting for Elandsberg Farms This paragraph makes reference to minimum “The responsible heritage resources Stewardship Project, requirements of the HIA and cites Section 38(2)(f) of authority must specify the information to be comment by e-mailed letter, the NHRA (Act 25 of 1999). This is not correct because provided in a report required in terms of independent visual impact the cited section addresses directive to responsible subsection (2)(a): Provided that the assessment and heritage heritage authority to respond within 14 days to issued following must be included: reviews, 11 August 2014. notifications for proposed development. Section 38(2) ... does not have subsection (f) as stated in the Summers’ (f) if heritage resources will be adversely paragraph 27. Nonetheless, the HIA exercise we have affected by the proposed development, the conducted thus far fully satisfied Section 38(2) of the consideration of alternatives...” [Own NHRA 25 of 1999. Notice of Intend to Develop and the emphasis]. Need and Desirability (NID) Applications were submitted to both the South African Heritage Resources Agency (SAHRA) and Heritage Western Cape (HWC) (HWC Case 12004JL09E). Both these heritage compliancy authorities issued their responses and directives that Phase 1 HIA study was necessary, hence the HIA exercise we conducted. HWC issued their directive and specified the nature of the heritage assessment deemed

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necessary for the nature of the proposed powerline development. We have followed and fulfilled these directives to later.

We have fully complied with Section 38(2)(a) by submitting the relevant applications, notifications and NID. Beyond that, in line with Section 38(3), we have engaged and met with HWC officials to discuss their specifications for the HIA study with regards to the proposed powerline routes and associated alternatives (as specified in Sec. 38(3)(f), as well as the extent of the proposed powerline servitudes to be covered in the HIA study. 126. 28. The DEA&DP Guideline for Involving Richard Summers BSocSci Please note that selection of routes is not determined by Heritage Specialists in EIA Processes, dated LLB LLM (Environmental heritage studies. Selection of routes is a technical June 2005, provides the following with Law) exercise that is determined by factors such as demand regard to “Clarifying Appropriate smith • ndlovu • summers for electricity and existence of infrastructure such as Development Alternatives”: attorneys, acting for substations and power stations. Eskom has the mandate Elandsberg Farms to transmit and distribute electricity to where it is “Alternatives considered in the EIA process Stewardship Project, required. There are responsible for designing can include location and/or routing comment by e-mailed letter, Transmission network. Heritage specialists, SAHRA and alternatives, layout alternatives, process independent visual impact Heritage Western Cape were involved in the scoping and/or design alternatives, scheduling assessment and heritage phase and subsequent EIA Process. As far as we are alternatives or input alternatives. Any reviews, 11 August 2014. concerned all heritage aspects were adequately covered. development proposal may include a range of possible alternatives from some or all of Summers, et. al. paragraph 28 addresses the role of these various categories of alternatives. heritage specialists in EIA specifically with reference to The “no- go” alternative in EIA provides a selecting alternatives. The information provided is

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benchmark against which to evaluate correct. However, it is our considered interpretation that potential impacts of the proposed project the guidelines Summers, et. al. refers to were not alternatives. The heritage specialist should necessarily referring to heritage sub-discipline be involved in the selection of appropriate specialists’ studies. We are the responsible Principle development alternatives, which clearly Investigator (PI) for the HIA Phase 1 Report. In respond to significance of heritage impacts. conducting this study, we commissioned additional input from independent heritage sub-discipline specialists Alternatives are best considered in the pre- such as built environment, cultural and spatial history, application and early stages of the EIA, archaeology, palaeontology and physical cultural where the proposal has greater flexibility properties risk managers. As Principle Investigator, we and opportunities to avoid or prevent are competent to engage with both the developer and significance impacts are more easily the compliance authorities regarding the proposed achievable.”32 [Own underlining]. development, its location and alternatives to be considered in the Phase 1 HIA as stipulated in both the NHRA, Act 25 of 1999 Section 38 and the SAHRA and HWC HIA Guidelines.

It is correct that Eskom SOC proposed a specific development in a specific geographic area where the proposed transmission lines should connect fixed pre- existing points. The proposed powerline has to T-off from existing and fixed Kappa Sub Station location and traverse through section of the Western Cape to another existing and fixed Omega Sub Station location. Whichever route the proposed powerline follows, it has to link these fixed points and logic framework dictates that the study area has to be defined around these fixed points and the powerline may only be considered within

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a viable corridor between the said fixed points. Once the developer’s planners, engineers and the EAP and GIS specialists proposed potential servitude routes within study area, we did not find any reason to primarily dismiss the proposed alternatives nor did we think it necessary to propose additional alternatives for HIA study before considering the proposed alternatives on the table. As such, we had the relevant notifications and applications submitted to the heritage compliance authorities. HWC issued their directives on the routes and alternatives. We analysed their directives and made further submissions and engaged the authority until three (3) proposed alternatives and their extent were defined for the HIA study. Based on this information, we then commissioned heritage sub-discipline specialists to assess the defined route servitudes. Summers, et. al. will be correct in pointing out that the Built Environment, Spatial History and Cultural Landscape specialists did not participate in selecting proposed routes. Our interpretation of this responsibility is that we are the primary HIA Study PI; we took that responsibility because we have the relevant heritage and management qualifications, experience and professional standing in heritage resources management to undertake the task and we did. After all, we extensively engaged with relevant heritage authority on the finalisation of the study servitudes. There is no logic in the notion that limited participation of a sub-discipline

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specialists would invalidate the alternative selection exercise. 127. 29. Whilst the Guideline for Involving Richard Summers BSocSci The purpose of the scoping phase of the EIA process Heritage Specialists quoted above identifies LLB LLM (Environmental covers your concerns. Scoping phase is the ideal way of heritage indicators and constraints as key Law) involving specialist in accordance with the legislation, if criteria for the selection of alternatives, the smith • ndlovu • summers there are serious heritage concerns in the route Built Environment, Spatial History and attorneys, acting for selection specialists can discard sensitive routes or Cultural Landscape Report (“Cultural Elandsberg Farms recommend further studies. Landscape Report”) notes that: Stewardship Project, comment by e-mailed letter, “ESKOM Transmission determined route independent visual impact alternatives before the beginning of the assessment and heritage project, based on existing ESKOM lines and reviews, 11 August 2014. servitudes, feedback from the first 765kV line application and the need to extend electrical power supply to the Western Cape. Specialists were not involved in route selection.”33 [Own underlining]. 128. 30. As a result of Eskom’s predetermined Richard Summers BSocSci It is unfortunate that your comment is based on lack of alternative routes, the study area itself was LLB LLM (Environmental information about the EIA process and our engagements geographically limited. Specialists were Law) with the relevant authorities. Before the proposed limited to study corridors of 1 kilometre on smith • ndlovu • summers powerline development is subjected to EIA studies either side of the proposed routes.34 At the attorneys, acting for Eskom conducts feasiblity studies which are key in route outset, therefore, studies undertaken by Elandsberg Farms selections as well technical considerations. The proposed the specialists did not inform the route Stewardship Project, corridors are 2km wide for all the specialist studies and selection. The effect of this is that the route comment by e-mailed letter, 4km for heritage studies. I believe any corridor wider selection has not been informed by an independent visual impact than 4km for a powerline development will be urealistic. assessment of information on the assessment and heritage Powerline construction is determined by many factors ie

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anticipated impacts of the proposed power reviews, 11 August 2014. technical considerations, environmental issues, funding line. The assessment of alternatives does and demand. Also note that there were three not therefore respond to specialist input alternatives for the proposed powerline development generated through the EIA process which and I am confident that you are aware of the would enable an appropriate response to advantages of having more than 3 alternatives for a particular environmental constraints or the single development. significance of impacts. 129. 31. It is also clear from the DEIR that the Richard Summers BSocSci Thank you for your comment. Are you aware of the exclusion of certain project alternatives by LLB LLM (Environmental environmental implications of having a 765 kv powerline the EAP has more to do with the cost Law) underground. sensitivity of the applicant than valid smith • ndlovu • summers When burying cables, the soil must be exchanged. environmental considerations. For example, attorneys, acting for Furthermore, not only do the cable routes need to be the alternative of situating the proposed Elandsberg Farms kept free from deeply rooted plants, they may not be power line underground is noted in the Stewardship Project, built on for any other purpose. In addition, underground DEIR but immediately dismissed for the comment by e-mailed letter, cables radiate heat. This has an effect on soil humidity, following reason: “[T]he preference with independent visual impact which, for example, can lead to drainage or drying out overhead lines is mainly on the grounds of assessment and heritage of marshes. The laying of underground cable also costs and intrusive nature”.35 reviews, 11 August 2014. requires the construction of cable jointing structures every 500 to 700 meters, as well as compensation facilities along the cable route. As a result, existing biotopes are permanently cut up. As long-term experience with underground 22-kV cable is lacking, the effects on the soil of decomposition of the plastic cable sheathing remain unknown. 130. 32. It is also clear that key to the selection Richard Summers BSocSci Eskom’s purpose is to provide sustainable of Alternative Route 1 as the preferred LLB LLM (Environmental electricity solutions to grow the economy and improve route was influenced by it being the “most Law) the quality of life of the people in South Africa and the direct” route between the Kappa and smith • ndlovu • summers region. Their mandate remains to provide electricity n

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Omega substations.36 In the discussion of attorneys, acting for an efficient and sustainable manner, including the project alternatives, the DEIR notes that: Elandsberg Farms generation, transmission and distribution of electricity. Stewardship Project, Please note that regardless of route 1 being the “As part of the planning exercise, the comment by e-mailed letter, preferred route it was subjected to serious scrutiny like division of Eskom Holdings SOC Limited independent visual impact any other alternatives. responsible for Transmission investigated assessment and heritage different alternatives to the preferred reviews, 11 August 2014. powerline. They identified the preferred technical, design and cost effective options for the proposed development. The power line will be approximately 415 km long traversing through terrain ranging from the uniform Karoo landscape to the mountains and hills across the region. Hence, preference is given to developing a power line running directly from and to the proposed substations at Kappa and Omega Sites. The shortest possible route will also ensure minimum impact on the receiving environment.”37 [Own underlining]. 131. 33. It is not necessarily the case that the Richard Summers BSocSci We agree with you and that is the major purpose of the shortest possible route will ensure the least LLB LLM (Environmental EIA and specialist studies. We are confident the studies impact on the receiving environment. This Law) also put your concerns into consideration and meet the claim (that the shortest possible route will smith • ndlovu • summers standards stipulated in the NEMA in its current form also ensure minimum impact on the attorneys, acting for unless if there was an over night amendment of the Act. receiving environment) is only justifiable if Elandsberg Farms that conclusion is supported by a Stewardship Project, comprehensive EIA process, which includes comment by e-mailed letter,

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a detailed comparative assessment of the independent visual impact different alternatives that enable the best assessment and heritage practicable environmental option to be reviews, 11 August 2014. implemented. As the EIA process undertaken to date fails to achieve the level of assessment required in terms of NEMA, it follows that the claim that Alternative Route 1 ensures the least impact on the receiving environment is unsubstantiated. 132. 34. The purpose of an EIA process is to Richard Summers BSocSci Please note that before the powerline development serve as an integrated environmental LLB LLM (Environmental proposal is subjected to EIA process, Eskom conducts management tool, “to identify, predict and Law) feasibility studies and the selection of alternatives is evaluate the actual and potential impact on smith • ndlovu • summers also informed by feasibility studies. Furthermore the the environment, socio-economic conditions attorneys, acting for scoping phase in the EIA process is meant to cover your and cultural heritage, the risks and Elandsberg Farms concerns. During scoping phase an disirable routes may consequences and alternatives and options Stewardship Project, be discarded or diviated before being considered for full for mitigation of activities, with a view to comment by e-mailed letter, EIA studies. minimising negative impacts, [and] independent visual impact maximising benefits...”38 The EIA process assessment and heritage should accordingly inform both the planning reviews, 11 August 2014. and the construction of the power lines. The EIA process should be utilised for informing the selection of alternative power line routes on the basis of the information on environmental impacts gathered during the EIA process. 133. 35. The assessment of alternatives “should Richard Summers BSocSci Your allegation of bias does not hold water, specialist include a comprehensive comparison of all LLB LLM (Environmental were selected on the basis of their independence,

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potential impacts, both direct and indirect Law) qualification and experience. Your comment is and cumulative, on the environment”.39 smith • ndlovu • summers debatable. Our entire team is suitably qualified and The level of interrogation required to attorneys, acting for experienced to conduct EIA studies for linear discharge the onus of assessing alternatives Elandsberg Farms developments. is accordingly a full disclosure of all impacts Stewardship Project, associated with each alternative and a comment by e-mailed letter, comparative consideration of all such independent visual impact impacts. Furthermore, an assessment of assessment and heritage alternatives must “provide the opportunity reviews, 11 August 2014. for an unbiased, proactive consideration of options, to determine the most optimal course of action”.40 134. 37. For the reasons set out herein, there is Richard Summers BSocSci Please note that regardless of route 1 being the insufficient information in the DEIR to LLB LLM (Environmental preferred route it was subjected to serious scrutiny like support the contention that the assessment Law) any other alternatives. The entire team is qualified and satisfies the above requirements. A smith • ndlovu • summers highly experienced to handle impact assessment for a comprehensive and detailed analysis of all attorneys, acting for powerline project. These impacts where analysed and impacts associated with each of the Elandsberg Farms assessed by our specialists. alternative routes has not been provided Stewardship Project, and there is no evidence of how the EAP comment by e-mailed letter, has undertaken comparative consideration independent visual impact of all impacts. The DEIR’s clear preference assessment and heritage for Alternative Route 1 at an early stage of reviews, 11 August 2014. the EIA process appears to have precluded the scope for an unbiased and objective consideration of options. 135. 38. The methodology adopted in the DEIR Richard Summers BSocSci To suggest that the EIA process is fundamentally flawed regarding the assessment of alternatives is LLB LLM (Environmental is a insult to the entire team. The entire team is

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flawed. In order to enable I&APs to engage Law) qualified and highly experienced to handle impact meaningfully on this issue, the following smith • ndlovu • summers assessment for a powerline project. Please note that information is required: attorneys, acting for before the powerline development proposal is subjected Elandsberg Farms to EIA process, Eskom conducts feasibility studies and 38.1. A comprehensive description is Stewardship Project, the selection of alternatives is also informed by required of how the route alternatives were comment by e-mailed letter, feasibility studies. Furthermore the scoping phase in the selected or decided upon, and in terms of independent visual impact EIA process is meant to cover your concerns. During what criteria; and assessment and heritage scoping phase an undisirable routes may be discarded reviews, 11 August 2014. or diviated before being considered for full EIA studies. 136. 38.2. a comparative assessment of the Richard Summers BSocSci The proposed powerline alternatives were subjected to positive and negative implications of each LLB LLM (Environmental comparative assessment by all our specialists. As of the identified alternative routes (based Law) indicated before the route selection processing informed on a rigorous assessment of each smith • ndlovu • summers by technical, financial, demand and environmental potentially significant impact associated attorneys, acting for considerations. A feasibility study was conducted prior with each of the identified alternative Elandsberg Farms to the EIA process. Furthermore the scoping study routes); and Stewardship Project, subjected the selected alternatives to serious scrutny comment by e-mailed letter, before being subjected to the full EIA studies. We are independent visual impact confident that the EIA process significantly assessment and heritage coprehensive. reviews, 11 August 2014. 137. 38.3. a comprehensive description is Richard Summers BSocSci Please note that before the powerline development required of how the preferred route LLB LLM (Environmental proposal is subjected to EIA process, Eskom conducts alternative was selected in terms of this EIA Law) feasibility studies and the selection of alternatives is process and in terms of what criteria. smith • ndlovu • summers also informed by feasibility studies. Furthermore the attorneys, acting for scoping phase in the EIA process is meant to cover your Elandsberg Farms concerns. During scoping phase an disirable routes may Stewardship Project, be discarded or diviated before being considered for full comment by e-mailed letter, EIA studies.Eskom has a mandate to provide electricity

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independent visual impact for the nation. They know which area is in need of assessment and heritage electricity. reviews, 11 August 2014. 138. NEED AND DESIRABILITY Richard Summers BSocSci Thank you for your comment. The need and desirability LLB LLM (Environmental was clearly addressesd on the project motivation. 39. The DEIR fails to adequately address Law) the issue of need and desirability and any smith • ndlovu • summers statements made therein are limited to a attorneys, acting for consideration of the need for additional Elandsberg Farms transmission capacity in the Western Cape. Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 139. 40. Based on Eskom’s mandate, the inquiry Richard Summers BSocSci Thank you for your comment. These site specific undertaken by the EAP is limited to LLB LLM (Environmental mitigation measures, will be included in the site specific recognising “the identified need for the Law) EMP. proposed development to proceed” and the smith • ndlovu • summers fact that “although there could be negative attorneys, acting for impacts associated with the proposed Elandsberg Farms development, there are several possible Stewardship Project, and effective mitigating measures that comment by e-mailed letter, could be implemented to minimise or independent visual impact eliminate negative impacts”.41 assessment and heritage reviews, 11 August 2014.

140. 41. Need and desirability, as a concept Richard Summers BSocSci Thank you for your comment. Before Eskom even required to be considered in terms of the LLB LLM (Environmental appoints independent consultants they already know the

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EIA Regulations, requires something more Law) need for that line. Meaning, they do feasability than a limited consideration of the positive smith • ndlovu • summers studies.We as consultants don’t sit down and make up outcomes of a proposed activity, coupled attorneys, acting for the need for the powerline.It might seem generic to with an attempt at mitigating adverse Elandsberg Farms you, but please be aware of the fact that Eskom environmental effects (which the current Stewardship Project, undergoes several processes prior to involving anyone EIA process is limited to). Rather the comment by e-mailed letter, else. We as independent consultants and specialists, enquiry into need and desirability requires a independent visual impact then do further studies. These studies(reports) holistic and integrated consideration of the assessment and heritage submitted, respond to all the issues that you have. positive and negative environmental effects reviews, 11 August 2014. of the proposed development. A balancing exercise is required to weigh up the relative pros and cons of the proposed development. This exercise requires the accurate prediction, evaluation and assessment of all environmental, economic and social consequences of the 765kV power line. 141. 42. As indicated above, the DEIR has only Richard Summers BSocSci Thank you for your comment. Before Eskom even motivated for the need for the proposed LLB LLM (Environmental appoints independent consultants they already know the power line from the general perspective of Law) need for that line. Meaning, they do feasability the country’s energy requirements 42 . A smith • ndlovu • summers studies.We as consultants don’t sit down and make up comprehensive integration of all relevant attorneys, acting for the need for the powerline.It might seem generic to environmental considerations into the Elandsberg Farms you, but please be aware of the fact that Eskom strategic socio-economic context is absent Stewardship Project, undergoes several processes prior to involving anyone from the DEIR. In other words, the DEIR comment by e-mailed letter, else. We as independent consultants and specialists, fails to include a consideration of both the independent visual impact then do further studies. These studies(reports) identified positive socio-economic benefits assessment and heritage submitted, respond to all the issues that you have. and the environmental “trade-offs” or reviews, 11 August 2014.

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adverse effects associated with the benefits of meeting energy requirements through the implementation of this project. In the EIA context the country’s energy requirements cannot be considered in isolation of and without due regard to the environmental costs associated with this project. 142. 43. According to the DEA&DP Guideline on Richard Summers BSocSci Thank you for your comment. Before Eskom even Need and Desirability43, the competent LLB LLM (Environmental appoints independent consultants they already know the authority, when considering an application Law) need for that line. We as consultants don’t sit down and for environmental authorisation, must: smith • ndlovu • summers make up the need for the powerline.It might seem “...have regard to a number of specific attorneys, acting for generic to you, but please be aware of the fact that relevant considerations, including Elandsberg Farms Eskom undergoes several processes prior to involving specifically having to consider “the need Stewardship Project, anyone else. We as independent consultants and and desirability of the activity”. The EIA comment by e-mailed letter, specialists, then do further studies. Regulations specify that the basic independent visual impact assessment report, scoping report and assessment and heritage environmental impact report must provide a reviews, 11 August 2014. description of the need and desirability of the proposed activity and identified potential alternatives to the proposed activity. It requires that both need and desirability must be considered by the developer, his/her independent environmental assessment practitioner (EAP), the specialists, and the competent authority. Interested and affected parties

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must also be afforded an opportunity to make representation in terms of their views in terms of the need and desirability considerations.”44 [Own underlining]. .... “During the actual assessment stages of an EIA process the need and desirability must be specifically assessed and evaluated, including specialist input/studies as required.”45 [Own underlining]. 143. 44. Additionally, the draft National Need Richard Summers BSocSci Thank you for your comment. Before Eskom even and Desirability Guideline published by the LLB LLM (Environmental appoints independent consultants they already know the Minister of Environmental Affairs in the Law) need for that line. We as consultants don’t sit down and Government Gazette on 5 October 2012 46 smith • ndlovu • summers make up the need for the powerline.It might seem explains the concept of “need and attorneys, acting for generic to you, but please be aware of the fact that desirability” in the following terms: Elandsberg Farms Eskom undergoes several processes prior to involving Stewardship Project, anyone else. We as independent consultants and “With regard to having to consider need comment by e-mailed letter, specialists, then do further studies. and desirability, the definition of independent visual impact “evaluation” must also be noted. NEMA assessment and heritage defines “evaluation” as “the process of reviews, 11 August 2014. ascertaining the relative importance or significance of information, in the light of people’s values, preferences and judgments, in order to make a decision”. When receiving an application for identified developmental need, the competent authority should evaluate such an

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application in order to determine the desirability of the receiving environment considering its sensitivity. It is, therefore, extremely important that the applicant’s motivation covers all aspects, especially those which may be queried by other departments relevant to the application type.” 47 [Own underlining]. 144. 45. The DEIR is ominously silent on the Richard Summers BSocSci Thank you for your comment. Before Eskom even enquiry into the need and desirability of the LLB LLM (Environmental appoints independent consultants they already know the project. There is therefore no indication of Law) need for that line. We as consultants don’t sit down and how the enquiry into need and desirability smith • ndlovu • summers make up the need for the powerline.It might seem has been undertaken, if at all. The only attorneys, acting for generic to you, but please be aware of the fact that logical conclusion is that this issue – which Elandsberg Farms Eskom undergoes several processes prior to involving is a key requirement of the EIA Regulations Stewardship Project, anyone else. We as independent consultants and – has not been addressed in the DEIR. The comment by e-mailed letter, specialists, then do further studies. result is that there is insufficient independent visual impact information for interested and affected assessment and heritage parties to comment on how this key reviews, 11 August 2014. requirement of the EIA Regulations has been addressed. 145. 46. The DEIR must first meet the legal Richard Summers BSocSci Thank you for your comment. Before Eskom even requirement of specifically considering need LLB LLM (Environmental appoints independent consultants they already know the and desirability in evaluating each impact, Law) need for that line. We as consultants don’t sit down and both negative and positive, in terms of each smith • ndlovu • summers make up the need for the powerline.It might seem of the aspects of the environment.48 The attorneys, acting for generic to you, but please be aware of the fact that current draft released for public comment Elandsberg Farms Eskom undergoes several processes prior to involving fails to achieve this. Stewardship Project, anyone else. We as independent consultants and

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comment by e-mailed letter, specialists, then do further studies. Once again, the independent visual impact entire team is qualified and highly experienced to handle assessment and heritage impact assessment for a powerline project. Please note reviews, 11 August 2014. that before the powerline development proposal is subjected to EIA process, Eskom conducts feasibility studies and the selection of alternatives is also informed by feasibility studies. Furthermore the scoping phase in the EIA process is meant to cover your concerns. During scoping phase an disirable routes may be discarded or diviated before being considered for full EIA studies. 146. 47. While addressing the country’s need for Richard Summers BSocSci Thank you for your comment. Before Eskom even energy resources is an issue of strategic LLB LLM (Environmental appoints independent consultants they already know the importance, that need cannot by itself be Law) need for that line. We as consultants don’t sit down and decisive of the need and desirability of the smith • ndlovu • summers make up the need for the powerline.It might seem proposed power line without regard to the attorneys, acting for generic to you, but please be aware of the fact that associated impacts on the receiving Elandsberg Farms Eskom undergoes several processes prior to involving environment. The DEIR has not motivated Stewardship Project, anyone else. We as independent consultants and that the benefits associated with the comment by e-mailed letter, specialists, then do further studies. Once again, the project, and the public good to be achieved independent visual impact entire team is qualified and highly experienced to handle by the proposed power line outweigh the assessment and heritage impact assessment for a powerline project. Please note negative impacts of the proposed power reviews, 11 August 2014. that before the powerline development proposal is line on the environment and the affected subjected to EIA process, Eskom conducts feasibility community. Based on the numerous studies and the selection of alternatives is also informed deficiencies in the assessment and by feasibility studies. Furthermore the scoping phase in evaluation of each project- related impact, the EIA process is meant to cover your concerns. During the DEIR does not enable the “evaluation” scoping phase an disirable routes may be discarded or of need and desirability. On this basis alone diviated before being considered for full EIA studies. the DEIR should be rejected by the

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competent authority. 147. CUMULATIVE IMPACTS Richard Summers BSocSci We acknowledge your contribution and we believe that LLB LLM (Environmental our specialists fulfilled the requirements of section 31 48. Regulation 31(2)(l) of the EIA Law) (2) (1) of the EIA process. South Africa has probably the Regulations requires that environmental smith • ndlovu • summers highest number of powerline networks in Africa thus our impact assessment reports must include an attorneys, acting for specialist have vast experience in powerline assessment of each identified potentially Elandsberg Farms developments. Generally powerline development significant impact including, inter alia, a Stewardship Project, impacts have been well documented and releatively description and assessment cumulative comment by e-mailed letter, easy to predict as well as to mitigate. impacts. independent visual impact assessment and heritage reviews, 11 August 2014. 148. 49. The EIA Regulations define the term Richard Summers BSocSci Thank you for making that observation, we are very “cumulative impact” as follows: LLB LLM (Environmental aware of that and the essence of the EIA process is to “the impact of an activity that in itself may Law) capture direct and indirect impacts as well as not be significant, but may become smith • ndlovu • summers considering the cumulative impacts of the proposed significant when added to the existing and attorneys, acting for development. Powerline development is not a new and potential impacts eventuating from similar Elandsberg Farms unique development that may warrant panic by or diverse activities or undertakings in the Stewardship Project, members of the public. area.” 49 [Own underlining]. comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 149. 50. In order to satisfy the applicable legal Richard Summers BSocSci Please note that specialist are guided by different requirement in the EIA Regulations, the LLB LLM (Environmental legislations and guidelines which are applicable to their DEIR is required to assess the impacts of Law) fields of study. For example in Archaeology construction the proposed power line in combination smith • ndlovu • summers a powerline close to another powerline is considered to with the impacts eventuating from existing attorneys, acting for be ideal than going to virgin servitude. Furthermore

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similar or diverse activities or developments Elandsberg Farms constructing a powerline across known sites provides in the area. The need for this is attributable Stewardship Project, the opportunity to avoid them. I would like to assure to the “realisation that the process of comment by e-mailed letter, you that our specialist did consider cummulative impacts evaluating the negative environmental independent visual impact in their various fields. Site specific and comprehensive impacts of individual developments, which assessment and heritage studies will be done once the final route is selected. may be unobjectionable in themselves, do reviews, 11 August 2014. not adequately take into account the accumulative nature of some effects”.50 As illustrated in these comments, the DEIR has singularly failed to address the requirement to assess cumulative impacts in any meaningful manner. 150. 51. A cumulative impact assessment in the Richard Summers BSocSci Please refer to response above(150). context of this project should therefore LLB LLM (Environmental entail an assessment of existing impacts to Law) the receiving environment from existing smith • ndlovu • summers activities or development and an attorneys, acting for assessment of the cumulative impacts to be Elandsberg Farms occasioned by the proposed power line. The Stewardship Project, DEIR has failed to undertake this level of comment by e-mailed letter, assessment. independent visual impact assessment and heritage reviews, 11 August 2014. 151. 52. In particular, a cumulative impact Richard Summers BSocSci We are quite aware of your observation but depending assessment would need to assess whether LLB LLM (Environmental on the field of study it is better to disturb an already the cumulative impacts associated with the Law) disturbed landscape than disturbing a virgin landscape. project are acceptable, or whether the smith • ndlovu • summers (Please refer to response 150) cumulative impacts result in too great an attorneys, acting for

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impact on the receiving environment. The Elandsberg Farms need for an assessment of cumulative Stewardship Project, impacts is particularly necessary in the comment by e-mailed letter, present project which entails the independent visual impact construction of a 765kV power line in close assessment and heritage proximity to existing infrastructure reviews, 11 August 2014. including, for example, existing 400kV power lines. 152. 53. The DEIR reveals that the impacts of Richard Summers BSocSci Please refer to response 150 the proposed power line have not been LLB LLM (Environmental assessed cumulatively with the existing Law) impacts associated with existing power lines smith • ndlovu • summers and other (similar or diverse) infrastructure attorneys, acting for and development along the proposed Elandsberg Farms alternative routes. Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 153. 54. Whilst the DEIR considers pre- Richard Summers BSocSci You mentioned this over and over again and we do not determined alternative routes with the LLB LLM (Environmental understand if you are only emphasising the point. We (intended) overall aim of identifying which Law) are aware of your concerns and as indicated earlier route will result in the least risk to the smith • ndlovu • summers cumulative impacts and their implications depends on receiving environment, missing from this attorneys, acting for the field of study. Our role in the process is to assess enquiry is an indication and assessment of Elandsberg Farms the impacts based on specialist inputs. the impacts on the receiving environment Stewardship Project, eventuating from existing similar or diverse comment by e-mailed letter, activities along the proposed routes. independent visual impact

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Similarly absent from the analysis is the assessment and heritage assessment of the cumulative impacts for reviews, 11 August 2014. each resource within the study area. 154. 55. In terms of section 1 of NEMA, the Richard Summers BSocSci We are aware of your concerns and as indicated earlier “best practicable environmental option” is LLB LLM (Environmental cumulative impacts and their implications depends on defined as “the option that provides the Law) the field of study. Our role in the process is to assess most benefit or causes the least damage to smith • ndlovu • summers the impacts based on specialist inputs. the environment as a whole, at a cost attorneys, acting for acceptable to society, in the long term as Elandsberg Farms well as in the short term.” It is widely Stewardship Project, recognised that the cumulative nature of comment by e-mailed letter, impacts may result in a particularly independent visual impact significant adverse impact on the assessment and heritage environment as a whole, resulting in a cost reviews, 11 August 2014. which is not acceptable to society. 155. 56. For this reason, and in order to Richard Summers BSocSci Our specialists reports bears testimony to your determine whether the EIA process is LLB LLM (Environmental concerns. studies conducted identified previously indeed capable of advocating the best Law) identified impacts and operational impacts which will practicable environmental option it is smith • ndlovu • summers best be dealt with by the operational management plan. critical that the DEIR: attorneys, acting for Please familiarise with Eskom powerline construction Elandsberg Farms processes before making conclusions. Our studies meet 56.1. Must describe past, present and Stewardship Project, intenational standards including World bank guidelines reasonably foreseeable “similar or diverse comment by e-mailed letter, since most powerline projects are funded by the World activities or undertakings” in the study area independent visual impact Bank. for the power line; assessment and heritage reviews, 11 August 2014. 156. 56.2. must identify, evaluate and assess Richard Summers BSocSci Certainly all experienced and qualified practitioners are the extent to which those similar or diverse LLB LLM (Environmental aware of the terms of reference for the proposed

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activities or undertakings in the study area Law) powerline development. Please note that powerline have the potential to have a substantial smith • ndlovu • summers development is not a unique development. Our detrimental impact which the proposed attorneys, acting for specialist have been conducting similar studies on power line would contribute to; and Elandsberg Farms developments which are now operational. Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 157. 56.3. must evaluate the potential for the Richard Summers BSocSci Certainly all experienced and qualified practitioners are proposed power line to have a substantial LLB LLM (Environmental aware of the terms of reference for the proposed contribution to cumulative impacts on the Law) powerline development. Please note that powerline environment with the potential to smith • ndlovu • summers development is not a unique development. Our significantly affect the environment based attorneys, acting for specialist have been conducting similar studies on on the significance of such impacts. Elandsberg Farms developments which are now operational Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 158. 57. Despite the legal requirement to assess Richard Summers BSocSci Certainly all experienced and qualified practitioners are cumulative impacts, there is little evidence LLB LLM (Environmental aware of the terms of reference for the proposed that this issue has been dealt with in the Law) powerline development. Please note that powerline required manner. The assessment tables in smith • ndlovu • summers development is not a unique development. Our relation to visual impacts51 and agricultural attorneys, acting for specialist have been conducting similar studies on impacts52 in the DEIR include only a Elandsberg Farms developments which are now operational superficial reference to cumulative impacts. Stewardship Project, Beyond inserting the word “cumulative” into comment by e-mailed letter,

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the text of the table, there is no indication independent visual impact of how cumulative impacts, as defined in assessment and heritage terms of NEMA and the EIA Regulations, reviews, 11 August 2014. formed part of the assessment by the EAP or how cumulative impacts were appropriately considered as an integral aspect of the evaluation of alternatives, if at all. 159. 58. The manner in which cumulative Richard Summers BSocSci As indicated earlier on site specific impacts will be impacts are addressed is not only LLB LLM (Environmental considered after the final route selection is concluded. superficial but also largely generic. There Law) The selected route will be subjected to walk down are no site specific considerations which smith • ndlovu • summers surveys which will deal with site specific impacts would indicate where cumulative impacts attorneys, acting for including tower to tower impacts. Please note that might differ, depending on the particular Elandsberg Farms construction phase management plan will also take into receiving environment along the length of Stewardship Project, consideration site specific impacts, there after an the alternative routes or the particular comment by e-mailed letter, operational phase management plan will consider the significance of a resource in a particular independent visual impact impacts of the proposed powerline after construction part of the study area. With linear assessment and heritage including impacts of routine mantainace work and developments of this nature it cannot be reviews, 11 August 2014. repairs. correct to suggest – as the DEIR does - that the nature, extent and duration of cumulative impacts are the same across the entire site or study area. It is clear that a more credible and comprehensive site specific analysis is required before the DEIR will be able to satisfy the content requirements of the EIA Regulations. 160. 59. In support of the concern that the issue Richard Summers BSocSci Please note that our specialist are independent and their

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of cumulative impacts has not been LLB LLM (Environmental fields are different. You are generalizing specialist considered appropriately, we highlight the Law) studies and yet they are not only guided by NEMA, they following unsubstantiated assumptions smith • ndlovu • summers also guided by their own legislations and guidelines and/or conclusions in the DEIR relating to attorneys, acting for including ethical considerations in their various fields. A cumulative impacts: Elandsberg Farms situation that may be an advantage to a palaeontologist Stewardship Project, may be a disadvantage to the other but our role is to 59.1. In its consideration of alternative comment by e-mailed letter, weigh the options. routes, the DEIR makes the assumption independent visual impact that Alternative Route 1 is preferable assessment and heritage because “not only is it the most direct, but reviews, 11 August 2014. it also parallels existing infrastructure along most of its length from Wellington northwards to Kappa”.53 The argument appears to be that because Alternative Route 1 runs parallel to existing power line infrastructure that the cumulative impact of the proposed power line on the receiving environment will be less than if the power line is not constructed alongside existing infrastructure. This argument (which presupposes only positive cumulative impacts) cannot be sustained without a comprehensive and objective assessment of the cumulative impact of the proposed power line when considered against the existing impacts associated with existing infrastructure. 161. 59.2. In relation to visual impacts, it is Richard Summers BSocSci Specialist are independent and their fields are different.

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noted merely that the “cumulative” visual LLB LLM (Environmental You are generalizing specialist studies and yet they are impact is “[n]ot significant, because the Law) not only guided by NEMA, they also guided by their own area is impacted by several other smith • ndlovu • summers legislations and guidelines including ethical developments”.54 It is precisely because of attorneys, acting for considerations in their various fields. A situation that the fact that the area is already impacted Elandsberg Farms may be an advantage to a palaeontologist may be a by other (similar or diverse) activities or Stewardship Project, disadvantage to the other but our role is to weigh the developments that a cumulative impact comment by e-mailed letter, options. assessment is critical. As shown in these independent visual impact comments, the Visual Impact Assessment assessment and heritage (“VIA”) Report fails to assess cumulative reviews, 11 August 2014. visual impacts, which is a material deficiency in a project of this nature, particularly where the preferred alternative is recommended along an existing power line route. 162. 59.3. The fact that the area is already Richard Summers BSocSci specialist are independent and their fields are different. impacted by “several other developments” LLB LLM (Environmental You are generalizing specialist studies and yet they are is meaningless unless the cumulative Law) not only guided by NEMA, they also guided by their own impacts have been considered and assessed smith • ndlovu • summers legislations and guidelines including ethical (and the findings justify the conclusion). In attorneys, acting for considerations in their various fields. A situation that the present case, the DEIR fails to assess Elandsberg Farms may be an advantage to a palaeontologist may be a the cumulative impact of this proposed Stewardship Project, disadvantage to the other but our role is to weigh the 765kV power line when considered against comment by e-mailed letter, options. the existing impact associated with existing independent visual impact power lines, and other infrastructure or assessment and heritage developments which give rise to the same reviews, 11 August 2014. or similar impacts. 163. 59.4. In relation to the impact of the Richard Summers BSocSci Please note that mitigation also includes impact

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proposed power line on wetlands and LLB LLM (Environmental avoidance. For further explanation refer to responses rivers, the DEIR claims that mitigation Law) above. measures can negate cumulative smith • ndlovu • summers impacts.55 For the reasons indicated attorneys, acting for elsewhere in these comments, the primary Elandsberg Farms focus of the DEIR appears to be on Stewardship Project, mitigation, not impact avoidance. Mitigation comment by e-mailed letter, cannot be the primary basis of impact independent visual impact assessment as this undermines the assessment and heritage objectives of the Impact Mitigation reviews, 11 August 2014. Hierarchy tool. Cumulative impacts must first be critically assessed and a consideration of impact avoidance should precede an assessment of impact mitigation.56 The cumulative impact of the proposed power line, and existing infrastructure with similar impacts, on wetlands and rivers must be specifically assessed. This has not been done. 164. 59.5. With regards to the socio-economic Richard Summers BSocSci The issue of cummulative impacts has been said over impacts of the proposed power line, it is LLB LLM (Environmental and over again.The specialist understood the terms of noted in the DEIR that farmers are Law) reference of his work and further assessment may be investigating methods of cost saving which smith • ndlovu • summers beyond his scope of work. Eskom is also guided by will impact labour. According to the DEIR, attorneys, acting for labour laws of the republic. this will have a “cumulative effect on Elandsberg Farms labour/employment”.57 How this relates to Stewardship Project, the cumulative impacts of the proposed comment by e-mailed letter, power line on socio-economic conditions is independent visual impact

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not clear at all from the DEIR. assessment and heritage reviews, 11 August 2014. 165. 60. The DEIR must be supplemented by a Richard Summers BSocSci Your concern is a technical matter which Eskom is aware credible and comprehensive assessment of LLB LLM (Environmental of. cumulative impacts. Based on our Law) understanding of the likely and anticipated smith • ndlovu • summers risks associated with the project, this attorneys, acting for should include, as a bare minimum, the Elandsberg Farms following: Stewardship Project, comment by e-mailed letter, 60.1. The cumulative fire risk associated independent visual impact with the proposed construction of this assessment and heritage 765kV power line parallel to existing reviews, 11 August 2014. transmission power lines. 166. 60.2. The cumulative visual impacts Richard Summers BSocSci Please note that our specialist are independent and their associated with the project which must take LLB LLM (Environmental fields are different. You are generalizing specialist into account the cumulative visual impacts Law) studies and yet they are not only guided by NEMA, they on the receiving landscape across the study smith • ndlovu • summers also guided by their own legislations and guidelines area. In this regard the VIA Report attorneys, acting for including ethical considerations in their various fields. A recommends that “the cumulative effect of Elandsberg Farms situation that may be an advantage to a palaeontologist adding to the visual clutter prior to the final Stewardship Project, may be a disadvantage to the other but our role is to placement should be evaluated”.58 The VIA comment by e-mailed letter, weigh the options. Report is insufficient in that the assessment independent visual impact is done “on a macro-scale”59 without any assessment and heritage detailed cumulative assessment of site reviews, 11 August 2014. specific visual impacts or how the cumulative visual impact might impact on a particular resource within the study area.

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167. 60.3. With regard to the potential impact Richard Summers BSocSci Please note that our specialist are independent and their on the Elandsberg Nature Reserve the LLB LLM (Environmental fields are different. You are generalizing specialist assessment of cumulative visual impacts is Law) studies and yet they are not only guided by NEMA, they a critical enquiry that must be undertaken, smith • ndlovu • summers also guided by their own legislations and guidelines particularly given the impact of the attorneys, acting for including ethical considerations in their various fields. A proposed power lines on the sense of place Elandsberg Farms situation that may be an advantage to a palaeontologist and the aesthetic qualities of this Stewardship Project, may be a disadvantage to the other but our role is to predominantly rural and wilderness comment by e-mailed letter, weigh the options. landscape. Without a detailed cumulative independent visual impact visual impact assessment, it is not possible assessment and heritage to draw any defensible conclusions reviews, 11 August 2014. regarding visual impacts. 168. 60.4. The cumulative biodiversity-related Richard Summers BSocSci Please note that our specialist are independent and their impacts on the Elandsberg Nature Reserve LLB LLM (Environmental fields are different. You are generalizing specialist and surrounding properties must be Law) studies and yet they are not only guided by NEMA, they considered comprehensively in terms of smith • ndlovu • summers also guided by their own legislations and guidelines additional habitat loss and disturbance. This attorneys, acting for including ethical considerations in their various fields. A has not been done. Elandsberg Farms situation that may be an advantage to a palaeontologist Stewardship Project, may be a disadvantage to the other but our role is to comment by e-mailed letter, weigh the options. independent visual impact assessment and heritage reviews, 11 August 2014. 169. 60.5. The cumulative heritage impacts Richard Summers BSocSci Note that you do not dismiss somebodies work without associated with the project. The primary LLB LLM (Environmental providing an alternative or a standard. We are confident basis for assessing Alternative Route 1 as Law) that our specialist studies met rquirements as set out in the preferred route in the draft Heritage smith • ndlovu • summers section 36 and 38 of the NHRA and also SAHRA and Impact Assessment Report (“draft HIA attorneys, acting for Heritage Western Cape guidelines.

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Report”)60 and the Cultural Landscape Elandsberg Farms Report is the presence of an existing 400kV Stewardship Project, transmission line and an approved 765kV comment by e-mailed letter, transmission line which already impacts independent visual impact landscapes and settlements along the assessment and heritage greater distance of Alternative Route 1. For reviews, 11 August 2014. the reasons set out elsewhere in these comments the level of analysis in the DEIR and specialist reports does not substantiate the selection of Alternative Route 1 based on a credible analysis of heritage related impacts in the various heritage studies. 170. 60.6. The cumulative impacts of the Richard Summers BSocSci Please note that our specialist are independent and their proposed power line on birds and bats must LLB LLM (Environmental fields are different. You are generalizing specialist be assessed in greater detail. The specialist Law) studies and yet they are not only guided by NEMA, they Bird Impact Assessment61 and Desktop Bat smith • ndlovu • summers also guided by their own legislations and guidelines Assessment62 reports do not consider the attorneys, acting for including ethical considerations in their various fields. A alternative routes in detail and they do not Elandsberg Farms situation that may be an advantage to a palaeontologist evidence the fact that the cumulative Stewardship Project, may be a disadvantage to the other but our role is to impacts associated with the proposed comment by e-mailed letter, weigh the options. power line have been assessed. The reports independent visual impact are more focused on recommending generic assessment and heritage mitigation measures (which could apply reviews, 11 August 2014. equally to all alternative routes) rather than on a detailed assessment of impacts (including cumulative impacts). 171. 61. The approach reflected in the DEIR to Richard Summers BSocSci To suggest that the EIA process is fundamentally flawed the assessment of cumulative impacts is LLB LLM (Environmental is a insult to the entire team. The entire team is

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flawed. The methodology adopted in the Law) qualified and highly experienced to handle impact EIA process to date undermines the smith • ndlovu • summers assessment for a powerline project. As indicated earlier purpose of the EIA process, which is to attorneys, acting for on site specific impacts will be considered after the final evaluate the impacts of an activity before it Elandsberg Farms route selection is concluded. The selected route will be is authorised and implemented. The Stewardship Project, subjected to walk down surveys which will deal with site approach to the assessment of cumulative comment by e-mailed letter, specific impacts including tower to tower impacts. Please impacts also undermines the objectives of independent visual impact note that construction phase management plan will also the Impact Mitigation Hierarchy tool, which assessment and heritage take into consideration site specific impacts, there after requires that an assessment of impact reviews, 11 August 2014. an operational phase management plan will consider the avoidance must precede an assessment of impacts of the proposed powerline after construction impact mitigation. One cannot defensibly including impacts of routine mantainace work and engage in the issue of impact mitigation repairs. when the impact assessment is deficient in several material respects – as it is in this case. 172. 62. Given the significant gaps in the Richard Summers BSocSci The entire team is qualified and highly experienced to assessment of cumulative impacts and the LLB LLM (Environmental handle impact assessment for a powerline project. As unsubstantiated assumptions and/or Law) indicated earlier on site specific impacts will be conclusions regarding cumulative impacts smith • ndlovu • summers considered after the final route selection is concluded. contained in the DEIR, there is simply not attorneys, acting for The selected route will be subjected to walk down sufficient information regarding the Elandsberg Farms surveys which will deal with site specific impacts assessment of cumulative impacts Stewardship Project, including tower to tower impacts. Please note that associated with the proposed development. comment by e-mailed letter, construction phase management plan will also take into The DEIR fails to satisfy the content independent visual impact consideration site specific impacts, there after an requirements of the EIA Regulations in this assessment and heritage operational phase management plan will consider the regard. reviews, 11 August 2014. impacts of the proposed powerline after construction including impacts of routine mantainace work and repairs.

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173. FIRE RISK Richard Summers BSocSci Thank you for your comment. 63. A significant impact which has not been LLB LLM (Environmental assessed adequately in the DEIR is the fire Law) risk that transmission power lines pose to smith • ndlovu • summers the surrounding environment. International attorneys, acting for studies confirm that fires are a very real Elandsberg Farms risk associated with transmission power Stewardship Project, lines and that the placement of power lines comment by e-mailed letter, in close proximity to one another increases independent visual impact that fire risk. assessment and heritage reviews, 11 August 2014. 174. 64. The DEIR recognises the potential risk Richard Summers BSocSci Thank you for your comment. Site specific mitigation of fire which can be caused by, among LLB LLM (Environmental measures, will be included in the site specific EMP. others, electrical flashovers.63 Whilst the Law) DEIR proposes certain mitigation measures smith • ndlovu • summers in this regard, it does not adequately assess attorneys, acting for the fire risk or the impact of potential fires Elandsberg Farms on the receiving environment in areas of Stewardship Project, particular concern. The mitigation measures comment by e-mailed letter, contemplated are generic and it is not clear independent visual impact how site specific considerations have assessment and heritage informed the assessment of the significance reviews, 11 August 2014. of fire-related impacts. 175. 65. The entire study corridor must be Richard Summers BSocSci Thank you for your comment. Noted. subjected to a rigorous assessment of the LLB LLM (Environmental fire hazards associated with the project. Law) This must include an assessment of the smith • ndlovu • summers potential for the project to contribute to a attorneys, acting for

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significant cumulative fire hazard in areas Elandsberg Farms of particular concern. Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 176. 66. With regard to mitigation measures, the Richard Summers BSocSci Thank you for your comment. Eskom has been DEIR stipulates that vegetation under the LLB LLM (Environmental constructing powerlines for decades and are very much power lines should be cleared so as to Law) aware of such dangers. The construction team,that reduce the risk of fire (with uncertainty as smith • ndlovu • summers Eskom will appoint will have their own ECO who will to what degree of vegetation should remain attorneys, acting for ensuring that such impacts are avoided by all means. I so as to prevent soil erosion).64 Elandsberg Farms would also like to believe, that Eskom would not appoint Appropriate methods of vegetation Stewardship Project, people who are not qualified. The details which you clearance underneath power lines to comment by e-mailed letter, require, will be included in the site specific EMP. mitigate the fire risk should be assessed in independent visual impact the context of areas of particular concern. assessment and heritage Vegetation removal methods below power reviews, 11 August 2014. lines include chemical, manual, mechanical and fire methods, though the latter is recommended only at appropriate locations and under strictly controlled conditions (and is accordingly seldom undertaken near power lines).65 The appropriate method depends on the circumstances and the various methods should have therefore been assessed in the DEIR to enable our client to assess whether the proposed measures are compatible with the

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management regime of the Elandsberg Nature Reserve. The clearing of vegetation under the power lines is highly problematic 177. 67. As noted in the DEIR, it is also Richard Summers BSocSci Thank you for your comment. Eskom has been imperative that Eskom clarify LLB LLM (Environmental constructing powerlines for decades and are very much responsibilities for fire management in the Law) aware of such dangers. The construction team,that power line servitude area.66 The smith • ndlovu • summers Eskom will appoint will have their own ECO who will responsibilities of land owners must be attorneys, acting for ensuring that such impacts are avoided by all means. I clearly identified and understood. The Elandsberg Farms would also like to believe, that Eskom would not appoint burdening of land owners with fire Stewardship Project, people who are not qualified. The details which you prevention concerns should be seen as a comment by e-mailed letter, require, will be included in the site specific EMP. negative impact on the land owning independent visual impact community. Any such burdening with assessment and heritage responsibilities should be clearly identified reviews, 11 August 2014. and assessed in the EIA process. 178. 68. The DEIR also fails to recognise that Richard Summers BSocSci Thank you for your comment. Eskom has been controlled burning fire plays an important LLB LLM (Environmental constructing powerlines for decades and are very much role in ensuring the survival of certain plant Law) aware of such dangers. The construction team,that species. Experience has shown that it has smith • ndlovu • summers Eskom will appoint will have their own ECO who will been impossible to implement effectively attorneys, acting for ensuring that such impacts are avoided by all means. I block burns underneath power lines. The Elandsberg Farms would also like to believe, that Eskom would not appoint construction of an additional power line will Stewardship Project, people who are not qualified. The details which you increase the area that will not be able to be comment by e-mailed letter, require, will be included in the site specific EMP. included in a planned burning regime, with independent visual impact potentially significant adverse impacts for assessment and heritage biodiversity management on the Elandsberg reviews, 11 August 2014. Nature Reserve. This impact has not been assessed.

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179. 69. Of particular concern to our client is the Richard Summers BSocSci Thank you for your comment. Noted. extent to which fire-related impacts have LLB LLM (Environmental been considered with regard to the Law) Elandsberg Nature Reserve. Our client has smith • ndlovu • summers direct experience of a previous fire having attorneys, acting for been caused by an Eskom contractor Elandsberg Farms carrying out the clearing work under the Stewardship Project, pylons of the existing 400kV power line. comment by e-mailed letter, Veldfires are frequent in the area and it is independent visual impact widely recognised that veldfires in this area assessment and heritage are notoriously difficult to control. Our reviews, 11 August 2014. client’s property is particularly vulnerable due to prevailing wind patterns, which often mean that veldfires along the mountains burn downwards towards Elandsberg, due to the mountain topography which causes a downdraft. 180. 70. The fire risk associated with this project Richard Summers BSocSci Thank you for your comment. Noted. must be comprehensively assessed, along LLB LLM (Environmental with the other fire-related issues raised Law) above. There is also no evidence to suggest smith • ndlovu • summers that the DEIR has considered the impacts of attorneys, acting for fire on Eskom infrastructure and the Elandsberg Farms potential for fire to cause trips and/or Stewardship Project, outages, which are widely recognized as a comment by e-mailed letter, serious threat to the operational stability of independent visual impact the transmission line network. assessment and heritage reviews, 11 August 2014.

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181. ELECTRIC AND MAGNETIC FIELD Richard Summers BSocSci Thank you for your concern. We have attached an EMF RADIATION LLB LLM (Environmental report as Appendix 5. This report, clearly stipulates the Law) use of electromagneic shieling to reduce the impacts. 71. There is significant general public smith • ndlovu • summers concern around the health risks associated attorneys, acting for with transmission power lines and the Elandsberg Farms exposure of the surrounding community to Stewardship Project, electric and magnetic field (EMF) radiation. comment by e-mailed letter, There is likewise significant general public independent visual impact concern that EMF radiation has a negative assessment and heritage impact on fauna and flora in the vicinity of reviews, 11 August 2014. transmission power lines. These issues and concerns have not been addressed adequately in the DEIR. 182. 72. Although the DEIR acknowledges the Richard Summers BSocSci A report was attached as an appendix, which had threat of EMF radiation to human health, LLB LLM (Environmental answers to all your concerns. You have stated that, the fauna and flora, the DEIR attempts to Law) report was outdated. May you please assist us with the address this concern with reference to a smith • ndlovu • summers latest, which speaks something totally different from study commissioned by the applicant in attorneys, acting for what was attached in the report. 2006 and conducted by Empetus Close Elandsberg Farms Despite extensive research, to date there is no evidence Corporation (“the Empetus Report”). Stewardship Project, to conclude that exposure to low level electromagnetic According to the DEIR, the Empetus Report: comment by e-mailed letter, fields is harmful to human health. “...highlights that all household appliances independent visual impact and other electrical equipment generate assessment and heritage Please refer to EMF Project- World Health Oraganization electrical and magnetic fields (EMF). reviews, 11 August 2014. site on : http://www.who.int/peh-emf/en/ Therefore people are generally exposed to varying levels of EMF in their daily lives at work and at home. EMF is always created,

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in varying levels, with the generation of electricity and the frequency of the electrical power system. Overhead powerlines generate electric and magnetic fields but not any different from what people are already exposed to from other sources in their daily lives.”67 183. 73. The Empetus Report is an eight year- Richard Summers BSocSci A report was attached as an appendix, which had old study and is out of date. Scientific LLB LLM (Environmental answers to all your concerns. You have stated that, the research in relation to EMF radiation from Law) report was outdated. May you please assist us with the power lines is ongoing. The EAP’s smith • ndlovu • summers latest, which speaks something totally different from interrogation of this issue should therefore attorneys, acting for what was attached in the report. be informed by the most recent studies Elandsberg Farms Despite extensive research, to date there is no evidence which take into account best available Stewardship Project, to conclude that exposure to low level electromagnetic science. comment by e-mailed letter, fields is harmful to human health. independent visual impact assessment and heritage Please refer to EMF Project- World Health Oraganization reviews, 11 August 2014. site on : http://www.who.int/peh-emf/en/ 184. 74. With regard to the argument that Richard Summers BSocSci A report was attached as an appendix, which had people are already exposed to EMF LLB LLM (Environmental answers to all your concerns. You have stated that, the radiation in their daily lives, there is no Law) report was outdated. May you please assist us with the evidence that an assessment of the levels smith • ndlovu • summers latest, which speaks something totally different from of EMF radiation to which people are attorneys, acting for what was attached in the report. ordinarily exposed to has been undertaken, Elandsberg Farms Despite extensive research, to date there is no evidence or the extent to which power lines give rise Stewardship Project, to conclude that exposure to low level electromagnetic to additional exposure and the extent to comment by e-mailed letter, fields is harmful to human health. which that results in a significant impact. independent visual impact The methodology reflected in the DEIR is assessment and heritage Please refer to EMF Project- World Health Oraganization

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flawed. reviews, 11 August 2014. site on : http://www.who.int/peh-emf/en/ 185. 75. There is no basis to conclude that the Richard Summers BSocSci A report was attached as an appendix, which had EMF radiation generated by power lines is LLB LLM (Environmental answers to all your concerns. You have stated that, the “not any different from what people are Law) report was outdated. May you please assist us with the already exposed to”. There has been no smith • ndlovu • summers latest, which speaks something totally different from assessment of exposure rates. There has attorneys, acting for what was attached in the report. also been no assessment of the potential Elandsberg Farms Despite extensive research, to date there is no evidence cumulative impacts that the proposed Stewardship Project, to conclude that exposure to low level electromagnetic 765kV power line will have on the receiving comment by e-mailed letter, fields is harmful to human health. environment when considered against the independent visual impact existing power lines in the study area which assessment and heritage Please refer to EMF Project- World Health Oraganization already give rise to EMF radiation. reviews, 11 August 2014. site on : http://www.who.int/peh-emf/en/ 186. 76. With reference again to the Empetus Richard Summers BSocSci A report was attached as an appendix, which had Report, it is noted in the DEIR that: LLB LLM (Environmental answers to all your concerns. You have stated that, the Law) report was outdated. May you please assist us with the “no evidence of a causal relationship smith • ndlovu • summers latest, which speaks something totally different from between magnetic field exposure and attorneys, acting for what was attached in the report. childhood leukemia or breast cancer has Elandsberg Farms Despite extensive research, to date there is no evidence been found and no dose-response Stewardship Project, to conclude that exposure to low level electromagnetic relationship has been shown to exist comment by e-mailed letter, fields is harmful to human health. between EMF exposure and biological independent visual impact effects”; and assessment and heritage Please refer to EMF Project- World Health Oraganization reviews, 11 August 2014. site on : http://www.who.int/peh-emf/en/ “according to findings of studies on the effects of electric and magnetic fields on plants with levels typical of a powerline environment, complying with the requirements for proper servitude

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management as prescribed by electric utility, are unlikely to affect plants in terms of growth, germination and crop production”.68 187. 77. The conclusions drawn from the Richard Summers BSocSci Despite the feeling of some people that more research Empetus Report on the impacts of EMF LLB LLM (Environmental needs to be done, scientific knowledge in this area is radiation on human health and fauna and Law) now more flora are not conclusive. International smith • ndlovu • summers extensive than for most chemicals. Based on a recent studies on the effects of EMF radiation are attorneys, acting for in-depth review of the scientific literature, the WHO contradictory in their conclusions and Elandsberg Farms concluded that current evidence does not confirm the generally acknowledge that research in this Stewardship Project, existence of any health consequences from exposure to field of study is on-going. As indicated comment by e-mailed letter, low level electromagnetic fields. above, any interrogation of this issue in the independent visual impact context of the EIA process must be based assessment and heritage Please refer to EMF Project- World Health Oraganization on best available science. reviews, 11 August 2014. site on : http://www.who.int/peh-emf/en/ 188. 78. What is clear, and which is Richard Summers BSocSci Despite the feeling of some people that more research acknowledged in the DEIR, is that there is LLB LLM (Environmental needs to be done, scientific knowledge in this area is general public concern on the issue of EMF Law) now more radiation and public fear in respect of the smith • ndlovu • summers extensive than for most chemicals. Based on a recent health and environmental risks associated attorneys, acting for in-depth review of the scientific literature, the WHO therewith. Elandsberg Farms concluded that current evidence does not confirm the Stewardship Project, existence of any health consequences from exposure to comment by e-mailed letter, low level electromagnetic fields. independent visual impact assessment and heritage reviews, 11 August 2014. 189. 79. The lack of conclusive evidence relied Richard Summers BSocSci Thank you for your comment. We did mention EMF and on in the DEIR, coupled with public concern LLB LLM (Environmental EMI from page 52 to 53. We also attached a report as

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and the risk of negative impacts on human Law) appendix 5. health and the receiving environment, smith • ndlovu • summers justifies a precautionary approach to this attorneys, acting for issue. Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 190. 80. There is insufficient information in the Richard Summers BSocSci Thank you for your comment. DEIR to satisfy the national environmental LLB LLM (Environmental management principles contained in section Law) 2 of NEMA. We refer specifically to the smith • ndlovu • summers precautionary principle which requires that attorneys, acting for “a risk-averse and cautious approach is Elandsberg Farms applied, which takes into account the limits Stewardship Project, of current knowledge about the comment by e-mailed letter, consequences of decisions and actions”.69 independent visual impact assessment and heritage reviews, 11 August 2014. 191. 81. Even if the DEIR seeks to rely on the Richard Summers BSocSci A report was attached as an appendix, which had argument that the science is inconclusive in LLB LLM (Environmental answers to all your concerns. You have stated that, the respect of harm to human health and the Law) report was outdated. May you please assist us with the environment caused by EMF radiation, this smith • ndlovu • summers latest, which speaks something totally different from does not mean that there is no risk of harm attorneys, acting for what was attached in the report. from EMF radiation. Relying on the Elandsberg Farms Despite extensive research, to date there is no evidence argument that the scientific literature does Stewardship Project, to conclude that exposure to low level electromagnetic not establish harm is not the same as comment by e-mailed letter, fields is harmful to human health.

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saying that there is no risk associated with independent visual impact EMF radiation. The DEIR has failed to show assessment and heritage Please refer to EMP Project- World Health Oraganization that there is no such risk. The reviews, 11 August 2014. site on : http://www.who.int/peh-emf/en/ precautionary principle applies in the face of this uncertainty and a risk-averse and cautious approach is required. 192. ELECTROMAGNETIC INTERFERENCE Richard Summers BSocSci Thank you fr your comment. We did mention EMF and LLB LLM (Environmental EMI from page 52 to 53. We also attached a report as 82. The fact that high voltage transmission Law) appendix 5. lines such as the proposed 765kV power smith • ndlovu • summers lines can produce corona and induced attorneys, acting for electromagnetic fields which produce Elandsberg Farms electromagnetic interference (EMI) is not Stewardship Project, recognised in the DEIR as a potentially comment by e-mailed letter, significant impact. It is also widely independent visual impact recognised that EMI can potentially affect assessment and heritage the functioning of electronic and reviews, 11 August 2014. telecommunications equipment. 193. 83. This potential impact is not considered Richard Summers BSocSci A report was attached as an appendix, which had at all in the DEIR. The only indication that LLB LLM (Environmental answers to all your concerns. You have stated that, the this concern has been considered is the Law) report was outdated. May you please assist us with the reference to the unsubstantiated statement smith • ndlovu • summers latest, which speaks something totally different from that “Minimal radio / television interference attorneys, acting for what was attached in the report. anticipated”.70 The potential for EMI to Elandsberg Farms Despite extensive research, to date there is no evidence interfere or interrupt electronic equipment Stewardship Project, to conclude that exposure to low level electromagnetic and telecommunications on our client’s comment by e-mailed letter, fields is harmful to human health. property is required to be considered as the independent visual impact construction of additional high voltage assessment and heritage Please refer to EMP Project- World Health Oraganization

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transmission lines will inevitably give rise to reviews, 11 August 2014. site on : http://www.who.int/peh-emf/en/ EMI. 194. IMPACT ON BIODIVERSITY Richard Summers BSocSci Thank you for the information. LLB LLM (Environmental 84. The Elandsberg Nature Reserve Law) supports two critically endangered smith • ndlovu • summers vegetation types, namely Swartland attorneys, acting for Alluvium Fynbos and Swartland Shale Elandsberg Farms Renosterveld. The area is critically Stewardship Project, important from a biodiversity perspective comment by e-mailed letter, and has been proclaimed as a provincial independent visual impact nature reserve (proclamation number assessment and heritage 15/2008, Western Cape) under the National reviews, 11 August 2014. Environmental Management: Protected Areas Act.71 195. 85. The Elandsberg Nature Reserve has also Richard Summers BSocSci All available and regionally known faunal and floral been determined as a Critical Biodiversity LLB LLM (Environmental reference databases were considered or assessed in Area (CBA) and contains several Ecological Law) order to assure that the assessments take as many of Support Areas (ESAs). This factor should smith • ndlovu • summers the potential species as well as important habitats into serve as a critical biodiversity indicator and attorneys, acting for consideration as possible given the extent of the various informant in EIA processes such as this. Elandsberg Farms alternatives. However, based on the absence of a Stewardship Project, However, consideration should be given to extreme detailed interrogation of the relevance of comment by e-mailed letter, extent each of the proposed alternatives cover that this factor in the assessment process, it is independent visual impact resulted in the likelihood of all documented species as not possible to ascertain to what extent the assessment and heritage well as a vast variety of different habitats being present CBA status of the Elandsberg Nature reviews, 11 August 2014. along portions of the routes. It should also be noted that Reserve has informed the EIA process. the study was aimed at assessing 2km wide corridor alternatives and as such detailed assessments are not

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practicable at this stage of the investigations. The assessment approach was aimed at identification and prioritisation of portions along the various alternatives that are considered most likely to be able to sustain the most diverse and sensitive faunal and floral populations and where more care would be required in the planning, construction and operational phases of the project. It has been made clear in the reports developed that as part of the planning phase of the development a walk down be undertaken of all areas considered of higher ecological importance identified within the baseline report for the selected route within the selected corridor. By so doing areas of least concern can be identified for the construction of support structures. It should further be noted that where portions of routes were identified that where considered ‘no go’ areas, it has been highlighted in the report and where possible alternative alignment has been proposed or recommended.

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regardless of what faunal or floral species are found within them. By so doing the sitespecific impacts associated with these areas will most likely be avoided. Site specific mitigation measures can then be developed for areas where re- alignment is not an option, however this would require detailed site assessments of all these areas; possibly as a ‘second phase’ assessment that can inform the EIA prior to final submission or prior to finalisation of the EMP for the project. This will allow for the further development of sitespecific construction and operational mitigation measures.

It should be noted that the assessment was based on a worst case scenario and are therefore considered indicative of the significance of impact that could result due to vegetation clearing and construction related activities within each sensitivity class. 196. 86. The conservation areas comprising the Richard Summers BSocSci Thank you for your comment. Elandsberg Nature Reserve have been LLB LLM (Environmental recognised as a critically important site for Law) the conservation of west coast lowland smith • ndlovu • summers renosterveld.72 The total number of attorneys, acting for indigenous plant species recorded on the Elandsberg Farms site is in excess of eight hundred, with Stewardship Project, approximately thirty of these being listed as comment by e-mailed letter, threatened species. The Elandsberg Nature independent visual impact Reserve also supports the critically assessment and heritage

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endangered geometric tortoise, which is the reviews, 11 August 2014. third most endangered tortoise in the world and has been listed by the IUCN as one of the top 100 most threatened species on earth. There is however no indication of how the biodiversity significance of the Elandsberg Nature Reserve has informed the EIA process, if at all. 197. 87. The impacts of the proposed power line Richard Summers BSocSci Thank you for your comment. on biodiversity are of particular concern to LLB LLM (Environmental our client, given the high biodiversity value Law) of the Elandsberg Nature Reserve. The smith • ndlovu • summers construction of the 765kV power line on our attorneys, acting for client’s property will inevitably result in Elandsberg Farms vegetation and habitation loss, and the Stewardship Project, presence of the power line will pose a fire comment by e-mailed letter, risk to the biodiversity supported by our independent visual impact client’s property. The terrain surrounding assessment and heritage our client’s property is mountainous and reviews, 11 August 2014. veld fires are notoriously difficult to control given the topography of the area. This increased risk posed by fire and the vegetation and habitation loss associated with the construction could have a devastating effect on the fauna and flora supported by our client’s property. This proposal threatens the very integrity of our client’s protected area management

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program. 198. 88. The impacts on biodiversity of ancillary Richard Summers BSocSci All available and regionally known faunal and floral infrastructure such as roads and LLB LLM (Environmental reference databases were considered or assessed in construction camps on biodiversity are also Law) order to assure that the assessments take as many of of particular concern. As discussed above, smith • ndlovu • summers the potential species as well as important habitats into site specific impacts associated with attorneys, acting for consideration as possible given the extent of the various ancillary infrastructure have not been Elandsberg Farms alternatives. However, consideration should be given to assessed at all in the DEIR. The potential Stewardship Project, extreme extent each of the proposed alternatives cover negative impact that such infrastructure comment by e-mailed letter, that resulted in the likelihood of all documented species could have on the rich biodiversity value of independent visual impact as well as a vast variety of different habitats being our client’s property must be assessed in assessment and heritage present along portions of the routes. It should also be the DEIR. This will require the full extent of reviews, 11 August 2014. noted that the study was aimed at assessing 2km wide the proposed development footprint to be corridor alternatives and as such detailed assessments assessed now as part of this process in are not practicable at this stage of the investigations. order to appreciate and understand the The assessment approach was aimed at identification nature and extent of all biodiversity related and prioritisation of portions along the various impacts. alternatives that are considered most likely to be able to sustain the most diverse and sensitive faunal and floral populations and where more care would be required in the planning, construction and operational phases of the project. It has been made clear in the reports developed that as part of the planning phase of the development a walk down be undertaken of all areas considered of higher ecological importance identified within the baseline report for the selected route within the selected corridor. By so doing areas of least concern can be identified for the construction of support structures. It should further be noted that where portions of routes

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were identified that where considered ‘no go’ areas, it has been highlighted in the report and where possible alternative alignment has been proposed or recommended.

The client has been provided with the GIS files indicating areas considered to be of very high and high sensitivity identified using all desktop information available with special mention of fine scale plans as well as site visits. It is the opinion of the specialists that alternative route alignment be considered around these areas and that CBAs be avoided as far as possible regardless of what faunal or floral species are found within them. By so doing the sitespecific impacts associated with these areas will most likely be avoided. Site specific mitigation measures can then be developed for areas where re- alignment is not an option, however this would require detailed site assessments of all these areas; possibly as a ‘second phase’ assessment that can inform the EIA prior to final submission or prior to finalisation of the EMP for the project. This will allow for the further development of sitespecific construction and operational mitigation measures.

It should be noted that the assessment was based on a worst case scenario and are therefore considered indicative of the significance of impact that could result

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due to vegetation clearing and construction related activities within each sensitivity class. 199. 89. The DEIR, read with the Terrestrial Richard Summers BSocSci It should also be noted that the study was aimed at Ecological Assessment Report,73 provides LLB LLM (Environmental assessing 2km wide corridor alternatives and as such insufficient detailed information on the Law) detailed assessments are not practicable at investigation of site specific impacts on smith • ndlovu • summers this stage of the investigations. The assessment biodiversity. The Terrestrial Ecological attorneys, acting for approach was aimed at identification and prioritisation Assessment Report is largely a desktop Elandsberg Farms of portions along the various alternatives that are study with minimal ground-truthing Stewardship Project, considered most likely to be able to sustain the most conducted. The maps provided are not of a comment by e-mailed letter, diverse and sensitive faunal and floral populations and sufficient scale to accurately determine independent visual impact where more care would be required in the planning, areas of high biodiversity sensitivity. assessment and heritage construction and operational phases of the project. It reviews, 11 August 2014. has been made clear in the reports developed that as part of the planning phase of the development a walk down be undertaken of all areas considered of higher ecological importance identified within the baseline report for the selected route within the selected corridor. By so doing areas of least concern can be identified for the construction of support structures. It should further be noted that where portions of routes were identified that where considered ‘no go’ areas, it has been highlighted in the report and where possible alternative alignment has been proposed or recommended.

It is the opinion of the specialists that alternative route alignment be considered around these areas and that CBAs be avoided as far as possible regardless of what

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faunal or floral species are found within them. By so doing the sitespecific impacts associated with these areas will most likely be avoided. Site specific mitigation measures can then be developed for areas where re- alignment is not an option, however this would require detailed site assessments of all these areas; possibly as a ‘second phase’ assessment that can inform the EIA prior to final submission or prior to finalisation of the EMP for the project. This will allow for the further development of sitespecific construction and operational mitigation measures. 200. 90. Some consideration is given in the DEIR Richard Summers BSocSci Site specific mitigation measures can then be developed and Terrestrial Ecological Assessment LLB LLM (Environmental for areas where re-alignment is not an option, however Report to the general mitigation of impacts Law) this would require detailed site assessments of all these on biodiversity. For the reasons stated smith • ndlovu • summers areas; possibly as a ‘second phase’ assessment that can above, the DEIR’s focus on generic attorneys, acting for inform the EIA prior to final submission or prior to mitigation measures without a proper Elandsberg Farms finalisation of the EMP for the project. This will allow for evaluation of the site specific impacts of the Stewardship Project, the further development of sitespecific construction and power line on biodiversity is not in comment by e-mailed letter, operational mitigation measures. accordance with the Impact Mitigation independent visual impact Hierarchy tool or the objectives of an EIA assessment and heritage process. reviews, 11 August 2014. 201. 91. The mitigation measures are mostly of Richard Summers BSocSci Site specific mitigation measures can then be developed generic application and there is no LLB LLM (Environmental for areas where re-alignment is not an option, however indication as to how the biodiversity impact Law) this would require detailed site assessments of all these on the Elandsberg Nature Reserve has been smith • ndlovu • summers areas; possibly as a ‘second phase’ assessment that can quantified or assessed. In order to ensure attorneys, acting for inform the EIA prior to final submission or prior to that biodiversity-related impacts are Elandsberg Farms finalisation of the EMP for the project. This will allow for

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addressed in the EIA process in a manner Stewardship Project, the further development of sitespecific construction and that will satisfy the requirements in NEMA, comment by e-mailed letter, operational mitigation measures. it is clear that the mapping and ground- independent visual impact truthing of sensitive areas will be required. assessment and heritage This process must inform how the impact reviews, 11 August 2014. on biodiversity is evaluated and assessed. 202. 92. It is accordingly not clear whether the Richard Summers BSocSci Thank you for your comment. biodiversity significance of our client’s LLB LLM (Environmental property has been considered at all in the Law) assessment of Alternative Route 1 or the smith • ndlovu • summers selection thereof as the preferred attorneys, acting for alternative route. Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 203. 93. The cumulative impact on biodiversity Richard Summers BSocSci Site specific mitigation measures can then be developed of another power line (in addition to the LLB LLM (Environmental for areas where re-alignment is not an option, however two existing 400kV power lines) traversing Law) this would require detailed site assessments of all these our client’s property has also not been smith • ndlovu • summers areas; possibly as a ‘second phase’ assessment that can considered and assessed. As indicated attorneys, acting for inform the EIA prior to final submission or prior to above, the DEIR must address the Elandsberg Farms finalisation of the EMP for the project. This will allow for cumulative impact of the proposed power Stewardship Project, the further development of sitespecific construction and line on biodiversity. comment by e-mailed letter, operational mitigation measures. independent visual impact assessment and heritage reviews, 11 August 2014.

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204. 94. Based on the failure to undertake an Richard Summers BSocSci All available and regionally known faunal and floral appropriate interrogation of biodiversity- LLB LLM (Environmental reference databases were considered or assessed in related impacts through ground-truthing Law) order to assure that the assessments take as many of and a site specific analysis of areas which smith • ndlovu • summers the potential species as well as important habitats into are considered as particularly sensitive attorneys, acting for consideration as possible given the extent of the various from a biodiversity perspective, there is Elandsberg Farms alternatives. simply insufficient information to enable the Stewardship Project, However, consideration should be given to extreme assessment of the environmental effects of comment by e-mailed letter, extent each of the proposed alternatives cover that the proposed power line on biodiversity. independent visual impact resulted in the likelihood of all documented species as assessment and heritage well as a vast variety of different habitats being present reviews, 11 August 2014. along portions of the routes. It should also be noted that the study was aimed at assessing 2km wide corridor alternatives and as such detailed assessments are not practicable at this stage of the investigations. The assessment approach was aimed at identification and prioritisation of portions along the various alternatives that are considered most likely to be able to sustain the most diverse and sensitive faunal and floral populations and where more care would be required in the planning, construction and operational phases of the project. It has been made clear in the reports developed that as part of the planning phase of the development a walk down be undertaken of all areas considered of higher ecological importance identified within the baseline report for the selected route within the selected corridor. By so doing areas of least concern can be identified for the construction of support structures. It

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should further be noted that where portions of routes were identified that where considered ‘no go’ areas, it has been highlighted in the report and where possible alternative alignment has been proposed or recommended.

It should be noted that the assessment was based on a worst case scenario and are therefore considered

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indicative of the significance of impact that could result due to vegetation clearing and construction related activities within each sensitivity class. 205. HERITAGE Richard Summers BSocSci We greatly appreciate your input, your contribution is LLB LLM (Environmental noted if the site in question is designated as a natural 95. An independent review of the draft HIA Law) heritage site (no. 80) Both the Environmental and Report and the Cultural Landscape Report smith • ndlovu • summers Heritage legislation provide for protection of such sites was undertaken on behalf of our client by attorneys, acting for and there are appropriate measures to deal; with Mr. Ashley Lillie and Ms. Sarah Winter. This Elandsberg Farms heritage located in the context of infrastructure review is attached as Annexure “A” Stewardship Project, development. Even World Heritage Sites are adequately hereto.74 This review has confirmed the comment by e-mailed letter, covered in the same way. From a heritage perspective heritage significance of our client’s property independent visual impact we do not see any reason for ringing alarm bells in the following terms: assessment and heritage because the law is clear about impacts associated with reviews, 11 August 2014. development. 95.1. The natural and cultural landscape Nowhere in our HIA or specialists reports in the associated with the Elandsberg Nature significance of Elandsberg Nature Reserve and Reserve has outstanding heritage associated heritage resources questioned. This property significance and is worthy of Grade 2 and associated heritage resources enjoy specific and heritage status. The property is also a general protection from the NHRA Sections 34 and 35. designated Natural Heritage Site (No. 81). Both the Environmental and Heritage legislation provide for protection of such sites and there are appropriate measures to deal with heritage located in the context of infrastructure development. Our report covered this principle and we are confident that the assessment made acknowledges this legal requirement. The observation that the heritage resources in Elandsberg Nature Reserve maybe worthy Grade 2 heritage status as recommended in Winter and

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Baumman (2009) HIA Report cited by Lillie and Winter (2014) review remains a recommendation that was based on an HIA study. In order to go beyond an HIA recommendation, the classified sites would require further assessment as stipulated in Sections 7 and 8 of the NHRA (25 of 1999). These sections forms the basis for Heritage Assessment Criteria and Grading. The Winter and Baumann (2009) conclusions regarding Grade 2 status did not lead to these sites being included in the national or provincial heritage registers. However, this does not mean the sites are not protected. As heighted, they fall under the general protection category. From a heritage perspective we do not see any reason for ringing alarm bells because the law is clear about impacts associated with proposed development especially given the fact that the heritage resources in question already enjoy general protection and the HIA study was conducted conscious of these factors. 206. 95.2. The Elandsberg Nature Reserve is Richard Summers BSocSci We acknowledge your input and we are confident our recognised as a site of very high LLB LLM (Environmental heritage specialists covered your concerns adequately. conservation importance containing very Law) scarce fauna and flora. smith • ndlovu • summers We acknowledge Summers, et. al.’s observations and attorneys, acting for we are confident our heritage study process and Elandsberg Farms specialists covered the concerns and the compliance Stewardship Project, authorities are yet to make their own determination. Be comment by e-mailed letter, that as it may, we are confident that the heritage independent visual impact compliance authorities have the knowledge,

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assessment and heritage understanding and capacity to make responsible reviews, 11 August 2014. decisions regarding management of any heritage resources in the project area. 207. 95.3. The combination of both cultural and Richard Summers BSocSci We have no doubt that Elandsberg is significant and we natural heritage makes the Elandsberg LLB LLM (Environmental are confident that our specialists have the necessary Nature Reserve a property of considerable Law) expertise and experience to assess heritage significance heritage significance. smith • ndlovu • summers of any given site in the Republic. attorneys, acting for Elandsberg Farms We have no doubt that Elandsberg reserve is significant. Stewardship Project, After all the said sites already enjoy adequate protection comment by e-mailed letter, within the heritage management frameworks. independent visual impact assessment and heritage reviews, 11 August 2014. 208. 95.4. The Bosplaas and Bartholomeus Klip Richard Summers BSocSci The Environmental and Heritage legislation (NHRA) homesteads situated on the Elandsberg LLB LLM (Environmental provides for the adequate protection of significant sites Nature Reserve are considered to be Law) in the context of development. Our specialist’s excellent examples of an early Swartland smith • ndlovu • summers assessments are governed by the law and guidelines as (Bosplaas) and Victorian homestead attorneys, acting for well as expert opinion. SAHRA and Heritage Western (Bartholomeus Klip). The additional survival Elandsberg Farms Cape have provided guidelines for conducting Heritage of the old landscape context makes the Stewardship Project, Impact Assessment. property a very rare part of the cultural comment by e-mailed letter, landscape. independent visual impact The Heritage legislation (NHRA, Act 25 0f 1999) assessment and heritage provides for the adequate protection of significant sites reviews, 11 August 2014. in the context of development. The very law and guidelines as well as expert opinion govern our specialist’s assessments. However, it is our considered heritage opinion that there is no basis for describing or

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classifying Bosplaas and Bartholomeus Klip as the last of the “excellent examples” of any category of heritage resources without applying both the NHRA Sections 7 and 38 Assessment processes. It is our understanding that Winter and Baumman (2009) study which Summers, et. al. (2014) relied on in making this classification, was a NHRA Section 38 assessment study and not take into account Section 7 assessment. Our HIA and auxiliary heritage studies could not be influenced by another separate and independent HIA study in order to classify sites to national register grades without the correct management processes being applied. Such required management processes are not the scope of our HIA exercise. 209. 96. The review also identifies the following Richard Summers BSocSci Our specialists were appointed based on their expertise critical concerns with the heritage impact LLB LLM (Environmental and experience in Heritage Impact Assessments. We assessment undertaken to date as part of Law) have confidence in our specialists; we strongly believe the EIA process: smith • ndlovu • summers their various methods and approaches are adequate to attorneys, acting for fulfil their mandates. The proposed development is not 96.1. The landscape assessment Elandsberg Farms unique in any way and it is not the first development of undertaken in the Cultural Landscape Stewardship Project, its kind in the republic and the Western Cape in Report is coarse grained and inconsistent in comment by e-mailed letter, particular. terms of its scale of analysis. independent visual impact assessment and heritage The cultural landscape specialists were appointed based reviews, 11 August 2014. on their expertise and experience in Heritage Impact Assessments. As such, their chosen method of assessment may not be primarily dismissed on the basis that a reviewer does not agree with their approach. We

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are of the opinion that there are various methods and approaches, including those used in the HIA studies in question that are adequate to fulfil the Phase 1 HIA mandates. The proposed development is not unique in any methodological way and it is not the first development of its kind in the republic and the Western Cape in particular. As such, these best practice methods and approaches that our HIA team relied on. 210. 96.2. The natural and cultural landscape Richard Summers BSocSci Thank for your observation, your input has been noted. associated with the Elandsberg Nature LLB LLM (Environmental However you must appreciate that the proposed Reserve and Alternative Route 1 is Law) development covers over 300km in length. As such ungraded in the Cultural Landscape Report. smith • ndlovu • summers specialist sample their studies, if your site was missed in attorneys, acting for the sample it does not invalidate the general Elandsberg Farms observation and hence the recommendations for walk Stewardship Project, down surveys and heritage monitoring during comment by e-mailed letter, construction phase. independent visual impact Summers, et. al.’s observation has been noted. assessment and heritage However, it should be emphasised that the proposed reviews, 11 August 2014. development is linear covering more than 300km in length. As such, consistent with any study, in Phase 1 HIA specialists may sample their studies, and may not necessarily report on 100% ground coverage. The observation that Elandsberg Nature Reserve was not graded in the Cultural Landscape sub-specialist report does not invalidate the observations, conclusions reached and recommendations in the overall HIA report. After all, this nature reserve has been flagged for its significance and heritage management measures were

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proposed in relation to protecting the heritage resources in development context. 211. 96.3. There has been no recognition of the Richard Summers BSocSci The heritage report acknowledges existence of specific heritage issues and concerns which LLB LLM (Environmental significant sites throughout the landscape. While we were raised with respect to potential Law) appreciate the significance of the site we must also draw impacts on the Elandsberg Nature Reserve smith • ndlovu • summers your attention to the fact that the law allows you to and its suggested Grade 2 status in the attorneys, acting for nominate a site for heritage grading. Our understanding Built Environment and Landscape Report Elandsberg Farms is that the site is not yet graded. Much as we prepared by Winter and Baumann (dated Stewardship Project, acknowledge its significance, your reference is not March 2009) for the Kappa Omega 1st comment by e-mailed letter, binding, expert opinion may differ, and the fact that we 765kV power line. independent visual impact differ does not make your opinion better. assessment and heritage reviews, 11 August 2014. The HIA and associated specialists reports acknowledge existence of significant sites throughout the project receiving landscape. However, should Summers et. al. seek to have the sites in Elandsberg Nature Reserve treated as fully protected Grade 2 resources, then they should take that proposal through to the relevant heritage authority by applying NHRA Sections 7 and 8. Our HIA scope did not seek to grade site into the heritage register but rather to classify them for purposes of assessing potential impacts and management recommendations and responses in the context of proposed development. The fact that we may differ with Winter and Baumann’s (2009) opinion does not make Summers, et. al.’s opinion better especially given the observation that the latter based their argument on limited heritage

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assessment category to reach their conclusion. It is our opinion that adequate protection or management measures are already taking shape starting with the phase 1 study until the final HMP and CEMP subject to the project receiving necessary approvals to proceed as may be determined by the environmental and heritage compliance authorities. 212. 96.4. With regard to the Kappa Omega 1st Richard Summers BSocSci Although literature review is a component of the Impact 765kV power line, the southern route LLB LLM (Environmental Assessment process, expert opinion presented in the alternative was proposed to follow the Law) literature and previous reports does not bind specialist alignment of an existing 400kV power line smith • ndlovu • summers to align with previous observation. The report you are through the Elandsberg Nature Reserve. attorneys, acting for making reference to is not a benchmark and worse still The Winter and Baumann Report (2009) Elandsberg Farms is not published. It does not deserve the authority you identified the cumulative impacts of this Stewardship Project, are attaching to it. We strongly feel there is no basis for alignment as highly problematic from a comment by e-mailed letter, making a bible for conducting HIA in the project area. heritage perspective. Contrary to this independent visual impact recommendation, the Cultural Landscape assessment and heritage Although literature review is a component of the Impact Report for the proposed Kappa-Omega 2nd reviews, 11 August 2014. Assessment process, however, the Winter and 765kV power line concludes that the Baumman (2009) report referred to in Summers, et. al. heritage impacts associated with Alternative comment is not a benchmark for Phase 1 HIA studies in Route 1 through the Elandsberg Nature the project area. While the study may be relevant, in Reserve can be mitigated by its realignment our opinion there is no ground for over-emphasising the close to the existing 400kV power lines. No opinions expressed in that report. Be that as it may our reasons are provided in the Cultural HIA report is independent and not bound to explain Landscape Report to justify its variance variance with another independent opinion. We strongly with the findings of the Winter and feel there is no basis for making Winter and Baumman Baumann Report. (2009) report a bible for conducting HIA in the project area nor do we consider it benchmark for best practice

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in HIA. As such our HIA team need not justify or explain similarity of difference of opinion expressed in their reports with reference to the Winter and Baumann (2009) report as suggested by Summers, et. al. 213. 96.5. There is an over-reliance in the draft Richard Summers BSocSci Please note that the proposed development is a linear HIA Report and Cultural Landscape Report LLB LLM (Environmental development and the corridor is 2km wide, there is on mitigation measures being resolved once Law) enough room to avoid significant sites by diverting the preferred alternative route is smith • ndlovu • summers within the 2km corridor. The NHRA allows for mitigatory determined. For the reasons stated attorneys, acting for measures to minimise or to avoid any significant sites elsewhere in these comments, the reliance Elandsberg Farms on the direct path of the proposed development. Our upon mitigation measures as a means of Stewardship Project, specialists are aware of the provisions. The addressing each potentially significant comment by e-mailed letter, environmental and heritage legislation that govern our impact undermines one of the primary independent visual impact specialists studies does not advocate for freezing the purposes of the EIA process, which is to assessment and heritage landscape, they allow for sustainable development to ensure that significant adverse impacts are reviews, 11 August 2014. take place while ensuring that significant heritage avoided. resources are protected. Your concerns are covered by the legislation and we have confidence in the Environmental Authorisation process. Furthermore the Environmental Authorisation process provides for walk down surveys and heritage monitoring during developments. We strongly feel that your fears are baseless, all your concerns are covered by the law unless if you do not have confidence in the entire system.

We are at Phase 1 of HIA process and our recommendation for further Phase 2 studies to be conducted is based on our opinion that it would be

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feasible to select a specific route from the three alternatives studied. Should the compliance authorities approve the recommended route, we are of the opinion that further HIA study phases will be necessary to further guide the compliance process noting that the objective of an HIA is not to simply assess whether the development may or may not proceed. Far from being over-reliant on Phase 2 HIA processes, our report is consistent with the compliance authorities guidelines of conducting Phase 1 HIA and best practice principles of heritage management in development contexts.

Furthermore, we took into consideration NHRA (Act 25 of 1999) Section 38(4)(f) and (g). Planning for mitigation where impact is anticipated should the development proceed is an acceptable best-practice procedure. Recommending preferred route walk-down or Phase 2 studies is a perfectly normal and acceptable foundation for further heritage mitigation or management tool. Summers, et. al.’s comments that mitigation have been applied as a means of addressing each potentially significant impact is incorrect. The HIA Report upheld the principle that ideally, in situ protection of heritage resource in the project-receiving environment is primary. However, our study is relative to the broad socio-economic benefits to be derived from the proposed development. Should the proposed development be approved to proceed in any of the

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alternative routes, we recommended that Phase 2 HIA studies would be necessary. For example, in acknowledging the existence of heritage resources in the project receiving area, the worse case scenario would be that avoidance of heritage resource would not be possible. In such a scenario, the HIA report proposed several applicable management and mitigation measures. This can hardly be considered as being counter to the EIA process that seeks to ensure that adverse impacts are avoided as suggested in Summers, et. al.’s comments. In fact, this is in line with HIA guidelines and the NHRA Section 38 (3)(g).

In deciding our recommendations, we took into consideration several factors among them the fact that the proposed development is a linear with three alternatives proposed each with a 2km-wide servitude. The final direct footprint of the powerline would be within a 55m wide servitude. Should any of the proposed servitudes be approved in their current or amended form, there would be room to avoid any physical cultural properties by diverting the tower positions within the 2km-wide corridor of the final alternative. The NHRA allows for mitigatory measures to minimise or to avoid any significant sites on the direct path of the proposed development. Furthermore the Environmental Authorisation process provides for walk down surveys and heritage monitoring during

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developments. Contrary to comment that the HIA is going counter to the principles of EIA, it is our considered opinion that our HIA report fully addresses both potential impacts and possible responses. 214. 96.6. The integration of visual and heritage Richard Summers BSocSci Please note that the specialist studies are mutually specialist studies from a cultural landscape LLB LLM (Environmental exclusive to allow specialists to exercise their perspective has been inadequate. This is Law) independence. Your allegations in this regard are not acknowledged in the Cultural Landscape smith • ndlovu • summers valid. Specialist attended integration meetings where Report which notes that “meetings of the attorneys, acting for each specialist presented their findings to the study specialists have only occurred twice during Elandsberg Farms team before finalizing their reports. Apart from the study period, resulting in minimal cross Stewardship Project, integration meetings, technology such as drop box reference of specialist inputs”75 and “visual comment by e-mailed letter, allows us to share large volumes of data without impact assessment and public participation independent visual impact necessarily meeting face to face. Specialist reports and are separate specialist studies and have not assessment and heritage project progress reports were posted on our website for been available to the built environment and reviews, 11 August 2014. the public to view. We are confident that the number of cultural landscape specialists”.76 In order integration meetings and facilities we provided to share to adequately determine visual impacts on information are adequate for impact studies. landscapes and settlements of heritage It should be noted that the specialist studies are value, the visual and heritage specialist mutually exclusive to allow specialists to exercise their studies should have been appropriately independence. The project EAP or HIA PI convenes integrated during the scoping and impact Specialist workshops or summits or integration meetings assessment phases. as a project management exercise to keep each team member abreast with progress and key issues. We do not agree with Summers, et. al.’s suggestion that the HIA and Visual Impact Assessment reports should have been integrated in the way they propose. Instead, as the HIA principles, we evaluated all specialists’ reports applicable to the HIA and applied the data from these

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studies to compile the HIA report. We evaluated both the VIA and the Cultural Landscape Reports and applied the findings from these studies in compiling the HIA Report. We are confident that our HIA report addressed findings of all auxiliary studies and there is no justification for Summers, et. al.’s to use the comments from the Cultural Landscape report as a reflection of the entire HIA Study. The Cultural Landscape specialist was commissioned to conduct and independent study and so was the VIA specialist. The observation that these tow specialists’ reports are not integrated does not invalidates the HIA report because the HIA report is based on all other specialists’ inputs.

For the record, apart from integration meetings, multi media platforms and technology such as drop box allowed us to share large volumes of data with all specialists during the EIA and HIA studies without frequent face to face. Specialist reports and project progress reports are posted on our website for the public or any member of the team to view. We are confident that the number of integration meetings and facilities we provided to share information are adequate for impact studies. 215. 96.7. The draft HIA Report does not meet Richard Summers BSocSci Let me emphasise that our specialist have the necessary the requirements of section 38(3)(e) of the LLB LLM (Environmental experience and expertise to conduct impact studies. As NHRA as it does not include the outcomes Law) far as we are concerned requirements of section (3) (e) of the public consultation processes smith • ndlovu • summers were covered adequately. Heritage specialists

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undertaken during the scoping phase. attorneys, acting for participated in public consultation meetings and also There is no evidence to suggest that there Elandsberg Farms exchanged information during the studies. It is has been any engagement with registered Stewardship Project, unfortunate that throughout the entire process we conservation bodies during the heritage comment by e-mailed letter, engaged the relevant authorities as required by the law. assessment process. Evidently this has not independent visual impact Please note that Heritage Western Cape and SAHRA occurred. assessment and heritage were engaged in accordance with the law. Furthermore reviews, 11 August 2014. any other stakeholders were engaged as part of the public consultation process. The HIA process forms part of the EIA process, As such conservation bodies were also notified as part of the EIA process. If any were missed the EIR process provides room for public engagements. The EIA and HIA studies must not be viewed in isolation. It is not clear how Summers, et. al. concluded that the HIA report does not meet the requirements of NHRA Section 38(3)(e). The HIA study is part of the EIA exercise for proposed development. A detailed I&APs, community and stakeholder consultation process has been conducted through specialised Public Participation Process (PPP). The HIA report clearly refers to this PPP exercise and any issue on heritage raised from this process has been addressed accordingly. This approach of having a specialist independently coordinate the stakeholder consultations is not arbitrary but well considered and is very effective. More important, the process meets the requirements of the NHRA Section 38(3)(e). However, this should be considered in context of NHRA Section 38(8) that acknowledge that provisions

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of the environmental management guidelines are primary subject to the authorities ensuring that heritage resources are adequately addressed in the EIA exercise. There nothing to suggest that parallel stakeholder engagement process should be conducted. In our opinion, the stakeholder and public consultations being conducted for the broader EIA project by an independent coordinator with participation of HIA PI is detailed and encompassing enough for both EIA and HIA processes. Nothing in this exercise excludes or prohibits any part to participate or comment or raise specific heritage issue. Ironically, Summers, et.al. comments were directed through the very same PPP process that they are criticising as not having been done. 216. 97. There is insufficient information in the Richard Summers BSocSci First and foremost powerline development is not unique, DEIR and the specialist reports to be able to LLB LLM (Environmental powerlines have been built all over and generic impacts support the contention that placing new Law) of powerline development are well documented. large scale power line infrastructure within smith • ndlovu • summers Environmental Impact studies remember are not the existing corridors impacted by existing attorneys, acting for academic endeavours. The selection of routes is power line infrastructure is defensible from Elandsberg Farms determined by Eskom‘s strategic planning and demand. a heritage perspective. The specialist Stewardship Project, We are confident that our specialists are capable and reports have failed to test this contention comment by e-mailed letter, they fulfilled their requirements of the relevant across various scales of analysis, which independent visual impact legislation that govern their work. would be required before any defensible assessment and heritage conclusions can be made from a heritage reviews, 11 August 2014. First and foremost the proposed powerline development perspective. is not unique nor is it the first of its kind for the developer. Powerlines have been built and generic impacts of powerline development are well documented.

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Impact studies are not academic endeavours but rather applied studies. The HIA study was not designed to test particular contentions but rather to assess the potential impact of the proposed development. Heritage resources and development are not necessarily incompatible to a point that we should be obliged to depart from a of point testing contentions even those that have no basis. The proposed alternative routes have been selected taking into consideration a basket of factors, which suggest that the alternatives are viable. The environmental and heritage compliance authorities that approved the study applications also concur that the alternatives gives were viable enough to warrant the study to proceed. That means the HIA study had to assess impact within each potential route in context of the fact that each route is considered viable. For example, assuming that the proposed development is approved to proceed within a servitude that is in the proximity of a listed Grade 2 colonial period historic building, there is nothing from heritage management perspective that suggested that such a move would result in automatic destruction of the said Grade 2 Property. The logic framework of heritage management would dictate that such a decision would be made in context of applicable heritage management tools. As highlighted before, the proposed development is not unique nor is it a pilot exercise. We have several similar developments in comparable environments that we can learn from. Even at World

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Heritage Sites Level, several WHS listed properties are managed and remain protected with development context in and around these properties. 217. 98. The review commissioned by our client Richard Summers BSocSci We are aware those significant natural and cultural also confirms that insufficient consideration LLB LLM (Environmental heritage sites occur along the proposed powerline route. has been given to the cumulative impacts Law) As you are aware heritage resources are graded of introducing a second 765kV power line smith • ndlovu • summers according to significance. The NHRA allows individuals to within significant natural and cultural attorneys, acting for nominate sites for grading if they so wish. The studies landscapes associated with Alternative Elandsberg Farms adequately considered the potential of encountering Route 1. Given the heritage significance of Stewardship Project, significant resources. Furthermore the NHRA provides our client’s property, it could be argued comment by e-mailed letter, for measures to avoid or to minimise impact of that the combined cumulative impacts of an independent visual impact development to significant heritage sites. additional 765kV power line through our assessment and heritage client’s property, the greater Tulbagh Valley reviews, 11 August 2014. Summers, et. al. makes an important observation and other significant local landscapes regarding cumulative impacts. However, we would like associated with Alternative Route 1 to state that we have a different opinion to the outweigh (in terms of significant adverse reviewers’ conclusion. Our reference to cumulative heritage impacts) the equivalent impacts impacts cannot be dismissed off hand as being associated with Alternative Routes 2 and 3. insufficient. Applying Rapid Cumulative Impact However, there is insufficient information in Assessment (RCIA) is an acceptable approach at this the draft HIA Report and the Cultural stage of the HIA study. Typically an RCIA involves only Landscape Report to enable an appropriate a desk review of available information, including existing interrogation of this. HIA, EIA & SIAs; strategic, regional, and/or heritage resource planning documents; and reports from the scientific community, and other interested actors. We have a different understanding of cumulative impacts assessment processes that should be followed in any development including the proposed Kappa-

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Omega Powerline development. We are in agreement with the observation that the proposed development will raise cumulative impacts and the HIA report pointed out this factor. However, we do not believe cumulative impacts can be adequately assessed in isolation or specifically to a category of valuable environmental and social component.

While both the environmental and heritage management regulations provide for inclusion of cumulative impacts, there is not baseline in heritage framework to suggest that our reference to cumulative impacts in the HIA report were insufficient. Literature review confirms that there is significant debate and disagreement among academics, developers, practitioners, and civil society organizations about whether cumulative impact assessment should be an integral component of environmental and social impact assessment (E/SIA) or a separate stand-alone process. However, we are clear that CIA is evolving and there is no single accepted state of global practice and as such, we limited our present input to RCIA.

However, in the HIA being part of the EIA process, we acknowledged that contemporary good practice requires that, at a minimum, project sponsors assess during the E/SIA process whether their development may contribute to cumulative impacts on valued

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environmental and social components and/ or may be at risk from cumulative effects on resources they depend on. And our HIA study has fulfilled this position by including the data from the RCIA.

We are of the opinion that full cumulative impact assessment processes involve continuous engagement with compliance agencies, affected communities, developers, and other stakeholders. We subscribe to the position of international organisations, such as the IMF and IFC, that in practice, effective design and implementation of complete cumulative assessment processes is often beyond the technical and financial capacity of a single developer. Cumulative Impact assessment (CIA) thus transcends the responsibility of a single project developer. In the context of HIA study under discussion, we acknowledge cumulative impacts are ever present but they may not be assessed in discipline isolation as implied by the review.

There is no prohibitive factor for cumulative impacts to be identified and acknowledged in the ESIA process. The project’s EMP and HMP can cover the measures proposed for managing the incremental contribution of a given project. This is often the case when dealing with well-studied airsheds, watersheds, seascapes, and landscapes, or with widely recognized global issues such as climate change. For instance, methods for assessing

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the incremental contribution to fabric of a graded heritage property degradation from the electricity transmission infrastructure operation may be well established in the heritage management community and are typically an integral component of a good HMP process. Similarly, the determination of visual intrusion of landscapes and their management within the heritage visual aesthetic context are well-recognized national or global practices. Neither of these cases would require a separate Heritage Cumulative Impact Assessment process; the inclusion of standard heritage mitigation, site protection and control measures as an integral component of HMP would typically suffice. Obliviously we went with this approach in our HIA study. 218. 99. For the reasons set out above, the Richard Summers BSocSci To suggest that the EIA process is fundamentally flawed heritage impact assessment undertaken as LLB LLM (Environmental is a insult to the entire team. The entire team is part of the EIA process is fundamentally Law) qualified and highly experienced to handle impact flawed. There is insufficient information to smith • ndlovu • summers assessment for a powerline project. While we appreciate enable a considered understanding of all attorneys, acting for that Elandsberg Nature Reserve has significant heritage heritage impacts or how the proposed Elandsberg Farms resources, your comment is not clear. Please note that power line will affect sites of particular Stewardship Project, the proposed corridor for heritage studies is 4km wide. heritage significance. The Elandsberg comment by e-mailed letter, As far as we are concerned the corridor is wide enough Nature Reserve is of considerable heritage independent visual impact to avoid any significant heritage resources. Which type significance, and it forms part of an assessment and heritage of heritage resources are you concerned with? As far as important cultural landscape that is not reviews, 11 August 2014. we are concerned if the heritage resources in the nature adequately described or assessed in the reserve are known, we are confident that it will be easy draft HIA Report or the Cultural Landscape for the development to avoid them by shifting pole Report. positions within the 4km corridor. If the final route is

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selected it still going to be subjected to a walk down survey by specialists. If heritage resources are encountered specialist will design mitigation measures that may include deviations or shifting of pole positions where necessary.

In the context of a development site specific HIA, the objective is not necessarily to test the universal value of heritage resources that may be in the project area, but rather to identify the sites and assess the potential impact the proposed development may trigger on the sites. In fact, the true outstanding value of any given heritage resources may not be fully investigated or measured in the context of a Phase 1 HIA scope of study. We are confident that the impact assessment we applied fulfils the objectives of the EIA process. Potential development related Impacts on heritage in the project area were well established. Therefore, we do not agree with Summers, et. al.’s conclusion that the HIA undertaken is “fundamentally flawed”. It is our considered position that describing our study and the supporting sub-disciple reports as flawed border on emotive reviewing which is not based on factual evaluation of the actual reports, methodologies applied and conclusions drawn in the Phase 1 HIA Report. The referenced nature reserve already enjoys accorded protection and no amount of repeated descriptions or overemphasis is necessary. Were the proposed

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development be approved to proceed in the vicinity of significant heritage properties in Elandsberg Nature Reserve, it does not follow that the heritage properties will automatically be destroyed as a result.

As highlighted already, as heritage management professionals, we do not see heritage resources and socio-economic development as mutually exclusive. Take example of UNESCO World Heritage Site listing as the ultimate high-ranking classification of heritage resources. Even such sites are managed from the same principle of socio-economic balance and sustainable management. We are duty bound by best practices to evaluate any potential impact of development on heritage resources relative to the sustainable and social and economic benefits to be derived from the development, (NHAR 25 1999 Sec. 38 (3)(e). The HIA report is detailed adequately to inform the responsible authorities and the stakeholders to allow for relevant judgements on the balance between the potential impacts of the proposed development.

We do not see HIA objectives as being to seek freezing the “cultural landscape” given the very fact that any cultural landscape is an ever-changing and organically evolving responsive to current and future needs and cultural resources management. There is nothing in these principles that suggest our Phase 1 HIA is flawed

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fundamentally or otherwise. We take exceptions to such commentary. To the contrary, we have upheld the fundamental principles of Phase 1 HIA and heritage management in line with applicable legislations, management guidelines and international best practices. 219. 100. The failure to appropriately assess site Richard Summers BSocSci Your comment is baseless, our heritage studies fulfill the specific heritage impacts renders the LLB LLM (Environmental requirements of section 38 of the NHRA as well SAHRA assessment deficient. The deficiencies in Law) and Heritage Western Cape guidelines. If we are the assessment of heritage-related impacts smith • ndlovu • summers referring to the same heritage legislation your comment effectively means that the requirements of attorneys, acting for does not hold water. You must learn to appreciate other section 38 of the National Heritage Elandsberg Farms people’s effort and complement where necessary. Resources Act have not been complied with Stewardship Project, Negativity does not solve problems, you are welcome to in connection with the minimum comment by e-mailed letter, make positive inputs to the exercise. requirements for the assessment of independent visual impact heritage impacts. assessment and heritage Our HIA assessment did not fail to assess site-specific reviews, 11 August 2014. impacts as suggested in Summers, et. al.’s comments. Once again, we note that Summers, et. al. opted to completely disregard, either deliberately or by design, all the methods, principle, results and recommendations provided into the Phase 1 HIA report and associated specialists studies reports. The HIA study report fulfils both the NHRA and the EIA requirements and it may not be reduced to descriptive terms such as “fundamentally flawed”, “Failure to appropriately…”, “deficient” etc. without any form of quantification of the so called flaws or deficiencies. Ironically, we observe that Summers, et. al. comments use the same emotive language on other independent

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specialist report comments. For example, paragraph 99 is replicated as paragraph 104 with minor changes when referring to the HIA and VIA reports. The object and objectivity of the comments become questionable if all comments only seek to denigrate the studies conducted. At most, Summers, et. al. comments does not help us to improve the process being undertaken. 220. 101. Related to this issue is the impact on Richard Summers BSocSci Please note that no corridor has been approved so far. sense of place. The experiential qualities of LLB LLM (Environmental The EIA process provides for walk down surveys once heritage sites is fundamental to their Law) the final route selection is approved. In the same vein significance and nature. Given the manner smith • ndlovu • summers our specialist recommended walk down surveys for the in which the proposed power line dissects attorneys, acting for proposed project. As such recommended walk down our client’s property it follows that the Elandsberg Farms surveys will cover your concerns. As far as we are impact of this on a site specific scale must Stewardship Project, concerned the Visual specialist is qualified and used be considered. This will need to be assessed comment by e-mailed letter, appropriate methodology to assess the visual impact of both in terms of the heritage assessment independent visual impact the proposed powerline. May you provide us with (in terms of the impact of the project of the assessment and heritage potential significant impact you are referring to. qualities and significance of the heritage reviews, 11 August 2014. resource) and from a visual impact The Phase 1 HIA report addressed the potential impact perspective. The DEIR has failed to on sense of place on the three alternatives. Sense of evaluate, consider and asses this potentially place is a subjective intangible value and so are the significant impact. experiential qualities. Having said that, we are confident that the specialist VIA study adequately addressed this issue as well. The HIA report also applied the findings of the VIA. The Phase 1 HIA adequately addressed this intangible resources impact and there was no failure as suggested in Summers, et. al comments.

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221. VISUAL IMPACTS Richard Summers BSocSci LLB LLM (Environmental 102. An independent review of the VIA Law) Report was undertaken on behalf of our smith • ndlovu • summers client by Messrs. Bernard Oberholzer and attorneys, acting for Quinton Lawson. This review is attached as Elandsberg Farms Annexure “B” hereto and should be Stewardship Project, considered as forming part of these comment by e-mailed letter, comments. independent visual impact assessment and heritage reviews, 11 August 2014. 222. 103. By way of summary, the Oberholzer Richard Summers BSocSci There is no regulation of how long should the Visual and Lawson review identifies the following LLB LLM (Environmental report be.. Hence the specilaist is highly qiualified and concerns with the visual impact assessment Law) has conducted a lot visual studies in the country as a undertaken as part of the EIA process: smith • ndlovu • summers whole. attorneys, acting for 103.1. The VIA Report is unacceptably Elandsberg Farms brief, with the study being divided into Stewardship Project, three broad landscape types (Ceres Karoo, comment by e-mailed letter, Ceres Mountain and Swartland) with a independent visual impact minimal description of each study area. assessment and heritage reviews, 11 August 2014. 223. 103.2. The VIA Report fails to identify local Richard Summers BSocSci The specialist did assess all the areas and the final landscapes within the three broad study LLB LLM (Environmental walkdown will further specify the scenic routes and areas and fails to identify important scenic Law) many others resources, landscape features, scenic smith • ndlovu • summers routes, wine routes, areas of a wilderness attorneys, acting for or rural character, and areas of Elandsberg Farms

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conservation value or tourism importance. Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 224. 103.3. There has been no attempt in the Richard Summers BSocSci The visual report did rate the resources, please recheck VIA Report to rate visual resources in terms LLB LLM (Environmental the report carefully. of their uniqueness, scarcity, vulnerability, Law) or in relation to their natural or cultural smith • ndlovu • summers landscape value. attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 225. 103.4. The study methodology in the VIA Richard Summers BSocSci Comment noted. Report is flawed because of the lack of LLB LLM (Environmental visual criteria used, such as visual integrity, Law) visual compatibility, visual sensitivity, and smith • ndlovu • summers sensitive receptors. attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 226. 103.5. The manner in which recommended Richard Summers BSocSci Site specific mitigation measures can then be developed

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mitigation measures are dealt with in the LLB LLM (Environmental for areas where re-alignment is not an option, however VIA Report is superficial. The assessment is Law) this would require detailed site assessments of all these of such a generic level that the mitigation smith • ndlovu • summers areas; possibly as a ‘second phase’ assessment that can measures could equally apply to any similar attorneys, acting for inform the EIA prior to final submission or prior to development across the country. In other Elandsberg Farms finalisation of the EMP for the project. This will allow for words, the mitigation measures are devoid Stewardship Project, the further development of site specific construction of any context relating to this project or its comment by e-mailed letter, and operational mitigation measures. impact on the receiving environment and independent visual impact areas which are particularly sensitive to assessment and heritage visual impacts. reviews, 11 August 2014. 227. 103.6. No monitoring programmes, or input Richard Summers BSocSci Site specific mitigation measures can then be developed into the Environmental Management Plans, LLB LLM (Environmental for areas where re-alignment is not an option, however are included in the VIA Report. Monitoring Law) this would require detailed site assessments of all these programmes are considered essential to smith • ndlovu • summers areas; possibly as a ‘second phase’ assessment that can ensuring compliance with recommended attorneys, acting for inform the EIA prior to final submission or prior to mitigation measures. Elandsberg Farms finalisation of the EMP for the project. This will allow for Stewardship Project, the further development of site specific construction comment by e-mailed letter, and operational mitigation measures. independent visual impact assessment and heritage reviews, 11 August 2014. 228. 103.7. The maps included in the VIA Report Richard Summers BSocSci Comment noted. are so reduced that legibility is a problem. LLB LLM (Environmental The maps are broad and general and Law) accordingly have little use at a local scale. smith • ndlovu • summers attorneys, acting for Elandsberg Farms Stewardship Project,

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comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 229. 103.8. The visual impacts associated with Richard Summers BSocSci At this moment in time there is no specifi EMP which construction camps, access roads and LLB LLM (Environmental means where these developments will be is unknown ancillary project developments has not Law) but on the report those ancilliry services were discussed been assessed. smith • ndlovu • summers and mitigation measure were put forward. attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 230. 103.9. No 3D or visual simulations, such as Richard Summers BSocSci The montages or visual simulations were provided on montages, of the proposed power line are LLB LLM (Environmental the appendix of maps for the whole study. given in the VIA Report. Law) smith • ndlovu • summers attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 231. 104. For the reasons set out above, the Richard Summers BSocSci It is not the objective of this report to attempt to visual impact assessment undertaken as LLB LLM (Environmental demarcate all sections of power line for all the

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part of the EIA process is fundamentally Law) alternative corridors that would need to be mitigated. flawed. Accordingly, the VIA Report does smith • ndlovu • summers This can only be done once the final alignments have not assist in assessing the visual impact of attorneys, acting for been selected and tower positions have been finalized. the proposed power line. There is therefore Elandsberg Farms Site specific impacts will be considered during the walk insufficient information to enable a Stewardship Project, down. considered understanding of all visual comment by e-mailed letter, impacts or how the proposed power line will independent visual impact affect particular resources. As such, it is not assessment and heritage possible at present – and based on the reviews, 11 August 2014. limited nature and scope of the studies undertaken to date – for our client to engage meaningfully on the manner in which the project will impact on the heritage significance and experiential qualities of our client’s property. 232. 105. A far more comprehensive treatment Richard Summers BSocSci The specific EMP will address your clients properties, the of the potential visual issues, visual impacts LLB LLM (Environmental walkdown will cover your client and will be contacted associated with our client’s properties, and Law) when the department authorises the preffered route. impacts on sense of place is required. smith • ndlovu • summers attorneys, acting for Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 233. NOISE-RELATED IMPACTS Richard Summers BSocSci Thank you for your comment. LLB LLM (Environmental

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106. The DEIR states that “Noise levels are Law) expected to increase as a result of various smith • ndlovu • summers construction activities. The noise will be attorneys, acting for limited to the construction phase. Elandsberg Farms Depending [sic] at the area of construction Stewardship Project, and surrounding activities, noise level might comment by e-mailed letter, be negligible.”77 independent visual impact assessment and heritage reviews, 11 August 2014. 234. 107. The manner in which noise-related Richard Summers BSocSci Thank you for your comment. Please be aware of the impacts associated with projects of this LLB LLM (Environmental fact that,its not the first time that Eskom is doing a nature is dealt with in the DEIR is Law) project of such kind. We have addressed all noise superficial and has no bearing on the smith • ndlovu • summers impacts, through out the DEIR. We even included project or anticipated project-related attorneys, acting for mitigation measures. impacts. Elandsberg Farms Stewardship Project, comment by e-mailed letter, independent visual impact assessment and heritage reviews, 11 August 2014. 235. 108. It is widely known that coronas from Richard Summers BSocSci Thank you for your comment. Please be aware of the high voltage transmission lines can LLB LLM (Environmental fact that,its not the first time that Eskom is doing a generate audible noise and radio-frequency Law) project of such kind. We have addressed all noise noise. This can potentially cause a nuisance smith • ndlovu • summers impacts, through out the DEIR. We even included and can also give rise to power loss and attorneys, acting for mitigation measures. As for electromegnatic electromagnetic interference (in addition to Elandsberg Farms interference, despite extensive research, to date there the adverse impact of audible noise). Stewardship Project, is no evidence to conclude that exposure to low level comment by e-mailed letter, electromagnetic fields is harmful to human health.

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independent visual impact assessment and heritage reviews, 11 August 2014. 236. 109. The noise impacts that will be Richard Summers BSocSci Thank you for your comment. We even included experienced on our client’s property have LLB LLM (Environmental mitigation measures. As for electromegnatic not been assessed in any meaningful Law) interference, despite extensive research, to date there manner. The DEIR considers the audible smith • ndlovu • summers is no evidence to conclude that exposure to low level noise impact solely from the perspective of attorneys, acting for electromagnetic fields is harmful to human health. construction operations. Whilst noise Elandsberg Farms impacts from construction are relevant, Stewardship Project, restricting the assessment of all potential comment by e-mailed letter, audible noise impacts (which the DEIR has independent visual impact done) is by no means adequate for the assessment and heritage purposes of satisfying the EIA Regulations. reviews, 11 August 2014. The conclusion that noise levels “might be neglible” is not borne out or substantiated by specialist input. 237. 110. The potential for the project to give Richard Summers BSocSci Thank you for your comment. Please be aware of the rise to audible noise must be investigated, LLB LLM (Environmental fact that,its not the first time that Eskom is doing a evaluated and assessed. The studies Law) project of such kind. We have addressed all noise required in this regard must be sufficiently smith • ndlovu • summers impacts, through out the DEIR. We even included accurate to enable our client to make a attorneys, acting for mitigation measures. As for electromegnatic meaningful appraisal of the potential for Elandsberg Farms interference, despite extensive research, to date there noise impacts to impact on their property Stewardship Project, is no evidence to conclude that exposure to low level rights, and to give rise to a nuisance. comment by e-mailed letter, electromagnetic fields is harmful to human health. independent visual impact assessment and heritage reviews, 11 August 2014.

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238. CONCLUSIONS Richard Summers BSocSci This can only be done once the final alignments have LLB LLM (Environmental been selected and tower positions have been finalized. 111. The DEIR is materially deficient in Law) Site specific impacts will be considered during the walk several respects, and most notably in smith • ndlovu • summers down. connection with the failure to identify, attorneys, acting for consider, evaluate and/or assess potentially Elandsberg Farms significant sitespecific impacts (including Stewardship Project, cumulative impacts) associated with the comment by e-mailed letter, proposed power line. independent visual impact assessment and heritage reviews, 11 August 2014. 239. 112. Regulation 31(2) of the EIA Richard Summers BSocSci Thank you for your comment. Regulations is determinative of the required LLB LLM (Environmental content of environmental impact reports. Law) For the reasons set out herein, the DEIR smith • ndlovu • summers does not satisfy the prescribed requirement attorneys, acting for relating to (1) the content for Elandsberg Farms environmental impact reports; and Stewardship Project, comment by e-mailed letter, (2) the nature and scope of impact independent visual impact assessment in terms of NEMA. assessment and heritage reviews, 11 August 2014. Hermon Farmers Association Objections 240. Dear All, Mike Gregor, Elandsberg Thank you for the information provided. I have attached a response from the local Stewardship Project, Farmers Union and lists of member’s comment by e-mailed letter, signatures in support of the motion. Please 08 August 2014. note that a number of our members are

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away hunting at the moment. Regards, Mike Gregor. 241. Objection: second 765kV Power line Deon Steyn, Chairperson, Objection noted. Transmission Line Kappa-Omega (DEA ref Hermon Farmers 14/12/16/3/3/2/352). After discussion with Association, comment by e- Mr. Shawn Johnston, environmental officer mailed letter, 08 August for Sustainable FuturesZA and the proposed 2014. project, we were informed that option 2 and 3 of this transmission line proposal was rejected and tah the newly preferred route would be via Wolsely, Elandsberg, DENEL towards Omega substation. 242. The Hermon Farmers Association strongly Deon Steyn, Chairperson, Objection noted object to the building of newly proposed Hermon Farmers transmission line, crossing our valley at Association, comment by e- Elandsberg near Hermon towards the mailed letter, 08 August Omega substation. 2014. 243. The building of this power line will visually Deon Steyn, Chairperson, Comment noted. destry the natural sense of place of our Hermon Farmers valley and environment and any further Association, comment by e- erectionof lines will have a negative socio mailed letter, 08 August economic impact on all people living in this 2014. area. 244. The line will further have a negative impact Deon Steyn, Chairperson, Comment noted. on farming activities in our area as Hermon Farmers aeroplanes are used to spray our crops. The Association, comment by e- lines make it increasingly difficult and mailed letter, 08 August dangerous for all parties concerned. 2014.

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As there are already existing power lines in Deon Steyn, Chairperson, Thank you for your comment our area and along the suggested route, Hermon Farmers the impact of new lines are not mitigated as Association, comment by e- you would suggest, but it actually has a mailed letter, 08 August negative cumulative effect and it is 2014. destroying our sense of place. 245. There is also sensitive Renosterveld in close Deon Steyn, Chairperson, Thank you for your comment. proximity, which are very rare in the rest of Hermon Farmers the world, and damaging this would be Association, comment by e- catastrophic. mailed letter, 08 August 2014. 246. We would also like to stress that this Deon Steyn, Chairperson, Thank you for your comment. particular route was considered by Eskom Hermon Farmers in 2006 and rejected for valid reasons. We Association, comment by e- do not see why this line wil now fulfill the mailed letter, 08 August criteria. 2014. 247. Attached please find the names and farms Deon Steyn, Chairperson, Thank you for your assistance, with the names. We will of farmers belonging to our Association who Hermon Farmers be registering them as interested and affected parties. strongly object to this new proposed line Association, comment by e- and who wants to be registered as mailed letter, 08 August interested and affected parties. 2014. Tomi’s Abbotoir’s Objections 248. I am a landowner near Hermon and believe Laurie Terblance, Dear Laurie, that aesthetics and sense of place, as well Operational Manager, Toni’s Thank you for your e-mail. I hereby acknowledge your as land value will be negatively affecetd by Abbotoir, comment by reply e-mails and you have been registered you as an option 2 line. I am also concerned about form, 14 July 2014 interested and affected party. I further register your visual impact on Hermon and adjacent opposition to the proposed Eskom 2nd 765kV towns, Riebeeck Kasteel and Riebeeck West transmission line through your area and your points

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and effects of power lines regarding health listed in the comments form received. issues, Cancer! Laurie, I look forward to any additional comments from yourself and any other interested and affected parties. Sincerely, Shawn Johnston 249. Hi Shawn, Laurie Terblance, Hi Laurie, As stated in our previous correspondence Operational Manager, Toni’s I can come and see you on Monday, 21July 2014 at from Michelle we still want to be registered Abbotoir, comment by reply 11am to clarify the route. as an affected and interest party as we are form, 18 July 2014 Find attached the Google Earth kmz files for the a member of the Hermon Boerevereniging, Gamma-Kappa and Kappa-Omega routes. also have land in Hermon and we are concerned on the impact of the Sincerely, Shawn Johnston environment between Tomis, Hermon and Wellington, especially as far as visual impact is concerned.

We are further concerned that none of the public participation documents were available at Riebeeck Kasteel Library on request and we want to have access to these documents for feedback purposes. We therefore still request to be registered as an affected party as our request was sent within the prescribed period Best regards, Laurie Terblanche Tomis Trust Trustee Renosterveld Conservancy Objections 250. Morning Shawn, Frank Turner, Chairpsron, I hereby acknowledge receing you comment. Thank you. Herewith our proposed letter. See what you Renosterveld Conservancy,

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think and get back to us by 5 pm please. comment by e-mail, 14 July Regards, Frank 2014. 251. We as the Renosterveld Conservancy in Frank Turner, Chairpsron, Objection noted. partnership with CapeNature, the Renosterveld Conservancy, Wellington Landbou Vereniging, the comment by e-mail, 14 July Wellington Tourism Association and all the 2014. members of the Renosterveld Conservancy OBJECT TO AND WILL APPEAL the construction of the above mention line through our conservation area in the strongest possible manner! 252. The route through our conservancy and the Frank Turner, Chairpsron, Kentridge Makhanya: The decision was taken by the greater Wellington area was proposed and Renosterveld Conservancy, Minister of Environmental Affairs to dismiss the appeals rejected in 2006 due to the sensitivity of comment by e-mail, 14 July against the 1st 765kV line. The 1st 765kV line is the area. We therefore find it totally 2014. currently under construction. However during the EMP unacceptable that the same route be and the servitude acquisition phase mitigation measures reconsidered once it has already been will be put in place to minimise potential impacts. rejected. 253. There are already two power lines going Frank Turner, Chairpsron, Thank you for your comment. We hereby acknowledge through Elandsberg Private Nature Reserve Renosterveld Conservancy, your concerns and you have been registered you as an and the ammunition factory, comment by e-mail, 14 July interested and affected party. I further register your Rheinmetaal/Denel which is a National Key 2014. opposition to the proposed Eskom 2nd 765kV Point. transmission line through your area. ONE MORE POWERLINE IS JUST TOO MUCH. 254. The Renosterveld Conservancy was Frank Turner, Chairpsron, Thank you for the information. established in 2002 and covers an area of Renosterveld Conservancy, approx.24,000 hectares with 13 members. comment by e-mail, 14 July

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The aim of the Conservancy is to protect 2014. the critically endangered and highly sensitive Renosterveld. This area has the largest piece of Renosterveld intact, of which there is only 4% left in the world, as recognized by Kirstenbosch Botanical Gardens, it is a HOT SPOT for endemic species. 255. The Conservancy has an active relationship Frank Turner, Chairpsron, Thank you for your comment. with Cape Nature and Department of Renosterveld Conservancy, Site specific mitigation measures can be developed for Landcare, in the clearing of aliens such as comment by e-mail, 14 July areas where re-alignment is not an option, this would black wattle, Port Jackson, hakea, blue 2014. require detailed site assessments of all these areas; gums etc. Millions of rand have been possibly as a ‘second phase’ assessment that can inform invested by the State and landowners. the EIA prior to final submission or prior to finalisation Three of the farms have signed and of the EMP for the project. This will allow for the further committed their land in perpetuity to the development of site specific construction and stewardship program with Cape Nature. operational mitigation measures. This is a unique public/private partnership aimed at restoring, maintaining and protecting critically endangered fauna and flora. 256. Members are concerned about the Frank Turner, Chairpsron, Comment has been noted. Please be adviced, that degrading of fauna and flora during the Renosterveld Conservancy, intense mitigation measures, will be included in the site possible construction of the line and comment by e-mail, 14 July specific EMP to ensure that the such beauty is vehicles used in the process. The unsightly 2014. preserved. vista will adversely affect the natural beauty and uniqueness of this unspoiled natural wonder.

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The critically endangered geometric Frank Turner, Chairpsron, Thank you for your comment, and it has been noted. tortoise, our flagship species, is particularly Renosterveld Conservancy, Environmental Impacts of power lines are assessed and vulnerable to any disturbances. Other comment by e-mail, 14 July quantified inside the EIR report. In most instances concerns are fires, during construction and 2014. mitigation measures are also recommended. Detailed unrestricted access to nature reserves. mitigation measures will be provided inside the site specific EMP. A CLO and Environmental Control Officer will be appointed by Eskom, who will take measures to controlling construction related matters and to ensure that no unauthorised access is allowed in the nature reserve. 257. The birdlife is already under threat and the Frank Turner, Chairpsron, Thank you for your comment, and it has been noted. shrinking and disturbance of the natural Renosterveld Conservancy, habitat, which we as a conservancy have comment by e-mail, 14 July pledged to protect, will be seriously 2014. affected. We have not only created a conservancy for the present day but also for the future generations. We are a success and would like the impact study to take cognizance thereof. 258. As the Conservancy chairman, I speak on Frank Turner, Chairpsron, Thank you for your comment and it has been noted. behalf of my members who are in Renosterveld Conservancy, agreement with the details of this letter. comment by e-mail, 14 July We understand the necessity of the 2014. construction of the line and do realize that it is of national importance - but where?!? If I take your map and take the green line 7

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8 9 10 11 12 it would bypass our conservancy. The route would travel through areas of wheat lands north of Gouda, down past Riebeeck Kasteel on the east side to join up with your Grid at 13. Ideally this would be our choice! 259. You ask in your questionnaire what the Frank Turner, Chairpsron, Thank you for your comment. impact would be and I can honestly say it Renosterveld Conservancy, would be No 5 – EXTREME and forever, 25 comment by e-mail, 14 July years plus, if the line came through on 2014. existing routes or further south. Our conservancy stretches from Voelvlei dam in the north to Bainskloof in the south. One cannot object to the construction of the power line as I have already said – it is of national interest. But, one could spend the extra funds now on a slightly longer route and save the conservancy for posterity. 260. I would like to meet with the relevant Frank Turner, Chairpsron, Thank you for your comment. We will make officials, be they Eskom or Nzumbululo on Renosterveld Conservancy, arrangements, to meet up with you. site to discuss the situation further. comment by e-mail, 14 July 2014. Department of Agriculture, Forestry and Fisheries Objections 261. Dear Shawn, Susan Steyn, Department of I hereby acknowledge receiving your submission. Attached please find DAFF's input. Agriculture, Forestry and Comment noted. Regards, Susan Fisheries, comment by e- mail, 18 July 2014. PS: I am in field and therefore cannot sign,

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if this is a problem please advise and I can forward a signed letter on Monday when I am back in office. 262. RE: Proposed Eskom Transmission Power Susan Steyn, Department of Thank you for your comment. Lines from the Kappa Substation near Ceres Agriculture, Forestry and to the Omega Substation near Koeberg, Fisheries, comment by e- DEA Reference 14/12/16/3/3/2/352. The mail, 18 July 2014. Department of Agriculture Forestry and Fisheries (DAFF) would like to thank you for the opportunity to review and comment on the above application. 263. DAFF has studied the supporting documents Susan Steyn, Department of Comments noted. for the abovementioned and the following Agriculture, Forestry and points related to DAFF’s mandate include: Fisheries, comment by e- mail, 18 July 2014. According to the information provide: (1) the proposed transmission line will cross productive State Forest Land at Wolseley

(2) trees cannot exist under transmission lines therefore a total loss of 40 ha is implied with this application and a loss of 60 ha already happened due to the existing line

(3) the Cabinet agreed to the continuation of Forestry in Wolseley in 2008 which with an additional loss of 40 ha could become

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unviable

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

Yours faithfully, Susan Steyn Cape Pine Objections 264. Cape Pine own and operates Kluitjieskraal Jan Truter, Cape Pine, Comment noted. state forest. Need to determine impact on comment by reply form, 21 forestry with Department of Agriculture, March 2014. Forestry and Fisheries. Ivan Harris Objection 265. Objection towards power line. The previous Ivan Harris, Palmiet Valley & Thank you for your comment. We hereby acknowledge line was rejected in 2006. I belong to the Wellington Farmers your concerns and you have been registered you as an Conservancy. Property is part of it. Already Association, comment by interested and affected party. I further register your existing line. Do not need another line. reply form, 29 Jul 2014. opposition to the proposed Eskom 2nd 765kV transmission line through your area Douglas Henry Objection 266. My wife and I retired to Riebeek West on Douglas Henry, Resident Thank you for your comment. We hereby acknowledge Feb 1st 2013, and 1 of the main attractions Riebeeck West, comment by your concerns and you have been registered you as an is the view of the valley, towards the reply form, 02 July 2014. interested and affected party. I further register your mountains. Pyllons would severly impact on opposition to the proposed Eskom 2nd 765kV this view transmission line through your area Mainstream Renewable Power South Africa - Paardekraal East Wind Energy Facility (at Kappa Substation) Objections 267. Dear Shawn, Mike Mangnall, Mainstream Dear Mike, Attached please find our comments Renewable Power South Thank you for your comments. I will add it to the FEIR

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regarding Eskom’s proposed second 765kV Africa, comment by e-mailed comments and response report. powerline through the Kappa area, Western letter, 07 August 2014. Sincerely, Shawn Johnston Cape. Regards, Mike Mangnall. 268. Comment on the Draft EIR for Eskom’s Mike Mangnall, Mainstream Thank you for your comments. proposed 2nd 765kV powerline (Gamma to Renewable Power South Omega): Potential impact on Mainstream’s Africa, comment by e-mailed renewable energy projects. Thank you for letter, 07 August 2014. the opportunity to comment on the Draft EIR for the above-mentioned proposed project. 269. Further to our previous emailed Mike Mangnall, Mainstream Thank you for your comments. correspondence as well as our meeting of Renewable Power South 23 May 2014, based on the Google kmz file Africa, comment by e-mailed sent on 21 July 2014, it is evident that the letter, 07 August 2014. preferred route for the proposed powerline corridor aligns adjacent to the existing 765kV line – see light blue and green lines on attached map. We have therefore assumed that the previously indicated routes (Alt 1, 2 and 3 lines in attached map) are no longer EIA alternatives. 270. The preferred alignment routes through our Mike Mangnall, Mainstream Kentridge Makhanya: The current corridors are 2km Perdekraal East wind farm site, for which Renewable Power South wide. This is for the simple reason that it will allow us to we already have secured EIA and land use Africa, comment by e-mailed avoid planned developments, sensitive environmental planning approvals and intend bidding it letter, 07 August 2014. receptors, etc. In certain areas we might have to into the DoE’s REIPPPP. More-specifically it expand the size of the corridor as a mitigation measure. crosses Farm 245 (Lower Stinkfontein) on Eskom’s land acquisition team will engage with you

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which we have a legal land contract in place during servitude acquisition. with the landowner. In terms of this agreement, we have exclusive rights over the land and third party requests for development therefore first require our written consent. 271. Our main concern with the preferred Mike Mangnall, Mainstream Kentridge Makhanya: Comment noted. Response alignment is the potential negative impact Renewable Power South provided under point 275. that the additional servitude area would Africa, comment by e-mailed have on our Perdekraal East turbine layout. letter, 07 August 2014. Our layout is at an advanced stage of development and any land lost to accommodate the second 765kV line will result in a reduction in turbine numbers and wind farm capacity. However, if a compromise could be reached with Eskom regarding their turbine setback requirements from transmission lines then the impact could possibly be ameliorated. 272. It is therefore essential that Eskom urgently Mike Mangnall, Mainstream Kentridge Makhanya: The current corridors are 2km clarify their position in this regard. If no Renewable Power South wide. This is for the simple reason that it will allow us to compromise can be reached, then we will Africa, comment by e-mailed avoid planned developments, sensitive environmental have no choice but to take the necessary letter, 07 August 2014. receptors, etc. In certain areas we might have to steps to protect our assets if required in expand the size of the corridor as a mitigation measure. future. Eskom’s land acquisition team will engage with you during servitude acquisition. 273. The preferred alignment is unlikely to have Mike Mangnall, Mainstream Thank you for your comment. Eskom will be getting any impacts on the other properties we Renewable Power South back to you.

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currently are leasing around the Kappa Africa, comment by e-mailed substation, as indicated on the attached letter, 07 August 2014. map. 274. We look forward to hearing back from Mike Mangnall, Mainstream Thank you for your comment. Eskom in this regard. Please do not hesitate Renewable Power South to contact the undersigned should you have Africa, comment by e-mailed any queries. letter, 07 August 2014. Genesis Eco-Energy Paardekraal West Wind Energy Facility (at Kappa Substation) Objections 275. Hi Shawn, Please send me link to or Ralph Damonse, Head Dear Ralph, information re the EIA process for the Project Development 765kV Line you working on. We would like Genesis Eco-Energy, Thank you for the chat. Please note I have registered to register as an affected party on behalf of comment by e-mail, 29 July Genesis Eco-Energy as a I&AP on the Eskom Kappa- the Perdekraal West Wind Farm on Lower 2014. Omega EIA. Stinkfonterin & Rietpoort Farms near Kappa. Thanx I will send the CD with the Kappa-Omega DEIR to your Ralph Damonse post box. Find attached the link where you can access Head: Project Development the Genesis Eco-Energy (Pty) Ltd DEIR: http://www.nzumbululo.com

Find attached the kmz Google Earth file of the combined route, Gamma-Kappa and Kappa-Omega. Sincerely, Shawn Johnston 276. Paardekraal West wind energy facility on Ralph Damonse, Head Thank you for your comment, and it has been noted. Lower Stinkfontein and Rietpport Frams Project Development Ceres Karoo. We object against the 2nd Genesis Eco-Energy, 765kV line crossing the Paardekraal West comment by e-mail, 29 July wind farm. 2014. Department of Environmental Affairs and Development Planning Western Cape Comments

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277. The following comments are relevant, which Loretta Osborne, Thank you for your comment, and it has been noted. will form part of the Department’s final Department of response: Environmental Affairs and Development Planning 2.1. An integrated waste management Western Cape, Directorate approach must be used that is based on Land Management: Region waste minimisation and must incorporate 1, comment by e-mail, 22 avoidance, reduction, recycling, re-use and August 2014. disposal where appropriate. 278. 2.2 Any solid waste from the proposed Loretta Osborne, Thank you for your comment, and it has been noted. development must be disposed of at an Department of appropriately licensed waste disposal Environmental Affairs and facility. Development Planning Western Cape, Directorate Land Management: Region 1, comment by e-mail, 22 August 2014. 279. 2.3 No surface or groundwater must be Loretta Osborne, Thank you for your comment, and it has been noted. polluted due to any activity on the site. Department of Environmental Affairs and Development Planning Western Cape, Directorate Land Management: Region 1, comment by e-mail, 22 August 2014. 280. 2.4 Should any archaeological artefacts be Loretta Osborne, Thank you for your comment exposed during excavation, the Department of construction in the vicinity of the finding Environmental Affairs and

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must be stopped. Under no circumstances Development Planning shall any artefacts be destroyed. Such an Western Cape, Directorate archaeological site must be marked and Land Management: Region fenced off, and South African Heritage 1, comment by e-mail, 22 Resource Agency must be contacted within August 2014. 48 hours. 281. 2.5 Comments received during the Public Loretta Osborne, Thank you for your comment. Participation Process from the Interested Department of and Affected Parties and the relevant Environmental Affairs and authorities and a Comments and Response Development Planning Report that adequately addresses any Western Cape, Directorate highlighted issues must be included in the Land Management: Region final EIA Report. 1, comment by e-mail, 22 August 2014. 282. 2.6 Please ensure that all relevant Loretta Osborne, Thank you for your comment. As our EMP is generic, recommendations and mitigation measures Department of and specialists have adviced that a site specific EMP stipulated in the specialist reports are Environmental Affairs and (walk down) be done, wouldn’t it be advisable that included in the draft Environmental Development Planning those mitigation measures be included in that EMP as it Management Programme to be submitted Western Cape, Directorate will be usd by the ECO during monitoring of the site. with the final EIA Report. Land Management: Region 1, comment by e-mail, 22 August 2014. 283. 2.7 All original signed declarations are to be Loretta Osborne, Thank you for your comment. We will include them. included with the final EIA Report submitted Department of to the competent authority for decision- Environmental Affairs and making. Development Planning Western Cape, Directorate Land Management: Region

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1, comment by e-mail, 22 August 2014. 284. 2.8 The recommendations and mitigation Loretta Osborne, Thank you for your comment. measures stipulated in the specialist reports Department of must be implemented and complied with. Environmental Affairs and Development Planning Western Cape, Directorate Land Management: Region 1, comment by e-mail, 22 August 2014. 285. 2.9 The reports refers to sensitive Loretta Osborne, Thank you for your comment. We will be sure, to add vegetation, however Activity 12 of Department of this activity. Government Notice No. R. 546 was not Environmental Affairs and applied for. Development Planning Western Cape, Directorate Land Management: Region 1, comment by e-mail, 22 August 2014. 286. 2.10 Furthermore, the development also Loretta Osborne, Thank you for your comment. We will be sure, to add crosses water courses, but Activities 11 and Department of these activities. 18 of Government Notice No. R. 544 and Environmental Affairs and Activity 16 of Government Notice R. 546 Development Planning were not applied for. Western Cape, Directorate Land Management: Region 1, comment by e-mail, 22 August 2014. 287. 2.11 The reports refer to the proposed Loretta Osborne, Comment noted. Kappa Omega 2nd 765kV powerline Department of

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approximately 415km and substations Environmental Affairs and upgrade and the proposed Gamma Kappa Development Planning 2nd 765kV powerline approximately Western Cape, Directorate 370km and substations upgrade. The Land Management: Region lengths should rather be distinguished/ 1, comment by e-mail, 22 differentiated. August 2014. 288. 2.12 The route descriptions is also unclear. Loretta Osborne, Comment noted. Detailed route descriptions must be Department of provided. Environmental Affairs and Development Planning Western Cape, Directorate Land Management: Region 1, comment by e-mail, 22 August 2014. 289. 2.13 The reports also refer to only one Loretta Osborne, Thank you for your comment. rating matrix. No distinction between Department of impact ratings for individual routes were Environmental Affairs and considered. A comparative assessment of Development Planning the positive and negative implications of Western Cape, Directorate the proposed activity and identified Land Management: Region alternatives must be considered. 1, comment by e-mail, 22 August 2014. 290. 2.14 The Botanical assessment does not Loretta Osborne, Thank you for your comment. address the need for fire for management Department of of indigenous vegetation. Similarly, the EMP Environmental Affairs and only includes Fire Prevention and does not Development Planning include the managing of vegetation and fire Western Cape, Directorate during the operational phase. Land Management: Region

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1, comment by e-mail, 22 August 2014.

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ESKOM 2ND KAPPA-OMEGA 765KV TRANSMISSION LINE ENVIRONMENTAL IMPACT ASSESSMENT COMMENTS AND RESPONSES REPORT

Issue Raised by Response FEIR Objections Against 2nd Kappa-Omega 765kV Transmission Line

CapeNature Objections & Request for meeting with the Department of Environmental Affairs 1 Dear Shawn, Alana Duffell-Canham, Dear Alana, Scientist: land-use, CapeNature Our previous letters submitted with regard to Jonkershoek, comment by e- Thank you for your e-mail. I will once more enter the the above mentioned applications (both dated mail, 08 December 2014. CapeNature comments into the FSR and follow-up in regard to 11 July 2014) have reference. your meeting request. Sincerely, CapeNature is of the opinion that our comments Shawn Johnston on the Draft Environmental Impact Reports for the Gamma--‐ Kappa and Kappa--‐Omega 2nd It is hereby noted that CapeNature has requested a 765kV powerlines have not been adequately formal meeting with the National Department of addressed in the Final EIR. Environmnetal Affairs on concerns raised in the CapeNature submissions. Our previous comments thus remain applicable and we would like to request a meeting with the applicant and the competent authority to discuss our comments and concerns.

Kind regards, Alana Duffell-Canham City of Cape Town’s FEIR Objections 2 Dear Mr Johnston, Pat Titmus, Regional Manager: Dear Mr. Morne Theron, Environmental and Heritage Thank you of your e-mail and comments relating to the Final Attached please find the City of Cape Town Management – Northern Region EIR and the Draft EIR. I will process all of your comments

comment on the abovementioned final EIR, & Morné Theron Pr. Plan once more. including the City’s previous comment on the A/1965/2014 Senior Sincerely, draft EIR. Environmental Practitioner: Shawn Johnston Regards, Environmental and Heritage Morné Theron Pr. Plan A/1965/2014 Management Branch Shawn Johnston: Comment received and noted for response Senior Environmental Practitioner: Environmental Resource by the EAP, Nzumbululo Heritage Solutions and the Eskom Environmental and Heritage Management Branch Management Department environmental and technical teams. Environmental Resource Management (ERMD), City of Cape Town, Department (ERMD) comment by e-mailed letter, 08 Comments received included: December 2014. 1. DEIR City of Cape Town response, 11 August 2014 2. FEIR City of Cape Town response, 05 Decemeber 2014

It is hereby noted that the City of Cape Town has requested a formal meeting with the National Department of Environmnetal Affairs and Eskom. 3 Proposed Kappa-Omega 2nd 765kV Powerline Pat Titmus, Regional Manager: Comment noted, but our understanding is that any spatial and Substations Upgrade in Western Cape – Environmental and Heritage development framework and Environmental Management Final Environmental Impact Report. (NEAS ref: Management – Northern Region Framework should also consider provision of essential services DEA/EIA/0001266/2012) (DEA ref: & Morné Theron Pr. Plan such electricity supply. In addition powerline corridors can be 14/12/16/3/3/2/352) A/1965/2014 Senior negotiated through built up areas using road and street Environmental Practitioner: servitudes and where necessary low voltage powerline can be The abovementioned final Environmnetal Impact Environmental and Heritage re-routed or decommissioned to give space for high voltage Report (Draft EIR), received on 19 November Management Branch transmission lines. We suggest that you submit your maps and 2014 from Sustainable Futures ZA, refers. Environmental Resource lay out plans to the developer so that a compatible route can Management Department be mapped. Also note that alternative 1 is not the preffered Be advised that the City of Cape Town technical (ERMD), City of Cape Town, alternative in terms of municipally boundaries, or comment is limited to the 2nd Kappa-Omega comment by e-mailed letter, 08 developments. Other than your concerns there are a lot more 765kV line only as it traverses the City’s December 2014. other factors that come into play. After all the proposed municipal jusridiction. powerline is meant to stabilize power supply to Cape Town.

Having reviewed the final EIR, and in particular the EAPs reply to the City of Cape Town

comment raised during the draft EIR, the City is of the opinion that its comment has not been adequately addressed (for your convenience a copy of the said comment, dd 11 August 2014, is attached herewith).

In light of the above the said comment remains unchanged. It is this office position that it would serve no further purpose to re-iterate the detailed comment already provided during this fial EIR process.

What is most important to bring to the Competent Authority’s attention is that the City does not concur with the EAPs prefered alternative (i.e. Alternative 1).

Development proposals (includig utility infrastructure) are assessed against the approved City of Cape Town Spatial Development Framework (CTSDF, 2012)1, as well as the Blaauwberg and Northern District Plans (EMF, 2012)2. Once Alternative 1 traverses the City’s municipal jurisdiction it does not run alongside any existing 400kV powerline routes as is incorrectly claimed by the EAP. As such the creation of a new power line corridor through Koeberg Cultural Landscape is inconsistent with the CTSDF and the relevant district plans.

It is re-iterated that the previosly approved 1st

765kV power line is compatible with the above spatial development framework and district plans. As such the alignment of the 2nd 765kV power line adjacent to the 1st 765kv power line once it traverse through the City of Cape Town’s jurisdiction would be consistent with the approved CFSDF and EMF.

1 The City of Cape town: Spatial Development Framework was approved by the Minister of Local Government, Environmental Affairs and Development Planning , Anton Bredell on 8 May 2012 ( Province of the Western Cape, Provincial Gazette, 6994, dd 18 May 2012) in terms of section 4(6) of the Land Use Planning Ordinance, Ord. 15 of 1985 and by the Council of the City of Cape Town on 28 May 2012 as a component of the Integrated Development Plan (IDP), in terms of section 34 of the Municipal Systems Act, Act 32 of 2000.

2 The Blaauwberg District Plan and Environmental Management Framework was approved as a Structure Plan in terms of section 4 (10) of the Land Use Planning Ordinance, Ord. 15 of 1985 on 27 September 2012. Elandsberg Farms Stewardship Programme FEIR Objections 4 Dear Sir/Madam, Richard Summers and Clarice Dear Clarice Arendse,

Arendse, smith • ndlovu • We act for Elandsberg Farms (Pty) Ltd and summers attorneys, comment Thank you for your e-mail and comments submitted on behalf Rapula Farming (Pty) Ltd. by e-mailed letter, 08 of Elandsberg Farms (PTY) Ltd and Rapula Farming (PTY) Ltd. December 2014. I hereby acknowledge your e-mail and attached 2. Please find attached hereto copies of the correspondence. following: 2.1. Our client’s comments on the Final Sincerely, Environmental Impact Assessment Report; Shawn Johnston 2.2. Annexure A; and 2.3. Annexure B. 3. Kindly acknowledge receipt hereof.

Kind regards, Clarice Arendse LLB LLM (Environmental Law) smith • ndlovu • summers attorneys 5 Dear Sir/Madam Richard Summers and Clarice Acknowledged. Please understand that, in most of our Arendse, smith • ndlovu • comments we repeatedly explained to Richard Summers, that 8 December 2014 summers attorneys, comment to suggest that the EIA process is fundamentally flawed is a Our ref: RWS/cr/P17-002 by e-mailed letter, 08 insult to the entire team. The entire team is qualified and Your ref: HESSA REF NO: December 2014. highly experienced to handle impact assessment for a 2012_JHB.HESSA_ENV.PRO_0006 powerline project. RE: PROPOSED KAPPA OMEGA 2ND 765kV POWER LINE – COMMENTS ON THE FINAL We further explained that, it is not a platform to insul t and ENVIRONMENTAL IMPACT ASSESSMENT REPORT undermine each other’s opinion and integrity. Over use of DATED NOVEMBER 2014 absolute comments such as ‘failure’ is in itself failure to DEA REF: 14/12/16/3/3/2/352 respect effort, qualifications and experience of dedicated specialists. 1. We act for Elandsberg Farms (Pty) Ltd and Rapula Farming (Pty) Ltd. Your comments are expected to aid the process not to undermine and distort the process. The process is not a 2. This letter contains comments, on behalf of platform to trade insults. We respect your professional our clients, on the Final Environmental Impact credibility and differences in opinion should not warrant such

Report (referred to as the “FEIR” in this absolute rejection of the entire team’s work. See our previous document) dated November 2014 prepared by comments. Nzumbululo Sustainable, Energy and Environmental Solutions for the proposed Kappa Omega 2nd 765kV power line.

3. Elandsberg Farms (Pty) Ltd and Rapula Farming (Pty) Ltd are the registered owners of the landholdings comprising Elandsberg Farms1 and Elandsberg Farms (Pty) Ltd is the registered owner of the landholdings comprising the Elandsberg Nature Reserve2 (located near Hermon and in the vicinity of the preferred alternative route (Alternative Route 1) for the proposed power line).

4. The purpose of this letter is to formally communicate the concern that none of our clients’ concerns with the environmental impact assessment (“EIA”) process have been addressed. In connection with the draft environmental impact report (“DEIR”), we aised several concerns which were motivated in detail in our letter of comments dated 11 August 2014 (a copy of which is attached for ease of reference marked A).

5. In November 2014, the FEIR was released for public comment. It is apparent from the FEIR that the Environmental Assessment Practitioner (“EAP”) has doggedly persisted with the nature and scope of studies undertaken to date and has

made no meaningful attempt to engage with issues raised by members of the public.

6. Issues raised in connection with the DEIR have been ‘addressed’ in the Comments and Response Report prepared by the EAP and released with the FEIR in November 2014. At best, the issues raised have been ‘addressed’ in the most superficial manner. It cannot be said that the EAP has responded in a meaningful manner to issues raised as legitimate concerns in the EIA process. The concerns raised do not appear to have resulted in the concerns being addressed through evaluation, consideration or assessment. Rather the concerns raised, have been dismissed by the EAP, in a highly unprofessional manner.

7. We do not feel that it will be constructive (in this set of submissions) to engage with the highly inappropriate manner in which the EAP has responded to several of the issues raised.3 In order to ensure that our clients exercise their rights and participate throughout the public participation process, we have set out several comments in connection with biodiversity and heritage related impacts. The purpose of this letter is therefore not to repeat all the concerns raised in connection with the DEIR. As those issues have not been addressed satisfactorily, the concerns raised in our letter of 11 August 2014 should be read together with this letter. To

the extent that the EAP’s approach in responding to issues raised with the DEIR evidences non- compliance with Regulation 17 of the EIA Regulations4, a separate submission will be made to the Department of Environmental Affairs (“DEA”) regarding evidence of non- compliance with the EIA Regulations.

8. We reiterate that none of our clients’ concerns have been addressed through substantive evaluation and assessment or with reference to accepted EIA methodology and practice. The fact that our clients have not elected to reiterate the concerns (all of which were substantiated in detail in our letter dated 11 August 2014) should not be seen as a concession that the issues have been dealt with satisfactorily. 6 Process Richard Summers and Clarice We are to post Authorisation because thus where further 9. Concerns with the manner in which impact Arendse, smith • ndlovu • studies will be done. assessment has effectively been deferred to the summers attorneys, comment post-authorisation stage formed a key by e-mailed letter, 08 component of the comments we submitted in December 2014. connection with the DEIR. 7 10. The EAP continues to rely on the post- Richard Summers and Clarice Point of correction, site specific impacts will be conducted approval process as a basis for assessing some Arendse, smith • ndlovu • upon approval from DEA, when the specialists conduct their of the site specific impacts occasioned by this summers attorneys, comment walk down project. We reiterate our opinion that the by e-mailed letter, 08 process is unlawful and the failure to assess December 2014. impacts now constitutes a fatal procedural flaw in the undertaking of the EIA. 8 11. Several other process-related flaws continue Richard Summers and Clarice We disagree with Summers et al on this matter; several

to undermine the efficacy of the EIA process. Arendse, smith • ndlovu • heritage foundations registered with Heritage were consulted. These include the following: summers attorneys, comment In addition all interested and affected parties were afforded 11.1. There is no evidence that Heritage by e-mailed letter, 08 the opportunity to engage with the Environmental Western Cape (“HWC”) has commented on or December 2014. authorisation process through our independent public endorsed the heritage impact and as reported on participation specialist. Some of the heritage foundations’ in the DEIR. In the absence of the formal inputs are included in this very list (see attached list). endorsement by HWC of the heritage studies We also disagree with item 11.3, in the best our knowledge we undertaken to date, it is submitted that the sent responses and issues to our specialist and also attended release of the FEIR for public comment was meetings with them. In addition we interacted with our premature. specialists and the public through our website 11.2. There is no evidence that heritage (www.nzumbululo.com) and multimedia communication conservation bodies registered with HWC have means. It is also the responsibility of our Principal Investigator commented on either the DEIR or the heritage to deal with responses and issues, where necessary as in the impact assessment (“HIA”). case of Ms S. Titlestad, the relevant specialist would be 11.3. One of the authors for the Built requested to respond via the EAP and to the Principal Environment, Spatial History and Cultural Investigator. We appreciate that there are various ways of Landscape specialist report5 (Ms S Titlestad) coordinating impact studies by a team of specialists and ours stated in a public forum (before the Impact was best suitable for our circumstances. Please note that Assessment Committee of HWC) that the public participation process which Summers et al are authors of the Built Environment Report had not responding to continued concurrently with Ms S. Titlestad‘s had any input into the response to heritage- site inspection. If any issues arose during that time, the door related issues contained in the Comments and was very open and hence your issues and responses. Response Report. 11.4. Ms S Titlestad further undertook a site inspection of the Elandsberg Nature Reserve after the FEIR was released for public comment. If that site visit results in the production of a final Built Environment Report, when will I&APs be afforded an opportunity to comment on that report? 9 BIODIVERSITY Richard Summers and Clarice All available and regionally known faunal and floral reference 12. The FEIR states the following: Arendse, smith • ndlovu • databases were considered or assessed in order to assure that

“However, with adequate planning of the summers attorneys, comment the assessments take as many of the potential species as well corridor in order to avoid areas of increased by e-mailed letter, 08 as important habitats into consideration as possible given the sensitivity, impact on floral habitat can be December 2014. extent of the various alternatives. significantly reduced.” However, consideration should be given to extreme extent each of the proposed alternatives cover that resulted in the likelihood of all documented species as well as a vast variety of different habitats being present along portions of the routes. It should also be noted that the study was aimed at assessing 2km wide corridor alternatives and as such detailed assessments are not practicable at this stage of the investigations. The assessment approach was aimed at identification and prioritisation of portions along the various alternatives that are considered most likely to be able to sustain the most diverse and sensitive faunal and floral populations and where more care would be required in the planning, construction and operational phases of the project. It has been made clear in the reports developed that as part of the planning phase of the development a walk down be undertaken of all areas considered of higher ecological importance identified within the baseline report for the selected route within the selected corridor. By so doing areas of least concern can be identified for the construction of support structures. It should further be noted that where portions of routes were identified that where considered ‘no go’ areas, it has been highlighted in the report and where possible alternative alignment has been proposed or recommended.

specialists that alternative route alignment be considered around these areas and that CBAs be avoided as far as possible regardless of what faunal or floral species are found within them. By so doing the sitespecific impacts associated with these areas will most likely be avoided. Site specific mitigation measures can then be developed for areas where re-alignment is not an option, however this would require detailed site assessments of all these areas; possibly as a ‘second phase’ assessment that can inform the EIA prior to final submission or prior to finalisation of the EMP for the project. This will allow for the further development of sitespecific construction and operational mitigation measures.

10 13. This has clearly not happened in the case of Richard Summers and Clarice All available and regionally known faunal and floral reference Alternative Route 1 (which impacts significantly Arendse, smith • ndlovu • databases were considered or assessed in order to assure that on Elandsberg) and thus one must assume that summers attorneys, comment the assessments take as many of the potential species as well the botanical impacts will not be significantly by e-mailed letter, 08 as important habitats into consideration as possible given the reduced, in which case the impact will be high- December 2014. extent of the various alternatives. negative, instead of medium – low. The EAP is However, consideration should be given to extreme extent making the very significant, yet incorrect each of the proposed alternatives cover that resulted in the assumption, that adequate planning of the likelihood of all documented species as well as a vast variety corridor has taken place and that key sensitive of different habitats being present along portions of the areas have thus been avoided. routes. It should also be noted that the study was aimed at assessing 2km wide corridor alternatives and as such detailed assessments are not practicable at

this stage of the investigations. The assessment approach was aimed at identification and prioritisation of portions along the various alternatives that are considered most likely to be able to sustain the most diverse and sensitive faunal and floral populations and where more care would be required in the planning, construction and operational phases of the project. It has been made clear in the reports developed that as part of the planning phase of the development a walk down be undertaken of all areas considered of higher ecological importance identified within the baseline report for the selected route within the selected corridor. By so doing areas of least concern can be identified for the construction of support structures. It should further be noted that where portions of routes were identified that where considered ‘no go’ areas, it has been highlighted in the report and where possible alternative alignment has been proposed or recommended.

The client has been provided with the GIS files indicating areas considered to be of very high and high sensitivity identified using all desktop information available with special mention of fine scale plans as well as site visits. It is the opinion of the specialists that alternative route alignment be considered around these areas and that CBAs be avoided as far as possible regardless of what faunal or floral species are found within them. By so doing the sitespecific impacts associated with these areas will most likely be avoided. Site specific mitigation measures can then be developed for areas where re-alignment is not an option, however this would require detailed site assessments of all these areas; possibly as a ‘second phase’ assessment that can inform the EIA prior to final submission or prior to finalisation

of the EMP for the project. This will allow for the further development of sitespecific construction and operational mitigation measures.

11 14. In relation to recommendations, the FEIR Richard Summers and Clarice The costruction of the 1st 765KV is still being constructucted states the following: Arendse, smith • ndlovu • “The proposed transmission powerline, and summers attorneys, comment associated upgrade for the substations will take by e-mailed letter, 08 place in an area, which was previously disturbed December 2014. by other developments activities such as construction of the powerlines, substations, access roads, boundary fence line and farms. No major or radical natural or human environmental impacts are anticipated during the construction and operational phases of the project given the fact that similar for example the 1st 765 kV powerline and other developments already exist in the general project area.”6 12 15. Not only is this statement factually Richard Summers and Clarice Acknowledged, note that whether it is acknowledged in the inaccurate, it is grossly misleading. There is no Arendse, smith • ndlovu • report, the fact remains that the nature reserve is protected acknowledgment in the FEIR that the Elandsberg summers attorneys, comment and will be treated as such during construction. Our studies Nature Reserve is a Protected Area, declared in by e-mailed letter, 08 covered wider aspects other than Elandsberg Nature Reserve. terms of the National Environmental December 2014. Management: Protected Areas Act 57 of 2003. 13 16. There is no specific section contained in the Richard Summers and Clarice Acknowledged. The question of the structure of the report and

FEIR which outlines the required mitigation. Arendse, smith • ndlovu • methodology depend on individual approaches. Our report Most of the mitigation suggestions seem to be summers attorneys, comment covered essential aspects of the Environmental Impact included in the Impact Statement section, but by e-mailed letter, 08 assessment outline in the EIA regulations dated 4th of only a few of the biodiversity related measures December 2014. December 2014. Environmental Impacts of power lines are are contained therein. These issues should be assessed and quantified inside the EIR report. In most addressed explicitly and clearly and the EAP instances mitigation measures are also recommended. should not be allowed to cover up the Detailed mitigation measures will be provided inside the site inadequacies of the FEIR by saying that “all specific EMP. mitigation measures as recommended by specialists should be applied”.7 14 17. The following is an example of a nonsensical Richard Summers and Clarice Please note that specialist studies were included in the report. statement in the FEIR which undermines the Arendse, smith • ndlovu • If you needed a more detailed explanation, we indicated that importance of the EIA process: “Dominant summers attorneys, comment I&Aps go over the specialist reports, which gave more detail of vegetation types related to vegetation in the by e-mailed letter, 08 the assessment and you can access our website at context of this development are protected December 2014. www.nzumbululo.com or call our office lines detailed in the areas.”8 This statement is meaningless and report. evidences a lack of understanding of biological concerns. Again, we strongly do not appreciate the insults and inappropriate use of words used by Richard Summers and Clarice Arendse.

15 18. The section on potential environmental Richard Summers and Clarice All potential impacts are listed in the report in accordance with impacts 9 does not list what these impacts are, Arendse, smith • ndlovu • NEMA regulations. and fails to mention terrestrial faunal impacts. summers attorneys, comment by e-mailed letter, 08 December 2014. 16 19. The following statement is taken straight Richard Summers and Clarice Indeed, it is anticipated that as far as possible the contractors from the Terrestrial Ecology Report: Arendse, smith • ndlovu • will utilize existing infrastructure including access roads. We “As far as possible existing roads should be summers attorneys, comment have confidence in the team’s specialist opinions. utilised for access roads; where the need is by e-mailed letter, 08 identified for the development of temporary December 2014.

tracks cognisance should be taken of the following: · Design tracks to cross open veld at 90 degree angles to avoid as much natural vegetation as possible...”10 17 20. The proposal to design tracks to cross open Richard Summers and Clarice Impact studies are not academic endeavours but rather veld at 90 degree angles is nonsensical and Arendse, smith • ndlovu • applied studies. The study was not designed to test particular completely unfeasible for Eskom. Without summers attorneys, comment contentions but rather to assess the potential impact of the detailed knowledge of access roads and new by e-mailed letter, 08 proposed development. tracks it is impossible to assess the botanical December 2014. impact of this aspect of the project. Once again, we note that Summers, et. al. opted to completely disregard, either deliberately or by design, all the methods, principle, results and recommendations provided into the study. Ironically, we observe that Summers, et. al. comments use the same emotive language on other independent specialist report comments. The object and objectivity of the comments become questionable if all comments only seek to denigrate the studies conducted. At most, Summers, et. al. comments does not help us to improve the process being undertaken 18 21. With regard to recommendations – on page Richard Summers and Clarice Acknowledged, sensitive habitats should be avoided. 187 of the FEIR – the following is stated: “9. Arendse, smith • ndlovu • Avoid sensitive habitats, as defined in the summers attorneys, comment sensitivity assessment, when planning the by e-mailed letter, 08 power line route; December 2014. 10. Avoid populations of species of special concern, when planning power line route” 19 22. This is a good example of generic Richard Summers and Clarice The specific EMP will have to look at specific areas which need statements made by the EAP and is at best an Arendse, smith • ndlovu • more attention that is if alternative 1 is authorised by the attempt at “greenwashing”. Although it is summers attorneys, comment Department or the specific section will have to be diverted. comforting for the authorities to see in the FEIR, by e-mailed letter, 08

it is actually meaningless in terms of real December 2014. mitigation measures for a specific project. If these two recommendations had been applied, it would be impossible to route the line along Alternative Route 1 via Elandsberg, as the entire area is a sensitive habitat, and supports numerous species of conservational concern. Given that the planning stage has already been undertaken, it is not clear at what stage sensitive habitats and species of conservational concern are to be avoided. The walk-down stage is too late in the process, as the lines cannot be laterally shifted and all that can be done is to adjust the pylon position longitudinally along the pre-approved route corridor. The planning approach has circumscribed the efficacy of the EIA process by limiting the critical role that impact avoidance plays in the mitigation hierarchy. In fact, the planning approach adopted with regard to this project means that the two recommendations quoted above will not be implemented if the preferred route alternative is via Elandsberg. 20 23. Identification of the important mitigation Richard Summers and Clarice Environmental Impacts of power lines are assessed and measures seems to have been made the Arendse, smith • ndlovu • quantified inside the EIR report. In most instances mitigation responsibility of someone (presumably whoever summers attorneys, comment measures are also recommended. Detailed mitigation compiles the environmental management by e-mailed letter, 08 measures will be provided inside the site specific EMP. programme (“EMP”) at some future point in time December 2014. (post-authorisation) and based on an undetermined methodology. This approach is not Site specific mitigation measures can be developed for areas consistent with EIA best practise. Legally, based where re-alignment is not an option, however this would

on a proper consideration of the National require detailed site assessments of all these areas; possibly Environmental Management Act 107 of 1998 as a ‘second phase’ assessment that can inform the Eskom (“NEMA”) and the EIA Regulations, the EIA prior to constructionor or prior to finalisation of the EMP for process (and the environmental impact reports the project. This will allow for the further development of site in particular) are supposed to include and collate specific construction and operational mitigation measures all necessary information that must be incorporated into the EMP. This has not been the case here. 21 24. The methodology of the Terrestrial Ecology Richard Summers and Clarice We acknowledge your contribution and we believe that our Report is inconsistent. If the consultants had Arendse, smith • ndlovu • specialists fulfilled the requirements of section 31 (2) (1) of flagged Elandsberg as an area of “exceptional summers attorneys, comment the EIA process. South Africa has probably the highest number significance” (which they should have done, by e-mailed letter, 08 of powerline networks in Africa thus our specialist have vast according to their own criteria) then they would December 2014. experience in powerline developments. Generally powerline not have been able to recommend Alternative development impacts have been well documented and Route 1 as a preferred route. releatively easy to predict as well as to mitigate. 22 25. The EAP reflects a poor understanding of the Richard Summers and Clarice Once again, to suggest that the EAP process has a poor EIA process. The report which has been Arendse, smith • ndlovu • understanding is an insult to the entire team. The entire team submitted to the DEA is the FEIR. This is the summers attorneys, comment is qualified and highly experienced to handle impact final opportunity for impact assessment and by e-mailed letter, 08 assessment for a powerline project. While we appreciateyour public participation in the EIA process. It is not December 2014. comments, and ensure that they are adhered to, we don’t clear what the EAP is suggesting by way of site appreciate any insults. specific mitigation measures that “can be developed” in the future for certain areas. It is Powerline development is not unique, powerlines have been also not clear what is being contemplated by the built all over and generic impacts of powerline development reference to “detailed site assessments” or “a are well documented. Environmental Impact studies remember ‘second phase’ assessment that can inform the are not academic endeavours. The selection of routes is EIA prior to final submission or prior to determined by Eskom‘s strategic planning and demand. We finalisation of the EMP.” The EAP ignores the fact that there is no opportunity for further are confident that our specialists are capable and they fulfilled assessment at some undetermined future stage. their requirements of the relevant legislation that govern their The whole purpose of an EIA is to evaluate, work. assess and consider project-related impacts

before a project is authorised. 23 26. The EAP has failed completely to respond to Richard Summers and Clarice All available and regionally known faunal and floral reference the concerns raised regarding how the Arendse, smith • ndlovu • databases were considered or assessed in order to assure that biodiversity impact on the Elandsberg Nature summers attorneys, comment the assessments take as many of the potential species as well Reserve has been quantified or assessed. It is by e-mailed letter, 08 as important habitats into consideration as possible given the plainly apparent that this impact has not been December 2014. extent of the various alternatives. assessed in the manner required by NEMA. On However, consideration should be given to extreme extent this basis the FEIR should be rejected by DEA. each of the proposed alternatives cover that resulted in the likelihood of all documented species as well as a vast variety of different habitats being present along portions of the routes. It should also be noted that the study was aimed at assessing 2km wide corridor alternatives and as such detailed assessments are not practicable at this stage of the investigations. The assessment approach was aimed at identification and prioritisation of portions along the various alternatives that are considered most likely to be able to sustain the most diverse and sensitive faunal and floral populations and where more care would be required in the planning, construction and operational phases of the project. It has been made clear in the reports developed that as part of the planning phase of the development a walk down be undertaken of all areas considered of higher ecological importance identified within the baseline report for the selected route within the selected corridor. By so doing areas of least concern can be identified for the construction of support structures. It should further be noted that where portions of routes were identified that where considered ‘no go’ areas, it has been highlighted in the report and where possible alternative alignment has been proposed or recommended.

The client has been provided with the GIS files indicating areas

considered to be of very high and high sensitivity identified using all desktop information available with special mention of fine scale plans as well as site visits. It is the opinion of the specialists that alternative route alignment be considered around these areas and that CBAs be avoided as far as possible regardless of what faunal or floral species are found within them. By so doing the sitespecific impacts associated with these areas will most likely be avoided. Site specific mitigation measures can then be developed for areas where re-alignment is not an option, however this would require detailed site assessments of all these areas; possibly as a ‘second phase’ assessment that can inform the EIA prior to final submission or prior to finalisation of the EMP for the project. This will allow for the further development of sitespecific construction and operational mitigation measures.

24 7. The Terrestrial Ecology Report states the Richard Summers and Clarice Very true all routes areas which can not be mittigated and are following: Arendse, smith • ndlovu • very sensitive will need to be re routed. “Development of a transmission line within or summers attorneys, comment near a nature reserve can result not only in by e-mailed letter, 08 direct impact on vegetation due to clearing, but December 2014. can also decrease the ‘sense of place’ of the area, consequently resulting in loss of ecotourism on which the nature reserves depend. It is therefore strongly recommended

that the options that would pass through nature reserves or in close proximity to nature reserves, if chosen, be re-routed to more disturbed areas inland of where the options are presently proposed.”11 25 28. This finding and recommendation in the Richard Summers and Clarice Route 1 is not yet approved but it is preferred and I strongly Terrestrial Ecology Report clearly ignores the Arendse, smith • ndlovu • believe thet the the powerline will not take the whole 3192 ha fact that the Elandsberg Nature Reserve summers attorneys, comment in size (approximately 3192ha in size) is a legally by e-mailed letter, 08 protected nature reserve in terms of the December 2014. National Environmental Management: Protected Areas Act 57 of 2003. Information regarding this protected status is freely available. The Elandsberg Nature Reserve should have been identified as an area through which the proposed power lines should not traverse, and Alternative Route 1 should accordingly not have been approved. 26 29. The Terrestrial Ecology Report further failed Richard Summers and Clarice The specilaist is free to use any reference they wish to use, to mention the key reference to lowland Arendse, smith • ndlovu • they are not titled to use one which is widely known.it depends conservation priorities – the so called Jarman summers attorneys, comment on the specialist descretion Report (Jarman 1986, Conservation Priorities in by e-mailed letter, 08 Lowland Regions of the Fynbos Biome, South December 2014. African National Scientific Programmes Report 87, the Counsel for Scientific and Industrial Research, Pretoria). The Jarman report ranks Elandsberg (which it even then recognised as conserved) as the second most important site in the entire West Coast Renosterveld Region.12 27 30. In addition, the Terrestrial Ecology Report Richard Summers and Clarice Comment noted, we acknowledge the specialists ‘s opinion in states: Arendse, smith • ndlovu • this matter.

“During the field assessment isolated summers attorneys, comment Renosterveld and woody alien vegetation stands by e-mailed letter, 08 were encountered where vegetation has been December 2014. cleared in servitudes as mitigation to possible fire damage. These were considered isolated instances and therefore clearing of vegetation within servitudes was not taken into consideration during the impact assessment.”13 28 31. Whether this critically sensitive vegetation Richard Summers and Clarice Acknowledged. We stand by our specialist opinion because it is type (renosterveld) is isolated or not, the fact is Arendse, smith • ndlovu • an objective assessment of the situation on the ground. Also that vegetation clearing has been undertaken in summers attorneys, comment note that site specific impacts and mitigation measures and various parts of the existing servitude, and by e-mailed letter, 08 will still be dealt with in detail after authorisation. If the would thus be likely to occur in parts of the new December 2014. project gets authorised. servitude. The failure to assess the impact of this is a significant omission, especially in light of the following statement contained in the same paragraph: “However, it should be noted that vegetation clearing and subsequent change of the natural fire regimes within the servitudes will result in transformation of vegetation communities and would result in a much higher impact rating than what was calculated in the impact assessment below.”14 29 32. The Terrestrial Ecology Report continues by Richard Summers and Clarice Acknowledged. Please note that specialists recommend the stating: Arendse, smith • ndlovu • best options for minimising damages to the environment. They “All SCC (Species of Conservational Concern) summers attorneys, comment could be several ways of dealing with the challenge but and plants considered to be of medicinal value by e-mailed letter, 08 certainly one has to weigh options and the decision is informed should be marked during the walk down of the December 2014. by experience and expertise. This is not the first powerline preferred corridor, prior to commencement of Eskom is proposing to build. construction activities. Marking of SCC should be undertaken by a suitably qualified and appropriately experienced Botanist;

· Relevant permits should be obtained for rescue and relocation of any SCC identified; · All SCC individuals encountered during the walk down or construction phase of the development should be rescued and relocated to the nearest similar habitat to that from which it was taken, by a suitably qualified specialist”.15 30 33. Rescue and relocation is not supported by Richard Summers and Clarice Acknowledged. In our view rescue and relocation is deemed as CapeNature as an acceptable mitigation measure Arendse, smith • ndlovu • the most feasible option given that it is not only terrestrial for many species for various reasons, including summers attorneys, comment issues that are considered for final recommendations. All the low likelihood of success for many taxa, the by e-mailed letter, 08 specialists inputs are weighed equally. Please note that should need to conserve habitat rather than just December 2014. balance the benefits of the projects with protection of the species, and importantly because translocating environment for sustainable development. While we species involves disturbance of the receiving acknowledged CapeNature’s opinion we strongly support the site. Unless a similar, but previously disturbed, Rescue and relocation method as the best suitable method for receiving site can be located (which is in need of our circumstances. rehabilitation) then translocating specimens may in fact increase overall disturbance. 31 34. The recommendation that species of Richard Summers and Clarice Acknowledged. As indicated above, rescue and relocation has conservational concern encountered during the Arendse, smith • ndlovu • been carefully selected as the most feasible option given that walk-down should be rescued and relocated is summers attorneys, comment all specialist inputs were equally considered. The Terrestrial simply not feasible or advisable. As many as by e-mailed letter, 08 and Ecology study should not be treated in isolation. It is part 40% of the species of conservational concern en December 2014. and parcel of the whole package of specialist studies that route will be shrubs with very low translocation should zero on one alternative route for approval by DEA. In potential. Accordingly, rescue and relocation our view the entire report cannot rejected on the basis of a cannot be used as a mitigation measure for loss very small section of the route. of species of conservational concern. It is submitted that there will be loss of species of conservational concern in footprint areas, and also in the road access areas. This appears to have been completely ignored in the Terrestrial Ecology Report.

32 35. Eskom has not provided information to Richard Summers and Clarice Acknowledged. Please note that the proposed line is proposed specialists on where the road access points will Arendse, smith • ndlovu • in developed areas with farm roads, rural and existing regional be. Road access can often have a bigger summers attorneys, comment road infrastructure which will be utilized during construction. botanical impact than the actual pylon by e-mailed letter, 08 Also note that in the majority of cases the proposed powerline footprints, as the cumulative road footprint in December 2014. route runs along 1st 765kv and 400kv poweline with existing any one section is much greater than the pylon access road. Based on our experience, contractors often use footprint. The inability to assess the botanical existing structures for their camp sites. In addition as impact of road access is accordingly a significant indicated earlier on site specific impacts will be considered shortcoming. after the final route selection is concluded. The selected route will be subjected to walk down surveys which will deal with site specific impacts including tower to tower impacts. Please note that construction phase management plan will also take into consideration site specific impacts, there after an operational phase management plan will consider the impacts of the proposed powerline after construction including impacts of routine mantainace work and repairs. 33 36. The Terrestrial Ecology Report provides that: Richard Summers and Clarice Acknowledged. Note that this recommendation is tentative; it “Care should be taken if chemical methods Arendse, smith • ndlovu • will depend on which method the contactors will use for (herbicides) are to be utilised for both summers attorneys, comment vegetation clearance. Your suggestion will be incorporated in vegetation clearing prior to construction as well by e-mailed letter, 08 the final EMP as alien vegetation removal post construction. December 2014. Spill or indiscriminate use of herbicides could result in the loss of indigenous floral individuals or habitat;”16 34 37. It is submitted that herbicides should not be Richard Summers and Clarice Comment noted. Your input will be included in the final used at all, nor should they be necessary Arendse, smith • ndlovu • management plan (EMP) anywhere in the study area. In particular, summers attorneys, comment herbicides should not be used in any medium, by e-mailed letter, 08 high or very high sensitivity areas, as collateral December 2014. damage and loss of potential species of conservational concern is very high with herbicide usage. If any herbicide are to be used,

they should be hand painted on cut stems of species that re-sprout, and should not be permitted to be sprayed. 35 38. The Terrestrial Ecology Report recommends Richard Summers and Clarice It should be noted that the assessment was based on a worst that “all areas surrounding construction activity Arendse, smith • ndlovu • case scenario and are therefore considered indicative of the footprints should be kept off-limits to summers attorneys, comment significance of impact that could result due to vegetation construction vehicles and personnel.”17 This by e-mailed letter, 08 clearing and construction related activities within each mitigation measure lacks specificity and is December 2014. sensitivity class. accordingly impossible to enforce. It is unclear It has been made clear in the reports what areas constitute the construction activity developed that as part of the planning phase of the footprints. This mitigation measure should have development a walk down be undertaken of all areas provided, for example, that approved considered of higher ecological importance identified development footprints be demarcated prior to construction. within the baseline 2report for the selected route within the selected corridor. By so doing areas of least concern can be identified for the construction of support structures.

It should further be noted that where portions of routes were identified that where considered ‘no go’ areas, it has been highlighted in the report and where possible alternative alignment has been proposed or

recommended.

36 39. In respect of specific eradication for alien Richard Summers and Clarice Comment noted. Your suggestions will be included in the and weed species, the report recommends: Arendse, smith • ndlovu • construction Environmental Management Plan (EMP) · “Care should be taken with the choice of summers attorneys, comment herbicide to ensure that no additional impact by e-mailed letter, 08 and loss of indigenous plant species occurs due December 2014.

to the herbicide used; · Footprint areas should be kept as small as possible when removing alien plant species; and · No vehicles should be allowed to indiscriminately drive through open veld during the eradication of alien and weed species.”18 37 40. As noted above, no herbicide should be Richard Summers and Clarice Your inputs are appreciated and will be included in the final permitted in medium, high or very high Arendse, smith • ndlovu • EMP as noted above. sensitivity areas, not even for alien vegetation summers attorneys, comment control, except where the alien invasive by e-mailed letter, 08 vegetation requires herbicide to prevent re- December 2014. sprouting from cut stems. In this specific case, it would be recommended that herbicide be hand painted (as opposed to being sprayed) onto cut stems within 5 minutes of felling, and that the herbicide be mixed with a suitable dye so that treated stems are easily identifiable. 38 41. The Terrestrial Ecology Report stipulates Richard Summers and Clarice Comment noted. Your contribution will be implemented that: Arendse, smith • ndlovu • particularly in the EMP.. “All soils compacted as a result of construction summers attorneys, comment activities falling outside of the servitude and by e-mailed letter, 08 construction footprint areas should be ripped December 2014. and profiled. Special attention should be paid to alien and invasive control within these areas”.19 39 42. This statement is incorrect. No ripping or Richard Summers and Clarice Comment noted however our recommendation was based on profiling should take place in any areas of Arendse, smith • ndlovu • the worst case of compaction where ripping might be natural vegetation, particularly not in any areas summers attorneys, comment appropriate as part of the rehabilitation process. of medium, high or very high sensitivity, as it by e-mailed letter, 08 will significantly increase the disturbance levels December 2014. and alien invasion potential. 40 43. No mention is made in the Terrestrial Richard Summers and Clarice Please note that specialist studies are expected to provide an

Ecology Report of certain key references, Arendse, smith • ndlovu • independent assessment of the project area and we are including: summers attorneys, comment confident that the specialist is qualified and experienced to 43.1. Von Hase, A., M. Rouget, K. Maze, and N. by e-mailed letter, 08 conduct visual impact studies for linear developments like Helme. 2003. A fine-scale conservation plan for December 2014. powerlines. Literature review is an important component in Cape Lowlands Renosterveld: Technical report. any study, how selection of the literature depends on the CCU Report # 2/03, Botanical Society of South specialist’s own knowledge and expertise. We are further Africa, Kirstenbosch. This report highlights confident that our specialist used appropriate methodology to Elandsberg as a priority area for Renosterveld assess the visual impact of the entire development. Specific conservation in the Swartland. impacts will be covered when the final route selection is 43.2. Helme, N. 2008. Botanical Scoping concluded. As in the response above, over use of absolute Assessment: New transmission lines from comments is not appreciated by the entire team. The Bantamsklip to Bacchus, Kappa and Muldersvlei, consultation and review process is meant to ensure that and extension of Bacchus Substation, Western significant heritage resources are protected during any Cape. Report for Eskom and Arcus Gibb (SA). development. Nick Helme Botanical Surveys, Scarborough. This report also highlights Elandsberg as a priority area for Renosterveld conservation in the Swartland, and highlights it as an area of very high ecological sensitivity that should be avoided by new power lines. 43.3. Elandsberg Nature Reserve is indicated as a Focus Area in the map of the National Protected Area Expansion Strategy (2008). 41 44. The section on the No-Go alternative20 in Richard Summers and Clarice Comment noted but you issues revolve around differences in the Terrestrial Ecology Report is a cursory Arendse, smith • ndlovu • expert opinions and approaches. analysis. Notably, no mention is made of formal summers attorneys, comment conservation areas and the fact that the by e-mailed letter, 08 ecological condition of these areas is stable or December 2014. improving. It is for this reason that the No-Go scenario in these areas is positive from an ecological perspective, versus negative for all development alternatives.

42 45. There is only a brief discussion of cumulative Richard Summers and Clarice Please note those specialists are guided by different impacts21 which is cursory and inadequate. No Arendse, smith • ndlovu • legislations and guidelines which are applicable to their fields mention is made of the impacts of servitude summers attorneys, comment of study. For example in Archaeology construction a powerline brushcutting (which may be strongly negative); by e-mailed letter, 08 close to another powerline is considered to be ideal than going access roads (which may also be negative); or December 2014. to virgin servitude. Furthermore constructing a powerline the cumulative impact of Eskom power lines and across known sites provides the opportunity to avoid them. I servitude management in general. The brushcut would like to assure you that our specialist did consider servitude on Elandsberg alone impacts on 18 cummulative impacts in their various fields. Site specific and hectares of vegetation (this is clearly visible on comprehensive studies will be done once the final route is Google Earth imagery dated 14 October 2014), selected. which is far from insignificant in a Critically Endangered vegetation type, especially when it As indicated earlier on site specific impacts will be considered is known to support numerous species of after the final route selection is concluded. The selected route conservational concern. The proposed power line will be subjected to walk down surveys which will deal with will cross many kilometres of intact vegetation, site specific impacts including tower to tower impacts. Please and thus servitude brushcutting could have note that construction phase management plan will also take significant cumulative negative impacts when into consideration site specific impacts, there after an added to the other brushcutting undertaken in operational phase management plan will consider the impacts existing Eskom servitudes in the region. The of the proposed powerline after construction including impacts acknowledgement that “by adding an additional of routine mantainace work and repairs. servitude the loss of Renosterveld would be significant within the area”22 suggests that the authors are aware of the negative impact of brushcutting, but do not address the impacts adequately or comprehensively throughout the entire route 43 46. The frequency of brushcutting in the Richard Summers and Clarice Comment noted. The Terrestrial and Ecology report is based servitude that crosses Fynbos vegetation of this Arendse, smith • ndlovu • on the study of the site of interest and expert opinions. type is critical. If undertaken frequently, or if the summers attorneys, comment Differences in approaches and expert opinions should not be site is burnt in the intervening period, it may by e-mailed letter, 08 undermined. Although we appreciate your opinion it is should lead to local extinction of some of the slower December 2014. not be treated as binding. growing and slower maturing species, notably

certain succulents and shrubs, some of which may be species of conservational concern. Frequent brushcutting in Fynbos systems can severely alter vegetation structure, rapidly changing it to a grassland that is in fact more fire prone than the original vegetation (although this is in fact noted in page 111 of the FEIR, the potential impact thereof is not accurately assessed in either the FEIR or the Terrestrial Ecology Report). 44 47. The section on the No-Go alternative20 in Richard Summers and Clarice Your detailed comments are note, however as mentioned the Terrestrial Ecology Report is a cursory Arendse, smith • ndlovu • above your issues revolve around differences in approach and analysis. Notably, no mention is made of formal summers attorneys, comment expert opinion. It is unfortunate that your opinions are based conservation areas and the fact that the by e-mailed letter, 08 on subjective and biased analysis of the impacts where as our ecological condition of these areas is stable or December 2014. study is objective and independent of any personal or external improving. It is for this reason that the No-Go influence or interest. scenario in these areas is positive from an ecological perspective, versus negative for all development alternatives. There is only a brief discussion of cumulative impacts 21 which is cursory and inadequate. No mention is made of the impacts of servitude brushcutting (which may be strongly negative); access roads (which may also be negative); or the cumulative impact of Eskom power lines and servitude management in general. The brushcut servitude on Elandsberg alone impacts on 18 hectares of vegetation (this is clearly visible on Google Earth imagery dated 14 October 2014), which is far from insignificant in a Critically Endangered vegetation type, especially when it is known to support numerous species of

conservational concern. The proposed power line will cross many kilometres of intact vegetation, and thus servitude brushcutting could have significant cumulative negative impacts when added to the other brushcutting undertaken in existing Eskom servitudes in the region. The acknowledgement that “by adding an additional servitude the loss of Renosterveld would be significant within the area”22 suggests that the authors are aware of the negative impact of brushcutting, but do not address the impacts adequately or comprehensively throughout the entire route. The frequency of brushcutting in the servitude that crosses Fynbos vegetation of this type is critical. If undertaken frequently, or if the site is burnt in the intervening period, it may lead to local extinction of some of the slower growing and slower maturing species, notably certain succulents and shrubs, some of which may be species of conservational concern. Frequent brushcutting in Fynbos systems can severely alter vegetation structure, rapidly changing it to a grassland that is in fact more fire prone than the original vegetation (although this is in fact noted in page 111 of the FEIR, the potential impact thereof is not accurately assessed in either the FEIR or the Terrestrial Ecology Report). The mitigation measures proposed in the Terrestrial Ecology Report will not significantly reduce the cumulative impacts of the project, as

the pylons and access roads will still be built in various ecologically sensitive areas, and the servitudes are very likely to be brushcut as, when and where Eskom desires. It is also submitted that Eskom has had a bad and well documented history of servitude mismanagement (most notably at the Plattekloof Natural Heritage site in the City of Cape Town, as well as in the Breede River valley near Robertson where Succulent Karoo vegetation (which was not capable of holding a fire) was brushcut). 45 48. With regard to areas of exceptional Richard Summers and Clarice Comment noted, but as indicated above we realize your lack of significance 23, it is questionable how the Arendse, smith • ndlovu • appreciation of our methods and approaches in impact studies. Terrestrial Ecology Report’s analysis determined summers attorneys, comment that only three areas were of exceptional by e-mailed letter, 08 biodiversity significance, when the criteria were December 2014. that “these areas coincide with areas indicated to be either natural vegetation and CBAs (Fine Scale Plans) or critically endangered ecosystems (Threatened Ecosystem Status).” Elandsberg fits all these criteria, yet it was excluded. The failure by the specialists to incorporate Elandsberg in their findings stems from the fact that they did not refer at all to the Cape Lowlands Renosterveld study (von Hase et al 2004), which is the recognised Fine Scale Plan for that specific area. 46 49. Further, mitigation requirements are not Richard Summers and Clarice Please note that the studies were conducted by qualified and dealt with explicitly in the Terrestrial Ecology Arendse, smith • ndlovu • experienced specialist whom we do not doubt the credibility of Report. This is a particularly serious oversight, summers attorneys, comment their work. In our view it is the responsibility of compliance

as mitigation is one of the most important by e-mailed letter, 08 agencies to make the final decision on our studies. sections of an impact assessment and without a December 2014. credible implementation of the mitigation hierarchy the results of the EIA are not credible. The fact that mitigation requirements are not contained in the Terrestrial Ecology Report invalidates the impact assessment, which refers to the impacts “after mitigation”. 47 HERITAGE Richard Summers and Clarice Thank you for raising issues relating to the heritage value of 50. Several critical concerns were raised in our Arendse, smith • ndlovu • the Elandsberg Farms. Your concerns have been noted and letter dated 11 August 2014 with the level of summers attorneys, comment dealt with adequately; refer to revised Cultural Landscape heritage impact assessment. These concerns by e-mailed letter, 08 Report, November 2014, BoD and ST, November 2014. ith were captured in an independent review of the December 2014. adequately. draft HIA Report and the Built Environment Report which was undertaken by Mr. Ashley Lillie and Ms. Sarah Winter. 48 51. Our previous set of comments highlighted Richard Summers and Clarice No doubt that every landscape in one way or another is a the fact that the Elandsberg Nature Reserve is a Arendse, smith • ndlovu • cultural landscape. We have no doubt that Elandsberg Reserve property of considerable heritage significance summers attorneys, comment is significant. In addition the sites in question are already and that there were several flaws in the heritage by e-mailed letter, 08 protected by the NHRA and NEMA and the HIA study was impact assessment methodology, which had December 2014. conducted conscious of these factors. Our heritage studies compromised the assessment of heritage were not limited to one locality and one type of heritage; we impacts. The heritage-related concerns were looked beyond historical and colonial heritage of the substantiated by the independent expert opinion landscape. of Ashley Lillie and Sarah Winter. 49 52. It appears that we are unable to engage Richard Summers and Clarice Indeed we do not see the logic of panicking over a process meaningfully with the EAP on this particular – Arendse, smith • ndlovu • that is legislated and whose results are yet to be assessed and critically important – aspect of the impact summers attorneys, comment adjudicated by the relevant competent authorities. Please note assessment process. The reason for this is the by e-mailed letter, 08 that our responses were triggered by comments that seek to high-handed and dismissive approach the EAP December 2014. undermine our credibility. Reading from the tone of comments has adopted in connection with the heritage- and issues, we are of the view that you are simply lobbying

related issues identified in connection with the against the whole process with little or no intention to DEIR. In illustration of this point the Comments contribute productively to the EIA process. Your clients were and Response Report24 indicates as follows: accorded the opportunity to raise their concerns in accordance 52.1. “From a heritage perspective we do not with the NEMA regulations and section 38 of the NHRA. see any reason for ringing alarm bells because the law is clear about impacts associated with development.” 52.2. “This property and associated heritage resources enjoys specific and general protection from the NHRA Sections 34 and 35.” 52.3. “... we are confident our heritage specialists covered your concerns adequately.” 50 53. In order to determine definitively whether or Richard Summers and Clarice Your concerns are noted however we still insist that our not the EAP can defensibly claim to have Arendse, smith • ndlovu • various methods and approaches are adequate to fulfil the covered heritage-related concerns adequately summers attorneys, comment Phase 1 mandates. Please note that issues of methodology our clients have again commissioned Ashley by e-mailed letter, 08 and approaches are contested, our methods and approaches of Lillie and Sarah Winter to review the FEIR and December 2014. assessment may not be primarily dismissed on the basis that a the HIA. That review is attached hereto marked reviewer does not agree with our approach. Whether the B in a letter dated 8 December 2014 which review is repeated over and over again as long as it is the confirms that the concerns regarding the same reviewer being engaged we start questioning the heritage assessment methodology, cumulative credibility of the process. impacts and the nature and scope of heritage impact assessment have not been addressed in the final HIA and specialist report. 51 54. On this basis the claim in the Comments and Richard Summers and Clarice Your recurrent issues are acknowledged but we still stick to Response Report that requirements of section Arendse, smith • ndlovu • our point that our HIA report fulfils requirements of section 38(3) of the National Heritage Resources Act 25 summers attorneys, comment 38(3) and international best practice. It is within your of 1999 have been addressed is disputed. We by e-mailed letter, 08 constitutional rights to raise your concerns with compliance have been instructed to raise these concerns December 2014. agencies but we strongly feel that your issues would be best directly with the relevant heritage resources dealt with by the relevant specialists conducting the studies. authority in the Western Cape (HWC) due to the The role of Heritage Western Cape is to comment on a finished fact that the adequacy of heritage impact product.

assessment is central to our clients’ concerns and is likely to be the subject of an ongoing dispute if this issue is not addressed appropriately and responsibly through the NEMA EIA process. 52 VISUAL IMPACTS Richard Summers and Clarice Your intervention is commended as long as it is intended to 55. An independent review of the Visual Impact Arendse, smith • ndlovu • bring value to the EIA process. Assessment (“VIA”) Report was undertaken on summers attorneys, comment behalf of our clients by Messrs. Bernard by e-mailed letter, 08 Oberholzer and Quinton Lawson and which December 2014. formed part of our clients’ comments on the DEIR. 53 56. The review by Messrs. Oberholzer and Richard Summers and Clarice Your comments are noted. Please refer to attached response Lawson indicated that the level of detailed visual Arendse, smith • ndlovu • from Gerhard Griesel dated 20 October 2014. In our opinion impact assessment was inadequate for a project summers attorneys, comment experience and expertise are key in impact studies hence our of this nature and did not enable an appropriate by e-mailed letter, 08 confidence in the specialist. Note that our Heritage Principal consideration of visual impacts. It is simply December 2014. Investigator reviewed the specialists’ reports. inadequate for the concern raised to be disposed of with glib references to the fact that “the specialist is highly qualified and has conducted a lot of visual studies in the country as a whole”.25 It was also not acceptable for the EAP to retort that the “specialist did assess all the areas and the final walkdown will further specify the scenic routes and many others”.26 Responses such as those quoted in the aforementioned text are meaningless and do not take the matter further. Our clients went to the trouble of commissioning independent expert opinion on the basis that they felt the treatment of visual impacts was not adequate. The type of flippant response to these issues is

unacceptable. In the circumstances, we have no alternative but to request DEA to reject the visual impact study and the FEIR in the manner contemplated in Regulation 34 of the EIA Regulations. Alternatively, and as a bare minimum DEA is requested to inform the applicant that both the visual impact report and the FEIR have been referred for specialist review in terms of section 24I of NEMA. 54 57. For the reasons set out above, the visual Richard Summers and Clarice Please refer to response letter from Gerhard Griesel dated 20 impact assessment undertaken as part of the Arendse, smith • ndlovu • October 2014. EIA process is fundamentally flawed. summers attorneys, comment Accordingly, the VIA Report does not assist in by e-mailed letter, 08 assessing the visual impact of the proposed December 2014. power line. There is therefore insufficient information to enable a considered understanding of all visual impacts or how the proposed power line will affect particular resources. It is not possible for our clients to engage meaningfully on the manner in which the project will impact on the heritage significance and experiential qualities of our clients’ property. 55 DESCRIPTION AND ASSESSMENT OF ALL Richard Summers and Clarice Your comments are not, however in our opinion we realize the COMPONENTS OF THE PROJECT Arendse, smith • ndlovu • misconception of post approval measure to protect the 58. We reiterate that there are several summers attorneys, comment environment. Our methodologies and approaches are guided potentially significant consequences for and by e-mailed letter, 08 by NEMA regulation and the NHRA and we strongly believe impacts on the environment that have not been December 2014. that we are operating within the confines of the laws of this dealt with in the EIA process and which the EAP land. seems to suggest will be investigated / assessed at some later (unidentified) stage. The Comments and Response Report confirms our concern that several critical aspects of the

project will only be evaluated and assessed after completion and approval of the EIA process. 56 59. In order to satisfy the legal requirements in Richard Summers and Clarice Acknowledged, we confirm that all impacts were adequately NEMA, all potential impacts on the environment Arendse, smith • ndlovu • dealt with in our report. In addition site specific impacts will be must receive adequate consideration as part of summers attorneys, comment further dealt with during walk down surveys. the EIA process before actions are taken in by e-mailed letter, 08 connection with them. December 2014. 57 60. The approach adopted in connection with Richard Summers and Clarice Comment noted, but it seems you have a different this project gives rise to a ‘deferred assessment’ Arendse, smith • ndlovu • understanding of the authorisation process. Our assessment in terms of which critical aspects of project- summers attorneys, comment goes beyond just authorisations. related environmental impacts are deferred for by e-mailed letter, 08 ‘assessment’ after the project has been December 2014. approved. This type of ‘deferred assessment’ is not compatible with NEMA or the EIA Regulations for the reasons set out in detail in our letter dated 11 August 2014. 58 61. It is also not possible for our clients to Richard Summers and Clarice See letter from Gerhard Griesel dated 20 October 2015. engage with potential impacts (for example Arendse, smith • ndlovu • visual impacts and impacts on biodiversity) summers attorneys, comment without a detailed understanding of the type of by e-mailed letter, 08 power line structures that will be used. The December 2014. severity of the impact may vary greatly depending on the type of structures. The FEIR is devoid of the requisite detail as it simply confirms that: “Various tower structures on which powerlines will be suspended are being considered for use during the construction in different sections of the line subject to landscape, engineering and biophysical environment of the receiving areas”.27

59 ALTERNATIVES Richard Summers and Clarice Your comments are noted. It is correct that Eskom SOC 62. For the reasons outlined in our comments Arendse, smith • ndlovu • proposed a specific development in a specific geographic area dated 11 August 204, we reiterate that the summers attorneys, comment where the proposed lines should connect fixed pre-existing approach to the identification and assessment of by e-mailed letter, 08 substations. The proposed powerline has to T-off from fixed alternatives in this project was constrained at December 2014. Kappa Sub Station and traverse through sections of the the outset, as the applicant pre-determined the Western Cape to another existing and fixed Omega Station alternative routes.28 It is clear from the location. Whichever way or approach, logic framework dictates specialist reports that the specialists (and the that the study area has to be defined around these fixed EAP) were not involved in the route selection points and the powerline may only be considered within a process or the identification of appropriate viable corridor between the fixed points (See our earlier development alternatives.29 In the result the response to issues EIA process has been constrained as it is not possible to fully implement the mitigation hierarchy if the alternatives are pre-determined and not influenced by specialist input. 60 63. The FEIR and specialist studies illustrate that Richard Summers and Clarice See response 59 above. Eskom pre-determined the alternative routes Arendse, smith • ndlovu • before the EIA process commenced and the EAP summers attorneys, comment and specialists were constrained to a by e-mailed letter, 08 consideration of these pre-determined December 2014. alternative routes only.30 61 64. Published guidelines (referred to in our letter Richard Summers and Clarice See response for 59 dated 11 August 2014) recognise that Arendse, smith • ndlovu • alternatives must be identified with reference to summers attorneys, comment the EIA process. In this sense, the EIA process is by e-mailed letter, 08 rendered ineffective if the role of the EIA process December 2014. is limited to identifying the impacts associated with pre-determined alternatives. 62 65. As the specialist studies did not inform the Richard Summers and Clarice See response for 59 route selection, the effect of this is that the Arendse, smith • ndlovu • route selection has not been informed by an summers attorneys, comment

evaluation and assessment of information on the by e-mailed letter, 08 anticipated impacts of the proposed power line. December 2014. The EAP has failed to demonstrate that the assessment of alternatives has responded to specialist input generated through the EIA process. 63 NEED AND DESIRABILITY Richard Summers and Clarice NEED and DESIRABILY have been adequately dealt with in 66. The enquiry into need and desirability in Arendse, smith • ndlovu • accordance with NEMA regulation. I our view differences in terms of the EIA Regulations, requires a holistic summers attorneys, comment opinion and approach do not make our findings invalid. There and integrated consideration of the positive and by e-mailed letter, 08 is no one answer to such studies, we are not dealing with negative environmental effects of the proposed December 2014. figures and numbers, it is a matter of facts and opinions, of development. This exercise requires the course backed by expertise and experience. accurate prediction, evaluation and assessment of all environmental, economic and social impacts. 64 67. Based on the deficiencies in the assessment Richard Summers and Clarice Acknowledged. Please understand that our role is protect the and evaluation of each project-related impact, Arendse, smith • ndlovu • Environment.Please understand, that we also work as the FEIR does not enable the “evaluation” of summers attorneys, comment independent consultants Before Eskom even appoints need and desirability contemplated in applicable by e-mailed letter, 08 independent consultants they already know the need for that guidelines. The EAP’s response to issues raised December 2014. line. We as consultants don’t sit down and make up the need during the public participation process illustrates for the powerline.It might seem generic to you, but please be that the EAP has scant regard for the relative aware of the fact that Eskom undergoes several processes importance or significance of information, in the prior to involving anyone else. We as independent consultants light of people’s values, preferences and and specialists, then do further studies. judgments, and the importance of that in order to enable informed decision-making in the EIA process. 65 CUMULATIVE IMPACTS Richard Summers and Clarice We insist that the issue relating to cumulative impacts has 68. In our letter dated 11 August 2014, we Arendse, smith • ndlovu • been dealt with adequately in our previous response. The identified several concerns regarding the fact summers attorneys, comment ‘Cultural Landscape Report’ recommendation of the preferred that cumulative impacts were not appropriately by e-mailed letter, 08 route Option 1 and 1a is based on the combination of

considered. These concerns have not been dealt December 2014. developed heritage indicators and the assessment of negative with in a meaningful manner through properly impacts on heritage resources on regional, sub regional and considered evaluation and assessment. Given local scales. This report also does not limit the recommended the EAP’s approach in responding to these option to route 1, based on the above, BoD and ST, November concerns in the Comments and Response 2014. Report, it would appear pointless to repeat our detailed submissions regarding cumulative impacts save to state that: 68.1. The additional review by Ashley Lillie and Sarah Winter dated 8 December 2014 (attached hereto) confirms that the cumulative heritage impacts have not been assessed. 68.2. Our clients have engaged Nick Helme who has also confirmed that the cumulative botanical impact has not been assessed thoroughly.31

31 Our clients were unable to obtain a formal written submission from Nick Helme in connection with the botanical impact assessment due to the relatively short timeframe for commenting on the FEIR. Our clients will endeavour to obtain a formal response from Mr. Helme which then can be submitted to DEA in supplementation of these comments in the FEIR given the central relevance of the need for our clients to obtain specialist inputs in connection with key areas on the basis that the EAP has simply failed to engage the substance of the concerns raised. 66 9. We reiterate that there are significant gaps in Richard Summers and Clarice See attached (previous) comments on the matter. the assessment of cumulative impacts and the Arendse, smith • ndlovu • EIA is based on several unsubstantiated summers attorneys, comment

assumptions and / or conclusions regarding by e-mailed letter, 08 cumulative impacts. December 2014. 67 70. There is simply not sufficient information Richard Summers and Clarice Please note those specialists are guided by different regarding the assessment of cumulative impacts Arendse, smith • ndlovu • legislations and guidelines which are applicable to their fields associated with the proposed development. The summers attorneys, comment of study. For example in Archaeology construction a powerline FEIR fails to satisfy the content requirements of by e-mailed letter, 08 close to another powerline is considered to be ideal than going the EIA Regulations in this regard. December 2014. to virgin servitude. Furthermore constructing a powerline across known sites provides the opportunity to avoid them. I would like to assure you that our specialist did consider cummulative impacts in their various fields. Site specific and comprehensive studies will be done once the final route is selected.

Thank you for making that observation, we are very aware of that and the essence of the EIA process is to capture direct and indirect impacts as well as considering the cumulative impacts of the proposed development. Powerline development is not a new and unique development that may warrant panic by members of the public.

68 ELECTRIC AND MAGNETIC FIELD RADIATION Richard Summers and Clarice Thank you for your concern. We have attached an EMF report 71. The purpose of raising several concerns with Arendse, smith • ndlovu • as Appendix 5. This report, clearly stipulates the use of Electric and Magnetic Field (“EMF”) radiation and summers attorneys, comment electromagneic shieling to reduce the impacts. Electromagnetic Interference (“EMI”), is to by e-mailed letter, 08 illustrate that there is general public concern on December 2014. A report was attached as an appendix, which had answers to the issue of EMF radiation and public fear in all your concerns. You have stated that, the report was respect of the health and environmental risks. outdated. May you please assist us with the latest, which speaks something totally different from what was attached in the report. Despite extensive research, to date there is no evidence to conclude that exposure to low level electromagnetic fields is

harmful to human health.

Please refer to EMF Project- World Health Oraganization site on : http://www.who.int/peh-emf/en/

69 72. There is no basis to conclude that the EMF Richard Summers and Clarice Thank you for your concern. We have attached an EMF report radiation generated by power lines is no Arendse, smith • ndlovu • as Appendix 5. This report, clearly stipulates the use of different from the background levels that people summers attorneys, comment electromagneic shieling to reduce the impacts. are already exposed to. There has been no by e-mailed letter, 08 assessment of the relevant exposure rates. December 2014. A report was attached as an appendix, which had answers to There has also been no assessment of the all your concerns. You have stated that, the report was potential cumulative health impacts when outdated. May you please assist us with the latest, which considered against the existing power lines in speaks something totally different from what was attached in the study area. The potential for EMI to interfere the report. or interrupt electronic equipment and Despite extensive research, to date there is no evidence to telecommunications on our clients’ property is conclude that exposure to low level electromagnetic fields is required to be considered as the construction of harmful to human health. additional high voltage transmission lines will inevitably give rise to EMI. Please refer to EMF Project- World Health Oraganization site on : http://www.who.int/peh-emf/en/

70 73. The lack of conclusive evidence relied on in Richard Summers and Clarice Thank you for your comment. We strongly believe that all the EIA process, coupled with public concern and Arendse, smith • ndlovu • Environmental impacts were indicated in the report. The entire the risk of negative impacts on human health summers attorneys, comment team is qualified and highly experienced to handle impact and the receiving environment, justifies a by e-mailed letter, 08 assessment for a powerline project. precautionary approach to this issue. The December 2014. Comments and Response Report reveals that the EAP’s approach is to defend the basis upon which the conclusions in the DEIR were reached. The reference to “extensive research” is not supported by the almost exclusive reliance on the Empetus Report which is a 2006 study.

71 74. We are of the opinion that this issue has not Richard Summers and Clarice Comment noted, but we acknowledge that powerlines are not been fairly and transparently evaluated with Arendse, smith • ndlovu • new inventions and their potential harm has been assessed reference to best available science. The inherent summers attorneys, comment elsewhere. The fact that powerlines of that nature are still risk associated with relying on the FEIR as a by e-mailed letter, 08 being constructed does not make the proposed 765 KV unique. basis for informed decision-making is that this December 2014. runs counter to the risk- averse and cautious approach which DEA is mandated to apply in terms of section 2 of NEMA. 72 NOISE-RELATED IMPACTS Richard Summers and Clarice Specific impacts will be dealt with once the final route 75. The noise impacts that will be experienced Arendse, smith • ndlovu • selection and authorisation is concluded. Note that the route on our clients’ property have not been assessed summers attorneys, comment covers more than 2km and noise levels will vary depending on in any meaningful manner. The potential for the by e-mailed letter, 08 the distance from the activity areas and the duration of the project to give rise to audible noise must be December 2014. activities. All your concerns will be best dealt with in our investigated, evaluated and assessed. The construction EMP. studies required in this regard must be sufficiently accurate to enable our clients to make a meaningful appraisal of the potential for noise impacts to impact on their property rights, and to give rise to a nuisance. It was precisely because of the generic and vague manner in which this impact was addressed in the DEIR that we raised several noise-related concerns. Our clients wish to understand the potential for the power lines to give rise to audible noise on their properties. It is highly inappropriate for the EAP to respond to this concern with the glib remark that “its not the first time that Eskom is doing a project of such kind”32 or that “we even included mitigation measures”.33 This superficial approach to site specific impacts leaves our clients with no understanding of how this potentially severe impact will interfere with their

use and enjoyment of their properties or detract from the qualities of the area. 73 CONCLUSIONS Richard Summers and Clarice Noted, but your comments are expected to aid the process not 76. As a result of the failure to engage with the Arendse, smith • ndlovu • to undermine and distort the process. The process is not a issues raised in regard to the DEIR, we are of summers attorneys, comment platform to trade insults. We respect your professional the opinion that the FEIR is materially deficient by e-mailed letter, 08 credibility and as a senior citizen we expect you to respect in several respects. The most serious flaw December 2014. fellow professionals. relates to the failure to identify, consider, evaluate and / or assess potentially significant It is not a platform to insult each other. Over use of absolute site-specific impacts (including cumulative comments such as ‘failure’ is in itself failure to respect effort, impacts) associated with the proposed power qualifications and experience of dedicated specialists. line. This has been substantiated (twice now) by The entire team is qualified and highly experienced to handle external expert opinion with regard to heritage- impact assessment for a powerline project. As indicated earlier related impacts. on site specific impacts will be considered after the final route selection is concluded. The selected route will be subjected to walk down surveys which will deal with site specific impacts including tower to tower impacts. Please note that construction phase management plan will also take into consideration site specific impacts, there after an operational phase management plan will consider the impacts of the proposed powerline after construction including impacts of routine mantainace work and repairs. 74 77. The FEIR does not satisfy the prescribed Richard Summers and Clarice We disagree with you on this matter. The entire team is requirement Regulation 31(2) of the EIA Arendse, smith • ndlovu • qualified and highly experienced to handle impact assessment Regulations relating to (1) the content for summers attorneys, comment for a mere powerline project. Powerline development is not environmental impact reports; and (2) the by e-mailed letter, 08 unique, powerlines have been built all over and generic nature and scope of impact assessment in terms December 2014. impacts of powerline development are well documented of NEMA. There is insufficient information elsewhere. In addition Eskom is experienced in building and relating to key aspects of the project and the managing powerlines. Environmental Impact studies impacts associated with the project (many of remember are not academic endeavours. The selection of which the EAP suggests will be dealt with as part routes is determined by Eskom‘s strategic planning and of a site walk-down in the post-authorisation demand. We are confident that our specialists are capable and

stage). This approach to the identification and they fulfilled their requirements of the relevant legislation that assessment of project impacts is not lawful. The govern their work. nature of the information made available is of a generic nature and in many instances is pitched Site specific mitigation measures can then be developed for at a scale of analysis which precludes a areas where re-alignment is not an option, however this would meaningful understanding of site-specific require detailed site assessments of all these areas; possibly impacts. The FEIR does not form a sound basis as a ‘second phase’ assessment that can inform the EIA prior for informed decision-making and the report to final submission or prior to finalisation of the EMP for the should be rejected by the DEA. project. This will allow for the further development of sitespecific construction and operational mitigation measures.

Mainstream Energy Perdekraal East Wind Energy Facility Objections 75 RE: Comment on Final EIR for the proposed Raymond Takuba & Mike Dear Raymond, & Mike, Kappa Omega 2nd 765kV powerline Mangnall, Senior Project Thank you for your e-mail and comments received. I hereby approximately 415km and substations upgrade Manager: Perdekraal East Wind acknowledge receiving your correspondence. Sincerely, in Western Cape. NEAS Reference: Farm, comment by e-mailed Shawn Johnston DEA/EIA/0001266/2012, DEA REFERENCE: letter, 08 December 2014. 14/12/16/3/3/2/352

Dear Hellen & Shawn, Thank you for the opportunity to comment on the final EIA report for the above mentioned project. Further to our previous emailed correspondence as well as our meeting on 23 May 2014, based on the Google kmz file sent on 21 July 2014, and a letter sent as a comment to the Draft EIR on the 6th August 2014 we would like to submit this I&AP letter as a comment to the final EIR.

As detailed in our letter submitted as a comment

for the Draft EIR commenting period, we would again like to highlight that the preferred alignment (Gamma – Kappa section) routes through our Perdekraal East wind farm site. As such, we kindly ask for a specific response to the issues raised in the previous letter. We look forward to hearing back from you in this regard. Please do not hesitate to contact the undersigned should you have any queries. Yours sincerely,

Mike Mangnall Senior Project Manager: Perdekraal East Wind Farm Vleesbank Concerns 76 I currently have numerous Eskom high tention Christoffel Lombard, Lombard Your comment has been noted. We will keep you informed power lines over my farms and would like to be Trust, Farms Vleesbank, about this proposed development. For further information visit kept informed. Soetendal and Dreyersvlei, www.nzumbululo.com website comment by reply form 18 November 2014. Tulbagh Valley Heritage Foundation Hello and thanks for the email, receipt of which I Jayson, Tulbagh Heritage Shawn Johnston: The Tulbagh Heritage Foundation’s comment can confirm. We will discuss this at our Founation, 24 November 2014. was noted. December meeting and revert back to you soonest. Regards Jayson Dear Jayson,

Thank you for your e-mail. If you require clarity, please feel free to call me directly. All objections and comments can be sent to me as well.

Sincerely,

Shawn Johnston Hello Shawn. Jayson, Tulbagh Heritage Shawn Johnston: Hi Jayson, Founation, 11 December 2014. I was unable to understand much about your Thank you for your e-mail. In brief: proposal as there were too many attachments and pdfs and appendixes and it was all very This is the EIA application for the 2nd 765kV Transmission line general and I could not easily gauge if there was from the Kappa Ceres Karoo Substation to the Omega a threat to Tulbagh heritage or not. Can you Substation outside of Koenerg. The 1st 765kV line was perhaps just send me a summary of this approved and is currently being built and that is the one that application indicating where the lines will go and will pass close to Tulbagh. That line was approved about 10 what they will look like? I really don’t have time years ago. The 2nd 765kV line is proposed from through to wade through a disk to try and find what is Ceres, across the mountains to Wolseley/Kluitjieskraal Forest relevant to my organisation Area and over the mountains into the Elandsberg Farms near Hermon. So the 2nd 765kV line would not pass near Tulbagh Regards, Jayson, Tulbagh Heritage Foundation at all. Heritage Western Cape wanted us to make sure that all Heritage Conservation Groups like yourself are informed and afforded the opportunity to comment on the EIA and HIA aspects of the project.

Jayson, if the Tulbagh Heritage Foundation have any objections or wish to raise any concern about the 2nd 765kV transmission line you can submit it to me.

Sincerely, Shawn Johnston Dear Shawn. Jayson, Tulbagh Heritage The Tulbagh Valley Heritage Foundation’s comments are Founation, 12 December 2014. noted. We will keep you informed about this proposed Thanks for the explanation. Based on what you development. have said below, the Tulbagh Valley Heritage Foundation will not object to the proposed Transmission line from Ceres to Koeberg.

Kind regards,

Jayson

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