VERSION 2 OF MAY 2017

DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1.1 ISSUES AND RESPONSES TRAIL (BID) 4 1.1.1 Issues related to site selection 4 1.1.2 Issues related to air quality 7 1.1.3 Issues related to energy 9 1.1.4 Issues related to geotechnical stability 11 1.1.5 Issues related to EIA and Public Participation 12 1.1.6 Issues related to Biodiversity 17 1.2 ISSUES AND RESPONSES TRAIL (DRAFT SCOPING REPORT – DECEMBER 2015) 22 1.2.1 Issues related to site selection 22 1.2.2 Issues related to air quality 22 1.2.3 Issues related to electricity, energy and infrastructure 25 1.2.4 Issues related to Risks, Hazards & Waste 28 1.2.5 Issues related to EIA and Public Participation 30 1.2.6 Issues related to Biodiversity 38 1.2.7 Issues related to water and wastewater 40 1.2.8 Issues related to spatial policy, development planning & transport 43 1.3 ISSUES AND RESPONSES TRAIL (DRAFT SCOPING REPORT – OCTOBER 2016) 46 1.4 ADDENDUM TO THE ISSUES AND RESPONSES TRAIL (DRAFT SCOPING REPORT – OCTOBER 2016) 60 1.5 DEA’s COMMENTS ON THE FINAL SCOPING REPORT 72 1.6 COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT (version 1 of 22nd March 2017) 86

figure

Figure 1. Decision-making framework for identification of key issues for the EIA 3

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 1 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

ISSUES AND RESPONSES TRAIL

INTRODUCTION

An important element of the Scoping process is to evaluate the issues raised through the Scoping interactions with the specialists, authorities and the public, the EIA team and the project proponent. In accordance with the philosophy of Integrated Environmental Management, it is important for the EIA to focus on the key issues.

To assist in the identification of key issues, a decision-making process is applied to the issues and concerns raised, based on the following criteria (Figure 1):

1. Whether or not the issue falls within the scope and responsibility of the proposed Atlantis Gas-to- Power EIA; and 2. Whether or not sufficient information is available to respond to the issue or concern raised without further specialist investigation.

Issues were sourced by the CSIR team from the following Scoping interactions:

 Newspaper advertisement – In order to notify and inform the public of the proposed project and invite members of the public to register as I&APs, and to inform the EIA consultant about specific issues or interests in the proposed project, the project was advertised in provincial newspapers, i.e. The Cape Times (8 October 2015) and Die Burger (8 October 2015);  Telephone – issues raised by I&APs during telephonic consultations;  Letters and faxes – issues sent to CSIR via fax or posted correspondence;  Email – issues sent to CSIR via email correspondence; and  Comment Form – issues submitted to CSIR via the Comment Form that was provided with the Background Information Document (BID) that were mailed to I&APs (9 July 2015). Letter with the release of the Draft Scoping Report.

Appendix E of the DSR contains detailed correspondence received from I&APs as part of the December 2015 Draft Scoping Report and the October 2016 Draft Scoping Report. Comments received that are not relevant to or form part of this EIA process have not been included in the Issues Trail below. Section 1.2 below provides a summary of the comments received following the release of the BID and prior to the release of the Draft Scoping Report and they have been grouped according to the following categories (number in brackets indicates the number of issues raised):

1. Issues related to site selection (1) 2. Issues related to air quality (1) 3. Issues related to energy (3) 4. Issues related to geotechnical stability (1) 5. Issues related to biodiversity (2) 6. Issues related to EIA and Public Participation (13)

Section 1.3 provides a summary of the comments received following the release of the Draft Scoping Report of December 2015 and they have been grouped according to the following categories (number in brackets indicates the number of issues raised):

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 2 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1. Issues related to site selection (1) 2. Issues related to air quality (6) 3. Issues related to Electricity, energy and infrastructure (8) 4. Issues related to Risks, hazards and waste (3) 5. Issues related to EIA and Public Participation (23) 6. Issues related to biodiversity (2) 7. Issues related to water and wastewater (7) 8. Issues related to spatial policy, development planning and transport (7)

Figure 1. Decision-making framework for identification of key issues for the EIA

Section 1.4 provides a summary of the comments received following the release of the Draft Scoping Report of October 2016 and they have been grouped according to the following categories (number in brackets indicates the number of issues raised):

1. Issues related to site selection (1) 2. Issues related to air quality (6) 3. Issues related to Electricity, energy and infrastructure (8) 4. Issues related to Risks, hazards and waste (3) 5. Issues related to EIA and Public Participation (23) 6. Issues related to biodiversity (2) 7. Issues related to water and wastewater (7) 8. Issues related to spatial policy, development planning and transport (7)

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 3 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1.1 ISSUES AND RESPONSES TRAIL (BID)

The section presents the issues raised following the release of the BID and prior to the release of the Draft Scoping Report, together with a response from the EIA team. A synthesis of issues to be addressed in the Specialist Studies is provided in the Plan of Study for EIA (Chapter 7). The results of the Specialist Studies will be made available to I&APs for comment as part of the Draft EIA Report. All comments received prior to the release of the Final Scoping Report, through meetings and written correspondence are attached as Appendix E to this report.

1.1.1 Issues related to site selection

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 1.1 In the interim the following comment is provided 12 Oct 2015; Pat Titmuss; With regards to (a), (b) and (c), the preferred site is site 2 for the based on the limited information that was provided Email development of the Gas-to-Power Facility is site 2. This is located in the BID: Regional in the located in the Atlantis Industrial Risk Industry zone and h. The two site alternatives are zoned for General Manager: will be more suited to the proposed development, as Industry (GI 1) use where the following land use Environmental & mentioned. restrictions apply: Heritage (a) Primary uses are industry, restaurant, service Management: The Specialist Risk Assessment will look at each component of station, motor repair garage, funeral parlour, scrap Northern Region the facility in greater detail with regards to risk and the yard, authority use, utility service, crematorium, (Blaauwberg surrounding zoning (done in the EIA phase). rooftop base telecommunication station, District) freestanding base telecommunication station, With regards to (i): transport use, multiple parking garage, agricultural 1. A a risk assessment and emergency / evacuation industry, private road, open space and additional use management plan for the Gas-to-Power project (during rights as listed in paragraph (b). the construction and operational phases) will be form (b) Additional use rights are factory shop and adult part of the EMPr. shop, subject to the provisions of items 71 and 72, 2. Confirmation on the issue of the proposed development whichever is applicable. classifying as an MHI will be done following the (c) Consent uses are abattoir, place of worship, completion of the EIA, during the development phase. institution, clinic, place of assembly, adult 3. The increase in population due to the proposed entertainment business, adult services, aqua-culture, development will be tested against the Koeberg informal trading, shop, office, sale of alcoholic Nuclear Power Station Traffic Evacuation Model (TEM) beverages, place of entertainment, helicopter in the EIA phase.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 4 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE landing pad, wind turbine infrastructure and container site. Floor factor: 1.5 Height: 18m Street boundary building line: 5 m, subject to the general building line encroachments in item 121. S(69) Hazardous substances Notwithstanding the fact that an activity constitutes a primary use right in terms of the GI zoning, no activity or use which includes the on-site storage of hazardous substances shall be permitted unless a risk management and prevention plan has been submitted and the City has given approval thereto. Kindly note that following in regard of the Risk Industry (RI) zone: The RI zoning provides for those industries which are noxious in terms of smell, product, waste or other objectionable consequence of their operation, or which carry a high risk in the event of fire or accident. While other uses are permitted with approval, the City should not compromise the capacity of the RI zoning to accommodate noxious trade and risk activities. ‘risk activity’ means an undertaking where the material handled or the process carried out is liable to cause combustion with extreme rapidity, give rise to poisonous fumes, or cause explosion, and includes major hazardous installations and activities involving dangerous and hazardous substances that are controlled in terms of national legislation; ‘noxious’ means an offensive, poisonous or potentially harmful trade, use or activity which, because of fumes,

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 5 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE emissions, smell, vibration, noise, waste products, nature of material used, processes employed, or other cause, is considered by the City to be a potential source of danger, nuisance or offence to the general public or persons in the surrounding area; If the Atlantis Gas-to-power Project is more suited to a “risk activity”, then Site 2 located in the Atlantis Industrial Risk Industry zone, might be the more suitable site alternative. The proposed project activities and its zoning implications/suitability in terms of the General Industry or Risk Industry zones must be clarified in the draft scoping report.

(i) The two sites alternatives are situated between the 5 – 16 km Urgent Protective Action Planning Zone (UPZ) boundary of the Koeberg Nuclear Power Station (KNPS). The Disaster Risk Management Centre (DRMC) is the custodian (on behalf of the City of Cape Town) for the execution of the Koeberg Nuclear Power Station Radiological Release Hazard Disaster Risk Management Plan (RRR) and is tasked with the responsibility of ensuring that the public safety arrangements are in place in the case of a nuclear emergency and that individual citizens are not endangered with particular emphasis on the population residing in the UPZ of the 0 – 16 km area from the KNPS. In light of the aforementioned, the DRMC require the following:

1. That a risk assessment and emergency / evacuation management plan for the Gas-to- Power project (during the construction and operational phases) be compiled; 2. That it be confirmed whether the proposed

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 6 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE development will be classified as a Major Hazard Installation (MHI) and, if confirmed, to adhere to the relevant Regulation requirements from the National Department of Labour; and 3. That this application be tested against the Koeberg Nuclear Power Station Traffic Evacuation Model (TEM). In order to the TEM model to be run the anticipated population increase of each alternative must be stipulated in a proforma table and included in the various scoping and environmental impact assessment reports.

The abovementioned comment must be included in the draft Scoping Report. Kindly submit the draft Scoping Report [once available] to this office in the form of 1 x hard copy and 1 x CD version.

1.1.2 Issues related to air quality

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 2.1 The activity triggers the need for an Atmospheric 22 Sep Ian Gildenhuys; Noted. Emission Licence NEM:AQA Listing Notice 893 of 2015; Email City of Cape Town: 2013, Category 1 – Combustion Installation, Sub- and Air Quality A Specialist Air Quality Study including Atmospheric Dispersion Category 1.4 Gas Combustion Installation (if the 50 Comment Management Unit Modelling will be conducted during the EIA phase. Megawatt heat input thermal is triggered); and and possibly Category 2 – Petroleum Industry Sub- Registratio Category 2.4 Storage and Handling of Petroleum n Form Products (if the thresholds are exceeded). If this is a City owned project the competence to issue the AEL in terms of the NEM: Air Quality Amendment Act, will in all likelihood rest with the

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 7 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE WCG DEADP (See S36(4) of NEMAQA) or potentially National DEA (see below S36(5)) – the legal interpretation is still a bit vague in this regard. “‘‘(5) Notwithstanding subsections (1) to (4), the Minister is the licensing authority and must perform the functions of the licensing authority if— (a) a provincial organ of state, which has been delegated the power to perform the licensing authority function in terms of subsection (2) by the metropolitan or district municipality, applies for an atmospheric emission licence; (b) the listed activity falls within the boundaries of more than one province; (c) the listed activity forms part of a matter declared as a national priority in terms of a Cabinet decision and notice referred to in section 24C(2B) of the National Environmental Management Act, 1998, as amended by the National Environmental Management Laws Second Amendment Act, 2013; (d) the listed activity relates to the activities listed in terms of section 24(2) of the National Environmental Management Act, 1998, or in terms of section 19(1) of the National Environmental Management: Waste Act, 2008, or the Minister has been identified as the competent authority; or (e) the listed activity relates to a prospecting, mining, exploration or production activity as contemplated in the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002), in the area for which the right has been applied for, and the Minister responsible for mineral resources has been identified as the competent authority in terms of section 24C of the National Environmental Management Act, 1998.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 8 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE (6) For the purposes of subsection (5)(d), the Minister, as the competent authority empowered under section 24C(2) of the National Environmental Management Act, 1998 and as the licensing authority empowered under section 43(1) of the National Environmental Management: Waste Act, 2008, may issue an integrated environmental authorisation for the activities listed under section 24(2) of the National Environmental Management Act, 1998 and section 19(1) of the National Environmental Management: Waste Act, 2008.” A full EIA with Specialist Air Quality Study including Atmospheric Dispersion Modelling would be required

1.1.3 Issues related to energy

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 3.1 Wartsila, as a potential supplier of the power plant, 7 Sep 2015; Wayne Glossop; Comment noted. has business interests in this EIA Process. Technology Email and Business options considered for the power plant may extend Comment Development beyond CCGT’s as is described in the BID. We, as a and Manager; Energy provider of engine technology based power plants, Registration Solutions; would like to see this technology fully Integrated into Form Wartsila South the analysis as this would be a more than viable Africa option for future IPP’s in South Africa. Wartsila would be willing to cooperate and support the CSIR in providing technology specific information to inform their analysis. 3.2 iKapa Energy is an Independent Power Producer 22 Sep 2015; Craig Morkel; Noted. (IPP) Project Developer who has applied to lease / Email and iKapa Energy purchase a portion of Site 2, as per Basic Information Comment (Pty) Ltd This EIA ill not consider pipelines, servitudes or road extensions Document (BID) for the purposes of gas-fired power and outside of the site boundaries. Should there be a requirement generation facilities and related intended uses. Issues Registration for environmental authorization for these activities; a separate

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 9 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE to be considered in the EIA phase: Gas Supply, incl. Form assessment will need to be conducted. gas handling, storage, distribution / reticulation pipelines and processing. Early Power Generation by means of Open Cycle Gas Turbines (OCGT), incl. GHG abatement. Power Generation by means of Combined Cycle Gas Turbines, possibly incl. further GHG abatement. Phased water requirements (demand) vs. sources (supply) for construction & operations of OCGT & CCGT. Servitudes for closest grid connection points at Ankerlig, Dassenberg, Omega/Sterrekus, etc. Extension of Gideon Basson St along existing servitude to Neil Hare (north) for construction & operations. Use of the adjacent rail siding (owned by City of Cape Town or Transnet?) along eastern boundary. Possible need to sub-divide Site 2 for separate intended uses & to avoid land sterilization. 3.3 In the interim the following comment is provided 12 Oct 2015; Pat Titmuss; (d) The project entails the offtake of natural gas from the LNG based on the limited information that was provided Email Regional pipeline proposed between Saldanha Bay and the Caltex in the BID: Manager: Tableview refineray, and the subsequent use of such gas to d. The document is unclear as to what the project Environmental & generate electricity. The abovementioned pipeline does not “energy production and enable the benchmarking Heritage form part of this EIA process. The only gas infrastructure referred to as Atlantis Gas-to-power Project” entails, Management: considered in this assessment would be such infrastructure as i.e. gas storage / pipeline or gas generation from Northern Region located on the site itself (i.e. offtake pipeline and reticulation waste products. (Blaauwberg pipelines). f. The BID states that the facility will generate District) 1500mW (milliwatt). It is questioned whether the BID It should also be noted that the intention of this project is to should not read 1500 MW (megawatt)? Please create a site which has all the requisite environmental confirm the correct anticipated generation output. authorisations and licensing, and which a subsequent g. 1500 MW is an enormous amount of power Independent Power Producer (IPP) could develop under an requiring an enormous amount of servitude space. appropriate agreement with the CoCT (i.e. the Applicant in this The Lack of servitude access could be a fatal flaw if EIA). As such, CoCT is undertaking this EIA process without not identified and resolved timeously. It is therefore knowing the exact generation output or plant configuration requested, in scoping the preferred site, that the which would ultimately be developed on the site by an IPP.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 10 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE viability of the required gas pipelines and Accordingly, a worst-case scenario is followed in this EIA transmission power lines servitude(s) routes, as well process, whereby a maximum generation capacity (i.e. 1500MW) as the power lines connection routes into the is assumed, along with a maximum development footprint. national grid, be assessed. (f) The correct maximum output is 1500 MW (megawatt) The abovementioned comment must be included in the draft Scoping Report. Kindly submit the draft (g) Thank you, comment noted. As indicated in the response to Scoping Report [once available] to this office in the (d) above, this EIA process follows a worst case scenario form of 1 x hard copy and 1 x CD version. approach in terms of generation capacity. Should it emerge, during the impact assessment phase of this assessment, that the servitude space is insufficient; the generation capacity will be amended accordingly.

1.1.4 Issues related to geotechnical stability

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 4.1 In the interim the following comment is provided 12 Oct 2015; Pat Titmuss; (l) Noted based on the limited information that was provided Email Regional Manager: in the BID: Environmental & Heritage l. Both proposed sites fall within secondary Management: protections zones of and buffer zones to one of the Northern Region Atlantis Aquifer compartments. This aquifer serves as (Blaauwberg a critical water resource supplying part of Cape District) Town’s water requirements and thus adequate precautions must be taken to prevent contamination of the groundwater and negative impacts on the natural recharge of the aquifer. It is critical to take cognizance of the ground infiltration of any generated stormwater. Stormwater management shall thus be in accordance with the Policy for Water Sensitive Urban Design and the stormwater system design philosophy employed at Atlantis, and the

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 11 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE design for this shall be submitted to the Atlantis Aquifer Management Team (via the City of Cape Town: Bulkwater Branch) for acceptance prior to implementation.

The abovementioned comment must be included in the draft Scoping Report. Kindly submit the draft Scoping Report [once available] to this office in the form of 1 x hard copy and 1 x CD version.

1.1.5 Issues related to EIA and Public Participation

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 5.1 To register as an Interested and Affected Party 7 Sep 2015; John Geeringh, Noted. Email and Eskom GC: Land Comment Development and Registration Form 5.2 To register as an Interested and Affected Party 7 Sep 2015; Osman Asmal; City Noted. Email and of Cape Town, Comment Corporate Services and & Compliance Registration Form 5.3 To register as an Interested and Affected Party; 8 Sep 2015; Bertus van Noted. Business Interest, developer of natural gas power Email and Niekerk; : Mulilo plants and interested in participating in this project Comment Thermal Project and Developments Registration Form 5.4 To register as an Interested and Affected Party 7 Sep 2015; David Peinke; Noted. Email and Atlantic

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 12 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE Comment Renewable Energy and Partners Registration Form 5.5 To register as an Interested and Affected Party 7 Sep 2015; Sonia Miszczak; Noted. Email and Atlantic Comment Renewable Energy and Partners Registration Form 5.6 Be advised that the Environmental Resource 12 Oct 2015; Pat Titmuss; Noted. Management Department (ERMD) is the duly Email Regional Manager: mandated department to provide co-ordinated City Environmental & comment on EIAs conducted within the Heritage municipality’s jurisdiction. As Atlantis falls within the Management: Blaauwberg District of the City your EIA must be Northern Region submitted to this office for comment [It is noticed (Blaauwberg that you also dispatched a BID to a number of other District) internal city departments. For the reason explained above you therefore do not need to circulate the EIA to other City departments] 5.7 In order for the City to meet the statutory 12 Oct 2015; Pat Titmuss; Noted. deadline(s) you are required to timeously submit 1 x Email Regional Manager: CD and 1 x hard copy of the various Environmental Environmental & Impact Assessment reports to this office before Heritage ERMD can circulate the draft scoping report to all Management: our affected line departments. The public Northern Region participation commenting period will be calculated (Blaauwberg from the date that this office receives the CD and District) hard copy. As such please ensure that the CD and necessary documentation is delivered to our physical address as stated below – MILNERTON CIVIC CENTRE; 87 PIENAAR ROAD; CAPE TOWN; 7441 5.8 In the interim the following comment is provided 12 Oct 2015; Pat Titmuss; (a) We are unable to provide the DEA reference number in

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 13 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE based on the limited information that was provided Email Regional Manager: the Scoping Phase as the application for environmental in the BID: Environmental & authorization has not yet been submitted. This has not a. Please reflect the DEA reference number in all Heritage been submitted as there is a limited amount of time to future correspondence. Management: complete the EIA report after submission. Thus, we b. Please list the listed activities in terms of the Northern Region would like to complete scoping beforehand. We have NEMA Listing notices that environmental (Blaauwberg provided a CSIR reference number in place of this for authorization is being required. District) I&APs and commenting authorities to use during c. Reflect the erf number(s) of the subject properties scoping. in future documentation. Site 1 being Remainder (b) Please see Chapter 4 of this Draft Scoping Report. CFM 1183 and Portion 4 of CFM 93, whilst Site 2 (c) Noted. consists of Portion 1 and 4 of CFM 1183. (e) Noted. e. Be advised that Atlantis is about 35-40 km from (j) We will not be repeating the studies previously done in the Cape Town, not 53 km as stated in the BID. 2012 Basic Assessment. The only studies that will be cponducted j. The proposed specialist studies, being are Air Quality, Noise Impact and Risk Assessment. Please see Atmospheric emissions, Noise Impact, Visual Impact, the latter from Heritage Western Cape attached as Appendix G1 Socio-economic and Heritage (e.g. archaeology) is to this report with regards to the presence of heritage resources acknowledged. However the subject sites were on site. assessed, amongst other, in terms of a (k) Noted. Paleontological and Archaeological studies in 2012 (m) Noted. that formed part of the Green Technology (n) Noted. Manufacturing Cluster Industrial Development EIA (o) Noted. process (DEA&DP References: 16/3/1/1/A1/2/3036/12 and 16/3/1/1/A1/2/3037/12) as compiled by Doug Jeffery Environmental Consultants. The information of the said studies is still current as such the need to unnecessarily repeat these studies is questioned? k. Please refer to the existing Environmental Authorizations that has been issued by DEA&DP in relation to each of the two site alternatives on 16 January 2013. It is worthy to note that the off-site biodiversity offset imposed on the two sites has subsequently been secured by the City of Cape Town in accordance with the Atlantis Biodiversity Landbank incentive scheme. As such the need for a

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 14 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE Botanical Assessment is not required. m. Although the BID indicates that the inclusion of gas pipelines falls outside of the scope of this EIA, it is to be noted that any additional components throughout the development of this EIA shall be submitted to the City of Cape Town: Bulkwater Branch for comment or approval as is necessary. n. As no anticipated water demands [i.e. ADD, peak week average daily demand] were provided, the Bulk Water Branch is unable to confirm whether or not the City of Cape Town’s bulk supply system has sufficient water resource, treatment, bulk storage and conveyance capacity to supply the proposed gas-to-Power project, the AADD must therefore be included in the subsequent EIA phases. o. The availability of the required pressure and flow from the local water reticulation network, and point of connection off the reticulation network to supply the proposed gas turbine must be confirmed with the relevant Area Manager of the Reticulation Branch of the Water & Sanitation Department.

The abovementioned comment must be included in the draft Scoping Report. Kindly submit the draft Scoping Report [once available] to this office in the form of 1 x hard copy and 1 x CD version. 5.9 With reference to the above you are requested to 11 Sep 2015; Ms Noluvo Toto Please see attached letter from Heritage Western Cape make a payment for R300 and submit Notification of Email Heritage resource (Appendix H) confirming the presence of no heritage resources Intend to develop. Please use the case number as management on site resulting from the findings of Paleontological and ref number when making payment :15091106 Department of Archaeological studies in 2012 that formed part of the Green NB: It is essential that you ensure that the case Cultural Affairs and Technology Manufacturing Cluster Industrial Development EIA number is used as the bank reference for any Sport process. payment made to us. Failure to do so will determine Western Cape that HWC regards your application as unpaid for and Government

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 15 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE any payment made will be forfeit. Please ignore previous case number below and use this one :15091103 5.10 Thank you for your applications for the above 12 Oct 2015; Ms Nini Mtongana Please see attached letter from Heritage Western Cape mentioned case. Please note that as from 01 April Email Administrative (Appendix H) confirming the presence of no heritage resources 2013, SAHRA no longer accepts any hard copy sub Officer on site resulting from the findings of Paleontological and missions, or sub missions via e-mail. All sub missions Archaeology, Archaeological studies in 2012 that formed part of the Green for which SAHRA comment is requested, must be Palaeontology & Technology Manufacturing Cluster Industrial Development EIA done via our online information system - the South Meteorites Unit process. African Heritage Resources Information System South African (SAHRIS). Instructions on how to register on SAHRIS Heritage and how to create a case for your project on SAHRIS Resources Agency included. (SAHRA) 5.11 To register as an Interested and Affected Party 12 Oct 2015; Esca Coetzee; Noted. Email and Senior Comment Environmental and Scientist Registration Engineering Form Services: Environmental Engineering; Sasol Group Technology 5.12 To register as an Interested and Affected Party – The 18 Sep 2015; Sibulele Mdingi; Noted. proposed facility is near an ESKOM distribution Email and Eskom Holdings; infrastructure 132 kV line Comment Brackenfell and Registration Form 5.13 To register as an Interested and Affected Party – 8 Sep 2015; Des Brasington; Noted. Atlantic Energy are involved in the gas to power Email and Manager: project and want to be kept updated on what is Comment stakeholder happening with this proposed project and relations; Registration Atlantic Form Renewable

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 16 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE Energy Partners (Pty) Ltd

1.1.6 Issues related to Biodiversity

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 6.1 The proposed project entails the development of a 13 Oct 2015; Rhett Smart; Noted and we have taken these studies into consideration. closed cycle gas turbine power plant and associated Email Scientific Services; Mention of these studies have been made in this Draft Scoping infrastructure, and will be located within two CapeNature Report and will be re-emphasized in the EIA phase. potential sites which form part of the “Green Technology Manufacturing Cluster” industrial development within Atlantis.

These two sites have undergone applications to provide for industrial development rights and have both been authorised (DEA&DP reference numbers: 16/3/1/1/A1/2/3036/12 and 16/3/1/1/A1/2/3037/12). The applications were for the removal of indigenous vegetation and transformation of undeveloped land for industrial development, and therefore the impacts related to habitat loss associated with any individual developments within these sites were addressed in these applications.

CapeNature commented on the previous applications and our comments were adequately addressed and both applications were authorised. One of the conditions of approval, which was also considered as essential by CapeNature, was a biodiversity offset in order to compensate for the loss of biodiversity on the site. The condition of approval required that the applicant must engage with CapeNature in terms of securing the offset. A

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 17 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE biodiversity offset has been secured and CapeNature has provided formal correspondence indicating that we are satisfied that the condition has been met (dated 28 April 2015).

The Department of Environmental Affairs and Development Planning has undertaken an audit of the projects and has confirmed compliance with the conditions of approval (22 September 2015). Subsequent to our correspondence, we have received a copy for review of the Integrated Reserve Management Plan for the subject biodiversity offset site, namely the Klein Dassenberg Nature Reserve.

As a result of the existing authorisations for the property which deal with the loss of habitat, which would be the primary impact on biodiversity, no further specialist studies related to biodiversity are proposed. CapeNature agrees with this however, we recommend that a description is provided of how these impacts have been addressed in the previous application.

An additional potential impact is the impact on avifauna as a result of the electricity transmission lines. Depending on the alignment and the length of these powerlines, an additional avifauna specialist study may be necessary, although existing studies could also be referred to.

As a general statement, CapeNature supports the implementation of technology that will reduce the emission of greenhouse gases, however we do not comment in detail on these aspects.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 18 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE

CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received. 6.2 Condition of Approval for an Off-Site Offset for the 28 Apr 2015; Rhett Smart; Noted. Environmental Authorisation of the Following Two Email Scientific Services; Projects: CapeNature  “Green Technology Manufacturing Cluster” Industrial Development: Portion 0 of Farm CA1183 and Portion 93 of Farm CA4, Atlantis. (DEA&DP ref: 16/3/1/1/A1/2/3037/12)  “Green Technology Manufacturing Cluster” Industrial Development: Portion 4 and Portion 1 of Farm CA1183, Atlantis. (DEA&DP ref: 16/3/1/1/A1/2/3036/12)

CapeNature commented on the above two projects during the NEMA Basic Assessment process. The project was authorised and considered comments from Cape Nature (and other authorities and interested and affected parties) and as such added the following condition (among others) for both projects:

17. The off-site biodiversity offset must be secured within 1 (one) year of the commencement of construction. The applicant must engage with CapeNature in this regard. In response to high demand and need for development within the Atlantis urban edge, the City of Cape Town adopted a pro-active stance towards the conservation of the highly threatened biodiversity within the Atlantis district. The vegetation types are Endangered or Critically

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 19 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE Endangered and there are remnants occurring within the urban edge.

The City of Cape Town therefore embarked on the Atlantis Industrial Incentives Scheme, which has also been termed a Land Banking Mechanism. The project entails pro-active purchase or obtaining of land for formal conservation, which then forms part of the land bank against which development of natural areas within the Atlantis urban edge can be used as a debit against the proactively secured land and therefore act as an incentive for industrial development within the Atlantis urban edge.

The above initiative has been endorsed by the Department of Environmental Affairs and Development Planning (ref. no. 17/1/2, dated 19 June 2014). CapeNature has also been consulted regarding the initiative.

A site visit was undertaken by CapeNature) Land Use Advice and Botanist) of the first property that was acquired, namely Portion 9 of Farm 20, on 1 August 2014. We were able to confirm that the subject property consists of Critically Endangered Atlantis Sand Fynbos in very good condition with a low level of alien invasive species infestation (very rare within an urban context) and contains several Red Listed threatened species. The subject property is therefore suitable for offsetting the fragments of natural vegetation within the urban edge, which are more fragmented and heavily infested with alien invasive species, however still of conservation importance due to the threatened status and

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 20 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE possibility of threatened species present, but unlikely to be viable in the long term.

CapeNature therefore is in support of the Atlantis Industrial Incentives Scheme. However, we wish to state that this initiative or similar should only be considered for replication if it meets several criteria and cannot become standard practice without meeting these criteria. A standard operating procedure (SOP) has been drafted and comments have been incorporated from the various relevant parties and is in the process of being signed off.

Within this context, the offset requirement for the two Green Technology Manufacturing Industrial Developments listed has been suggested to contribute to the debits for the AIIS. The two projects qualify in terms of the criteria, as they are both located within the Atlantis urban edge. CapeNature is therefore satisfied that condition 17 of the two EAs has been achieved.

A sub-set of conditions fall under condition 17 related to the compilation of a Conservation Environmental Management Plan (CEMP), namely 17.1 – 17.3. CapeNature has been informed that a CEMP is in the process of being compiled for the larger conservation area and will include all the requirements of the conditions as well as more background and detail regarding the project and the site. This CEMP will therefore also be relevant for any other offsets forming part of the AIIS. A copy of the CEMP should also be submitted to CapeNature.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 21 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1.2 ISSUES AND RESPONSES TRAIL (DRAFT SCOPING REPORT – DECEMBER 2015)

This section presents the issues raised following the release of the first version of the Draft Scoping Report in December 2015 are provided below, together with a response from the EIA team. A synthesis of issues to be addressed in the Specialist Studies is provided in the Plan of Study for EIA (Chapter 7). The results of the Specialist Studies will be made available to I&APs for comment as part of the Draft EIA Report. All comments received prior to the release of the Final Scoping Report, through meetings and written correspondence are attached as Appendix E to this report.

1.2.1 Issues related to site selection

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 1.1 1.9 Chapter 6, Project Alternatives, Section 6.4 2 February Brian Jones / Edgar Thank you for your comment. Location Alternatives (Pg 6-6): Why are other sites 2016; email Capes closer to major load centers not considered (e.g. The location of site alternatives is largely informed by the Wingfield)? City of Cape Town: anticipated LNG pipeline route planned to connect the Port of Utilities Saldanha with the Chevron Refinery located in Tableview, Cape Directorate: Town. This pipeline is anticipated to pass by the existing Ankerlig Electrical Services Open Cycle Gas Turbine power station, as this power station would be a potential offtake point for the supplied LNG. As a result, the site alternatives considered for this project where located in close proximity to potential LNG offtake points (i.e. the Ankerlig Open Cycle Gas Turbine power station) as opposed to potential load centres like Wingfield.

1.2.2 Issues related to air quality

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 2.1 From an air quality perspective, this office concurs 2 February Ms L. Motthys Thank you for your comments. with the impacts identified by the EAP. As indicated 2016; email on page 5 of the document, it is the view of this City of Cape Town: 7.1: This is noted and the correct format will be adhered to. office that the DEA will be the competent authority Specialized Health

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 22 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE when dealing with the Atmospheric Emissions Services: Air 7.2: Noted. Licencing (AEL) of the facility: with the City's Air Quality Branch Quality Management Unit commenting as an 7.3: Agreed. The AEL application will be completed and interested and affected party. submitted in addition to the Air Emission specialist study.

This office therefore wishes to offer the following 7.4: These requirements will be taken into consideration. comments: 7.5: Noted. 7.1 The format of the Air Impact Assessment and Report, as indicated on page 8- I (point 8.7.1) must be carried out in accordance with Government Notice 747, dated 11 October 2o13, being the Regulations prescribing the format of the Atmospheric Impact Report.

7.2 Any Screening exercises must be undertaken in accordance with Government notice R533 dated 11 July 2014, being the Regulations Regarding Air Dispersion Modelling.

7.3 An application for the AEL must accompany the EIA at this time and is to be submitted in accordance with the provisions of the One Environmental System application process which is managed concurrently with the EIA process.

7.3.1 The AEL application must be completed electronically on the South African Atmospheric Emissions Licencing and Inventory Portal.

7.3.2 An additional public participation process advertising the proposed application for an AEL and the relevant category

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 23 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE information must be conducted and the project advertised in at least two newspapers circulating in the area.

7.3.3 Please be aware that the application may be subject to an additional processing fee payable to the DEA for the issuing of the AEL.

7.4 Please be aware that the requirements of the GN 893 stipulates that the following Minimum Emission Standards be met in terms of the respected categories:

7.4.1 Category 1: Sub-category 1.4: Gas combustion installations and potentially:

7.4.2 Category 2. Sub-category 2.4: Storage and handling of petroleum products

7.4.3 Further Licencing requirements may become necessary as information regarding the proposed development is made available.

7.5 The Head: Specialised Environmental Health reserves the right to provide additional comment during the process and as further information becomes available during the process.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 24 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1.2.3 Issues related to electricity, energy and infrastructure

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 3.1 There is no reference to the suitability of the 2 February Brian Jones / Edgar Thank you for your comments. proposed site regarding the likelihood of establishing 2016: email Capes a servitude/land access for both the LNG gas pipeline Should the servitude not be adequate, there is a possibility of and the powerline right to the site. The report does City of Cape Town: the City of Cape Town (applicant) to register an additional mention that these would be subject to separate Utilities servitude, as it is the owner of the property. Also, the other site ElA’s but surely these cannot be ignored in this report Directorate: alternative (site 1) will present the same limitations in terms of completely. When considering alternative sites the Electrical Services locating a LNG pipeline and a transmission line in the same aforementioned becomes material for the obvious servitude. As such, the servitude capacity limitation is not unique reason that if one cannot physically get adequate to the preferred site (site 2). access for the pipeline and the powerline (Note: the powerline alone would need a servitude of We are proposing a corridor within which the transmission lines something like 40 m width) there will not be a viable and the LNG pipeline can be accommodated. This would be in project. addition to the existing Eskom servitude and will potentially be located adjacent to this servitude. Positioning the generation in Atlantis makes sense, but positioning 1 500 MW there means infrastructure or wheeling costs, will be required or incurred. 3.2 Utilizing 400 MW blocks is perhaps not the best 2 February Brian Jones / Edgar Thank you for this. option, if Eskom already utilize 150 MV units. Keeping 2016: email Capes the units to this same size will have economies of As the report mentions, the project description has not been scales for maintaining them. The same argument City of Cape Town: finalized in terms of using 400 MW blocks. This information can goes for the step-up transformers and the LV Circuit Utilities be conveyed to the developers in that stage of the project and breakers (8 000 A CB at I lkV, 4000 A CB at 22kV). At Directorate: the most suitable option, taking into consideration all these 400 MW the LV Circuit breakers become extremely Electrical Services factors, will be decided upon. specialized and expensive. 3.3 Provision should be made to enable the steam also to 2 February Brian Jones / Edgar Noted. be sold. 2016: email Capes

City of Cape Town: Utilities Directorate: Electrical Services

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 25 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 3.4 Activity 2 listed in GN R984 (Listing Notice 2) clearly 2 February Brian Jones / Edgar Thank you this is noted and agreed. includes the infrastructure to connect the generators 2016: email Capes to the Eskom Omega substation, but this has not Activity 2 states: “The development and related operation of been included in the EIA. This is a fundamental flaw in City of Cape Town: facilities or infrastructure for the generation of electricity from a the Branch's opinion as the connection infrastructure Utilities non-renewable resource where the electricity output is 20 may need to be routed via very elaborate routes to Directorate: megawatts or more”, and does not specifically related to the avoid environmentally sensitive surrounding areas Electrical Services infrastructure required for connection to a substation. and will definitely need to be considered as part of the study. Eskom had serious issues getting EIA for However, GN R984 Listed activities 7 and 9 have now been the proposed replacement of the 400 kV Koeberg included in the EIA. Please see Chapter 4. NPS GIS switchgear. Please note that these two listed activities specifically refer to the transportation of gas and the distribution and transmission of electricity outside an industrial complex, whereas the proposed project will be taking place in an industrial area. However, in order to remain risk adverse, we will include these two listed activities. 3.5 The report is unclear as to whether the proposal is to 2 February Brian Jones / Edgar It is proposed (and advised at this stage by Eskom) that the connect to the Ankerlig power station's busbar or to 2016: email Capes facility will involve integration at Ankerlig, at 400 kV, and will be the Omega/Sterrekus substation? Comment from dependent on the planned new double circuit 400 kV Ankerlig- Eskom must be included to confirm whether the City of Cape Town: Sterrekus 400 kV line scheduled for completion in 2019. Utility provider would indeed accept this connection. Utilities Directorate: This decision is subject to further investigation by Eskom Electrical Services including site visits. 3.6 The Branch indicated that the Nuclear Regulator 2 February Brian Jones / Edgar It is still to be clarified whether the newly built 132 kV Ankerlig might have a problem with customer connections on 2016: email Capes busbar is dedicated for the offsite supply or whether it can be the Ankerlig busbar as it will be the black-start supply zoned to accommodate customers/generators. for Koeberg and regulations would prohibit this. The City of Cape Town: Branch is therefore of the opinion that Eskom must Utilities Further investigation will be undertaken on this in the EIA phase be approached in order to get a high level indication Directorate: in collaboration with Eskom to arrive at the most suitable of whether it is possible or not (at either points.) The Electrical Services solution. aforementioned is a vital part of the impact assessment which, if ignored as Eskom did during their Erica project, could result in significant

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 26 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE challenges. 3.7 Chapter 1, Introduction. Section 1.2. Need and 2 February Brian Jones / Edgar This relates to response 3.5 and requires further investigation Desirability, item 4 (pg 1-7): The impact of distributing 2016: email Capes from Eskom as well as the electrical utilities directorate of the 1 500 MW of power from the site to Omega/Sterrekus City of Cape Town. substation must be discussed. This infrastructure City of Cape Town: does not exist. In light of the Eskom cash crisis it Utilities would also be best to do a “self-build" where the City Directorate: of Cape Town do the design and build and hand over Electrical Services to Eskom. This is done in most of the private renewable projects now which saves time and money. 3.8 Chapter 2, Project Description, Section 2.2.5 Power 2 February Brian Jones / Edgar Thank you for the comment. Evacuation and associated infrastructure (pg 2-8): 2016: email Capes The current infrastructure is designed for 200 MW, so This is agreed, and Eskom is under the impression (prior to more transporting 1 500 MW is a significant increase, and City of Cape Town: in depth investigation on the matter) that integration with can only really be done at 400 kV. It is essential to Utilities Ankerlig will most likely be at 400 kV and will be dependent on discuss connection points with Eskom as mentioned Directorate: the planned new double circuit 400 kV Ankerlig-Sterrekus 400 kV above. New lines will have to undergo the same EIA Electrical Services line scheduled for completion in 2019. as this one, so this EIA should include these at a high level. Two 400 kV lines will require a 100 m servitude The idea is to obtain authorization for a maximum of 1500 MW. If (assuming 2 separate lines) or about 6om on a it is determined that the electrical infrastructure can only combined multiline tower. capacitate a lower generation, then the authorization will still stand.

We will be engaging with yourselves and Eskom on this matter, but please be advised that the issue is being taken forward into the EIA phase and impacts thereof will be considered.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 27 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1.2.4 Issues related to Risks, Hazards & Waste

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 4.1 The above-mentioned documentation received by 2 February Xenthia Smith Thank you for your comments. the Directorate: Pollution and Chemicals 2016; email Management refers. The following comments must Pollution and 1. Noted and agreed. be addressed in the Draft Environmental Impact Chemicals Report (DEIR) and Environmental Management Management 2. Noted and agreed. A detailed plan for action for such Programme (EMP) : events will be outlines in the EMPr which will be Department available for review in the Draft EIA Report. 1. Waste Management Environmental Affairs and a) Removal and disposal of builder’s rubble should Development be done during the construction phase, and this Planning: Western should be recycled if possible or disposed of at a Cape licensed municipal facility, capable of to king in the amount of rubble estimated' b) All waste generated on site, rubble and domestic, must be stored and disposed of in a legally acceptable way. Domestic waste to be disposed of to the municipal landfill site.

2. General

a) Any event reselling in the spill or leak of product into the ground and/or water courses (e.g. that of hazardous substances used during the construction or operational phase) must be reported to oil relevant authorities, including D: PCM within 4 days.

This requirement is in terms of Section 30 { 10) of the National Environmental Management Act, No. 107 of 1 998 (NEMA) and Section 20 (3) of the Notional Water Act,

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 28 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE No. 36 of 998 (NWA) that pertains to the control of emergency incidents and should include the reporting, containment and clean-up procedure of such incident and the remediation of the affected area. All necessary documentation must be completed and submitted within the prescribed timeframes. Containment, clean- up and remediation must commence immediately.

b) All hazardous substances must be stored in a bunded area with a capacity of at least 110% of the maximum allowable volume. The storage of these substances should be fenced and off access controlled. All hazardous wastes must be disposed of using professional waste disposal contractors.

4.2 6.1 The use of natural gas for energy is acceptable in 2 February Mr E. Mohamed Thank you for your comments. the short term, however all opportunities to use 2016; email alternative sources of fuel should be investigated in City of Cape Town: 6.1: Noted and consideration was given to alternative fuel types order to ensure the sustainability of the project. Utilities in the pre-EIA phase. The use of Natural Gas was deemed the Refuse-derived fuel (RDF) and landfill gas are Directorate: Solid most viable for this site and location through thorough examples of said fuel alternatives. Waste Planning feasibility studies. Policy 6.2 As the preferred site/s will be based in Atlantis 6.2: Noted consideration should be given to the fact that the City of Cape Town regional landfill site has been 6.3: Thank you, noted. identified in the same area and the proximity of the landfill site should be included in the EIA.

6.3 As gas recovery from landfill sites are on the Solid Waste Strategy, future opportunity to utilize landfill

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 29 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE gas as a source of fuel may assist with the sustainability of the project whilst simultaneously achieving a strategic goal of the City of Cape Town: Solid Waste Department. 4.3 9.14 Chapter 5. Section 5.2 Issues and Responses Trail 2 February Mr M. Theron / Thank you for your comment. (pg5-7): The required table that indicates the 2016; email Sonja Warnich- anticipated population increase to the Koeberg Stemmet The table has been included on page 3-21, number 3.3.11. Nuclear Power Station's Urgent Protection Zone (UPZ) must be provided in order to test the proposed City of Cape Town: development against the KNPS Traffic Evacuation Environmental Model (TEM). Resource Management

1.2.5 Issues related to EIA and Public Participation

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 5.1 With reference to the above you are requested to 12 January Ms Noluvo Toto Thank you for your comment. make a payment of R300 and submit a NID. 2016; email Your case number is: 16012117. Heritage resource Please see attached letter from Heritage Western Cape management (Appendix H) confirming the presence of no heritage resources NB: It is essential that you ensure that the case Department of on site resulting from the findings of Paleontological and number is used as the bank reference for any Cultural Affairs and Archaeological studies in 2012 that formed part of the Green payment made to us. Failure to do so will determine Sport Technology Manufacturing Cluster Industrial Development EIA that HWC regards your application as unpaid for and Western Cape process. any payment made will be forfeit. Government 5.2 A complaints register must be kept on site during 2 February Xenthia Smith Thank you for your comment. Noted and agreed. the construction phase. The complaints register 2016; Email must specify the date, time, nature of the complaint, Pollution and details of the complainant as well as the responses Chemicals undertaken to adequately address and resolve the Management problems. Department

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 30 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE Environmental Affairs and Development Planning: Western Cape 5.3 The Department agrees that a specialist socio- 2 February Mr C. Hewett Thank you for your comment. economic impact study is not required for this 2016; email development as the scoping report provides City of Cape Town: As indicated in the Scoping Report, the material details of the sufficient information. However, it is requested that Economic proposed project are based on a maximum envelope, or worst- an estimated/projected value of the total capital Development case scenario. In other words, the exact size, and therefore investment for the project be provided in the capital investment, of the project is unknown; save for the fact environmental impact assessment report. that it would not be in excess of 1500MW generation capacity. A further point problematizing the calculation of approximate capital investment, is the fact that potential developers of the site (i.e. private engineering firms in the gas-to-power industry) will competitively bid against each other for the right to develop the proposed project (if Environmental Authorisation is granted). As such, the engineering firms capable of providing estimates on capital investment has a vested interest in not disclosing such figures, as such a disclosure would jeopardise their respective bidding processes.

Accordingly, the EAP, in consultation with the said engineering firms, and with due consideration of the sensitivity of such information, will endeavour to obtain a rough estimate of the project’s’ anticipated capital investment. 5.4 Please reflect the DEA reference number in all future 2 February Mr M. Theron / Application number was not previously stated as the application correspondence. 2016; email Sonja Warnich- had not yet been lodged. The number will be referenced from Stemmet now and throughout.

City of Cape Town: Environmental Resource Management

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 31 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 5.5 Executive Summary, Project overview (pg 3): Only 2 February Mr M. Theron / Noted and included. Option 2' erf number. Portion l and 4 of CFM 1183 is 2016; email Sonja Warnich- listed. However Option 1's erf number. Remainder Stemmet CFM 1183 and Portion 4 of CFM 93, being the alternative site has been omitted. Please include. City of Cape Town: Environmental Resource Management 5.6 Executive Summary, Need for an EIA (pg 4): It is 2 February Mr M. Theron / In terms of Activity 14 (GNR 983), the proposed project involves questioned why Activity 14 of Listing Notice 1 (GN R. 2016; email Sonja Warnich- the continuous piping of natural gas onto site, and thus any 983), i.e. the Storage of Dangerous Good and Stemmet storage related infrastructure and corresponding listed activities Activity 12 of Listing Notice 3 (GN R.985), i.e. the were omitted. Should the need for storage arise, an amendment Removal of more than 30om2 of indigenous City of Cape Town: to the application will be made to include this listed activity. vegetation, are not listed as triggers? Environmental Resource In terms of Listing Notice 3 (GN 985), please see Appendix H Management (Existing environmental authorization for the site), which highlights that the similarly listed activity (GN R546, Activity 12) was approved. 5.7 Executive Summary. Identification of Issues (pg 6): 2 February Mr M. Theron / 1. With regards to the botanical impact, we received In addition to the 3 identified issues, it is argued that 2016; email Sonja Warnich- confirmation from CapeNature regarding the the following additional issues should be identified: Stemmet biodiversity offset already in place for the site, which warrants the absence of another botanical assessment 1. Botanical Impact City of Cape Town: to be done on site (please see Appendix H). The 2. Groundwater Impact Environmental Botanical Assessment done as part of the previous 3. Impact on available municipal infrastructure Resource Environmental Authorization process, is attached as (i.e. Services Report) Management Appendix J.

2. In terms of the groundwater impact, due to the fact that there will be no storage of hazardous substances on site, a separate groundwater specialist study was not deemed to be necessary, however, this impact will be considered in the EIA phase. Please see table 6.4 (Chapter 6).

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 32 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE

3. In terms of the municipal services report, this has been conducted as part of the Environmental Authorizations granted on site (Appendix H), and the services report can be viewed in Appendix I to this report. 5.8 Executive Summary, Identification of Issues (pg 6): 2 February Mr M. Theron / Thank you, corrected. The last paragraph incorrectly refers to the 2016; email Sonja Warnich- proposed Plan of Study (PoS) for the EIA in Chapter Stemmet 9. The PoS is reflected in Chapter 8. City of Cape Town: Environmental Resource Management 5.9 Chapter 1, Introduction, Section 1.1 (pg 1-4): Clarify 2 February Mr M. Theron / Thank you for the correction. that the client is the City of Cape Town: Property 2016; email Sonja Warnich- Management Department. Correct this throughout Stemmet Pg 1-4: Please note it has been stated: “….land owner and the report (example Chapter 1. Section 1.4 page 1-1 1, applicant for the proposed project being the City of Cape Town etc). City of Cape Town: Metropolitan Municipality: Property Management Department Environmental (hereafter referred to as City of Cape Town).” Resource Management 5.10 Chapter 1, Introduction. Section 1.2 Project 2 February Mr M. Theron / Noted and corrected. Motivation (pg 1-4): Paragraph 1 states that ‘the 2016; email Sonja Warnich- project will reduce the risk of rolling electricity Stemmet blackouts, which are anticipated in South Africa '3 Medium Term Risk Mitigation Plan (MTRM) for City of Cape Town: electricity from 2011 to 2016’. As this period is already Environmental past. and given the fact this this project (if Resource successful) will only come only after 2016, this Management motivation becomes obsolete. Please remove. 5.11 Chapter 1, Introduction, Section 1.2 Project 2 February Mr M. Theron / Herein referring to the possible gas-to-power viabilities in the Motivation (pg 1-5): Bullet-point 3 refers to ‘planned 2016; email Sonja Warnich- kudu fields in Namibia. Note this has been changed to construction of a gas fired power station in Stemmet “proposed”.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 33 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE Namibia'. Name the proposed development and reference the source of information. City of Cape Town: Environmental Resource Management 5.12 Chapter 1, Introduction. Section 1.2.1 Need and 2 February Mr M. Theron / Noted, thank you. Desirability (pg 1-6): List under Table 1.1. Section 1, 2016; email Sonja Warnich- the City of Cape Town Spatial Development Stemmet Framework (2012). Refer to Policy Statements 7 and 30 as to reasons why the proposed land use is within City of Cape Town: the spatial development framework's timeframes. Environmental Resource In addition, list the Blaauwberg District Plan (2012). Management Refer to Spatial Development Objective 1) of the Blaauwberg District Plan relating to the promotion of infill industrial development. 5.13 Chapter 1, Introduction, Section 1.2.1 Need and 2 February Mr M. Theron / Thank you, corrected. Desirability (pg 1-9): The statement under Table 1.1, 2016; email Sonja Warnich- Section 9, that there is no exiting EMF is incorrect. Stemmet The City of Cape Town's EMF form part of the Blaauwberg District Plan as adopted on 26 August City of Cape Town: 2013 (PN. 297/2013, dated 13 September 2013). Environmental Resource Management 5.14 Chapter 1. Introduction, Section 1.2.1 Need and 2 February Mr M. Theron / CapeNature did state in that correspondence that existing Desirability (pg 1-9): The statement under Table 1.1, 2016; email Sonja Warnich- studies could also be referred to in this regard. Therefore a Section 11, highlights Cape Nature's confirmation of Stemmet separate avifauna study was not deemed necessary. the proposal; however it omits Cape Nature's concern with regards to potential impacts on City of Cape Town: avifauna as a result of the associated transmission Environmental lines. The report fails to argue why an avifauna study Resource is not warranted. Management 5.15 Chapter 4, Section 4.1, Table 4.1 Listed Activities (pg 2 February Mr M. Theron / Corrected, thank you. Listing Activity 24 (GN 983) was a pre- 4-2): Activity 24 of Listing Notice 1 is incorrectly 2016; email Sonja Warnich- cautionary measure. Although the area is zoned as “industrial”,

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 34 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE indicated under GN R.984. Correct to GN R.983. In Stemmet some parts surrounding the site contain vegetation may need to addition it is questioned why Activity 24 is listed in be removed to construct larger roads. the first instance as the subject properties are City of Cape Town: located within an urban area and should therefore Environmental Please see response 5.6. excluded? Resource Management The Botanical Study has been included as Appendix I to this As mentioned above. is questioned why Activity 14 report. of Listing Notice 1 (ON R. 983), i.e. the Storage of Dangerous Good and Activity 12 of Listing Notice 3 (GN R. 985), i.e. the Removal of more than 30om2 of indigenous vegetation are not listed as triggers?

Reference is made to additional information regarding the removal of [indigenous] vegetation that can be found in the Botanical Impact Assessment conducted by Bergwind Botanical Surveys in 2012. Include the said study as an annexure to the report. 5.16 Chapter 8. Plan of Study, Section 8.5 Issues to be 2 February Mr M. Theron / Due to the studies conducted in the previous BA process, a addressed in the Specialist Studies (pg 8-9): Include 2016; email Sonja Warnich- separate specialist study will not be done for this, however, the the Impact of the proposed development on the Stemmet impacts on the Atlantis aquifer will be considered in the EIA Atlantis Aquifer. phase. Please see table 6.4 (Chapter 6). City of Cape Town: Environmental Resource Management 5.17 Chapter 8, Plan of Study, Section 8.7.3 Risk 2 February Mr M. Theron / Noted and included. Please also see Chapter 3, page 3-22. Assessment (pg 8-12): Include the requirement to 2016; email Sonja Warnich- populate the anticipated population increase to the Stemmet Koeberg Nuclear Power Station's Urgent Protection Zone (UPZ) table under the Terms of Reference. City of Cape Town: Environmental Resource Management

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 35 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 5.18 This Department notes that the focus of this 8 February M. Engelbrecht Thank you for your comment. Environmental Impact Assessment ("EIA") 2016; Fax application is aimed at assessing the suitability of the Department of We are proposing to add listed activities pertaining to power proposed site for the proposed gas-to- power Environmental evacuation and associated infrastructure into the ambit of this facility. It is understood that the pipelines and Affairs and EIA so as to avoid separate EIA applications in the future. powerlines will be subjected to a separate EIA Development application. Planning: Development Management Region 1 5.19 Page 3 of Chapter 3 of the SR states that the co- 8 February M. Engelbrecht Noted, thank you. ordinates for the preferred site have been included 2016; Fax in Chapter 2. However, the co-ordinates have not Department of been included and must be included in the SR to be Environmental submitted to the Competent Authority. Affairs and Development Planning: Development Management Region 1 5.20 This Directorate notes that the heritage impacts 8 February M. Engelbrecht Noted, thank you. were addressed in the aforementioned EIA 2016; Fax application (Reference number: Department of 16/3/1/1/A1/2/3037/12). However, an updated response Environmental from Heritage Western Cape must be provided in Affairs and the EIA Report. Development Planning: Development Management Region 1

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 36 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 5.21 Note that proof of the public participation process 8 February M. Engelbrecht Please see Appendix C- G for proof of the public participation conducted must be provided in the SR to be 2016; Fax process followed as well as Chapter 8. submitted to the Competent Authority. Department of Environmental Affairs and Development Planning: Development Management Region 1 5.22 The 21 digit Surveyor General code of the proposed 8 February M. Engelbrecht Noted. site must be included in the SR to be submitted to 2016; Fax the Competent Authority. Department of Please note this was stipulated on the Application for Environmental Environmental Authorization submitted to the Competent Affairs and Authority. Development Planning: Development Management Region 1 5.23 Please note the originally signed declaration as 8 February M. Engelbrecht Noted. completed by the Applicant, Environmental 2016; Fax Assessment Practitioner and the Specialists who will Department of be compiling the specialist report as part of the EIA Environmental process must be included in the ElAR. Affairs and Development Please note that the activity may not commence Planning: prior to an Environmental Authorization being Development granted by the Competent Authority. Management Region 1 This Directorate reserves the right to revise or withdraw comments or request further information based on any information received.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 37 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1.2.6 Issues related to Biodiversity

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 6.1 CapeNature would like to thank you for the 1 February Rhett Smart; Thank you for your comments & all noted. opportunity to comment on the proposed 2016; Email Scientific Services; development and would like to make the following CapeNature Please see Appendix H: existing EA and Appendix J: Botanical comments. Please note that our comments only Assessment for a more in depth description. pertain to the biodiversity related impacts and not to the overall desirability of the proposed development.

The proposed development entails the acquisition of development rights to develop a gas power project, which will then be provided to an independent power producer. CapeNature did comment on the background information document (BID) for the proposed project, in which we discussed the biodiversity offset process that has been undertaken as part of an approval process for both of the alternative sites for the proposed development.

As a result of the biodiversity offset process described above, the impacts on biodiversity, specifically with respect to loss of habitat were addressed. In terms of the specialist studies proposed for the EIA Phase, there are none related to biodiversity, which CapeNature agrees with due to existing approvals for the properties, along with the biodiversity offset.

CapeNature does however recommend that the EIA Report must include a thorough description of how these impacts have been addressed through the previous application and associated biodiversity offset process. Reference can be made to the

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 38 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE previous studies and subsequent negotiations. This has been briefly described in Section 3.3.8 of the Draft Scoping Report.

In terms of the description of potential freshwater features on the proposed properties, this has been included under 3.3.4 Agricultural Capability and Sensitivity. Reference was made to the botanical specialist study undertaken for the previous approval.

As referred to, the only wetland mapped by NFEPA is the artificial stormwater pond in the south west of Site Alternative 2. However, the Biodiversity Network for the City of Cape Town also mapped a natural wetland in the centre of Site 2. The botanical specialist ground-truthed this feature for the previous study, and only encountered a grassy area with aliens and did not identify it as a wetland. It is assumed that this was based on the species

This Directorate concurs with CapeNature and the 8 February M. Engelbrecht Thank you. City of Cape Town (Environmental Resource 2016; Fax Management) regarding the fact that the botanical Department of The Botanical Assessment has been attached as Appendix J to impacts were addressed in the previous EIA Environmental this report. application for the clearance of indigenous Affairs and vegetation for the development on Portions 1 and 4 Development of Cape Farm No. 1183 for which Environmental Planning: Authorisation was obtained from this Directorate on Development 16 January 2013 (Reference number: 16/3/ Management 1/1/A1/2/3037/ 12). Therefore, no botanical impact Region 1 assessment will be required as part of this EIA application. However. the manner in which the botanical impacts

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 39 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE were addressed in the previous EIA application must be reported on in the EIA Report.

1.2.7 Issues related to water and wastewater

NO ISSUES RAISED DATE COMMENTATOR RESPONSE

7.1 No service demands related to a land use breakdown 2 February Mr J du Bruyn Noted. The water and sewerage demand will only be able to be have been provided. Hence the current comment 2016, email determined in the EIA phase. provides an over view of the current infrastructure City of Cape Town: capacity and does not address the impact the Utilities Please see Appendix I: Services Report. development may have on the infrastructure. On receiving the water demand Annual Average Daily Directorate: Wafer Demand (AADD) as well as the estimated sewage & Sanitation discharge (Average Dry Weather Flow or ADWF), both measured in kl/day, the comment can be expanded.

A services report should indicate planned pipeline routes so that the physical impact on existing services infrastructure can be determined.

7.2 Water Reticulation 2 February Mr J du Bruyn Noted. Please see response 7.1. 2016, email The reticulation system in the vicinity currently has City of Cape Town: spare capacity w.r.t. residual pressure and flow. The Utilities water demand is required in order to determine whether it can be serviced. Directorate: Wafer & Sanitation

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 40 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 7.3 The proposed development is situated in the 2 February Mr J du Bruyn Noted, Please see response 7.1. catchment of Gideon Basson 2 Pump Station which 2016, email pumps to Westleur Industrial Wastewater Treatment City of Cape Town: Works. This reticulation system in the vicinity Utilities currently has relative spare capacity w.r.t. flow. The sewage flow is required in order to determine Directorate: Wafer whether it can be serviced. & Sanitation

7.4 Bulk Water 2 February Mr J du Bruyn Noted. 2016, email Determination of water resource availability is again City of Cape Town: Please note that in terms of water resource use for the facility, dependant on the AADD being available. Additional Utilities the gas-to-power technology being employed will make use of information on pipeline routes is required in order to an air-cooling system, as this is a water scarce area. determine the possible impact on stormwater Directorate: Wafer recharge system to aquifer. & Sanitation

7.5 Due to the fact that the Atlantis dune plume and 8 February M. Engelbrecht Noted. Witsand Aquifer Nature Reserve is located within 2016; Fax 2.5km west of the site and may be impacted by the Department of Please see response 8.3 proposed development, the potential impacts on the Environmental aquifer and how it will be minimised must be Affairs and reported on in the EIA Report to be submitted to the Development Competent Authority. Planning: Development Management Region 1

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 41 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 7.6 Wastewater Treatment 2 February Mr J du Bruyn Noted, please see response 7.1. 2016, email Determination of wastewater treatment capacity for City of Cape Town: this development is again dependant on the ADWF Utilities being available. In light of the above the department indicated that a Services Report with more detail on Directorate: Wafer planned layouts and pipeline routes is required. A & Sanitation determination of estimated water demand and sewage discharge must also be included 7.7 The above-mentioned documentation received by 2 February Xenthia Smith Noted. The EMPr which will form part of the Draft EIR will the Directorate: Pollution and Chemicals 2016; Email outline management of contamination and environmental Management refers. The following comments must Pollution and pollution. be addressed in the Draft Environmental Impact Chemicals Report (DEIR) and Environmental Management Management Programme (EMP) : Department Water Management Environmental a) The DEIR and EMP must describe how the Affairs and prevention of the contamination of ground Development water and surface water is to be prevented. Planning: Western Cape

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 42 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1.2.8 Issues related to spatial policy, development planning & transport

NO ISSUES RAISED DATE COMMENTATOR RESPONSE 8.1 Alignment with Spatial Policy and Frameworks 2 February Ms L Steenkamp / Thank you, noted. 2016; email L. Kruger-Fountain The proposed alternative sites align with both the Cape Town Spatial Development Framework (2o12, as City of Cage Town: amended) and the Blaauwberg District Plan (2o12), Spatial Planning 8. which identifies both alternative sites for industrial Urban Design use. In addition Atlantis is well positioned in proximity to the current alternative landing sites for the lbhubesi Gas Fields Pipeline which makes Atlantis a logical location for a combined cycle gas turbine. 8.2 It should be noted that in terms of the above policies, 2 February Ms L Steenkamp / Noted and agreed. the sites are located within 16km of the Koeberg 2016; email L. Kruger-Fountain Nuclear Power Station. As a result development controls related to the Koeberg Nuclear Power City of Cage Town: Station (KNPS) included in the CTSDF and the BDP in Spatial Planning 8. policy 24.4 and section 4.5b respectively, impact on Urban Design the sites. Requirements in this regard should be assessed during the course of the environmental process. 8.3 Additional Impacts to be included in the Proposed 2 February Ms L Steenkamp / Please see response 5.16. Plan of Study: 2016; email L. Kruger-Fountain Please also note contamination will form part of the EMPr which Impacts on the Atlantis Aquifer: The Atlantis City of Cage Town: will be released for review in the Draft EIR. industrial area is located on top of the Atlantis Spatial Planning 8. aquifer. The Atlantis Aquifer Recharge scheme Urban Design In terms of land sterilization, this impact will be assessed in the provides the majority of potable water to Atlantis EIA phase. and is therefore a critical water resource. It is therefore requested that risks associated with the Please see table 6.4 (Chapter 6). potential contamination of this water source as a result of the proposed use must be assessed.

Potential land sterilisation: It is requested that land

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 43 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE sterilisation impacts on surrounding land parcels as a result of any applicable buffers or safety zones should be assessed. 8.4 Option 2 would appear to be the more logical 2 February Ms L Steenkamp / Noted, thank you. location of the current two site alternatives due to its 2016; email L. Kruger-Fountain proximity to the rail access, within the industrial precinct and further away from the Atlantis City of Cage Town: residential area. Spatial Planning 8. Urban Design 8.2 As mentioned during the Background Information 2 February Mr C Lovember Thank you for your comment. Document stage, be advised that the tentative 2016; email preferred site (Option 2) for the power station plant City of Cage Town: Yes, CSIR agrees that a rezoning application is required for the is zoned General Industrial (GI) and not Risk Industry Planning & Building proposed type of development. It would however not be logical (RI). As such the property would have to undergo a Development to embark with rezoning before Environmental Authorisation is formal rezoning application (Note: Eskom was Management granted. As such, the rezoning of the site falls beyond the scope required to undergo a similar rezoning application of the EIA. prior to the establishment of the adjacent Ankerlig Open Cycle Gas Turbine power station). Distribution of the electricity generated by the proposed project falls beyond the scope of this EIA. As indicated in the Scoping Clarity is required as to whether the same distribution Report, only the gas-to-power facility, its supporting power lines, as well as servitudes that Eskom is infrastructure and the transmission lines to evacuate the power currently using, is going to be utilized by this project? from the project site are included in the project description and subsequent assessment. 8.3 The applicant should provide confirmation that they 2 February Mr C Lovember Noted. As the applicant is the City of Cape Town, this can be comply with the Green Technology criteria as per the 2016; email confirmed. Council Policy of Green Technology with regard to City of Cage Town: the Atlantis Industrial Area. Planning & Building Development Management 8.4 It is noticed that the Table indicating the anticipated 2 February Mr C Lovember Please see response 4.3. population increase into the Koeberg Nuclear Power 2016; email Station's (KNPS) Urgent Protection Zone (UPZ) that City of Cage Town: was requested during the Background Information Planning & Building Document stage is not included in the draft Scoping Development

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 44 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

NO ISSUES RAISED DATE COMMENTATOR RESPONSE report. It is reiterated that the said table must be Management provided in order to test the proposed development against the KNPS Traffic Evacuation Model (TEM). 8.5 In paragraph 2.2.4 (page 2 - 7) reference is made to 2 February Mr J Massyn Noted, thank you. negotiations with Transnet with regard to a level 2016; email crossing in order to get access to the site. This City of Cape Town: This has been added. railway line in fact belongs to the City of Cape Town. Transport for Cape Town The proposed access off Neil Hare Road on the northern end of the site necessitates a level crossing across the railway line. This is not supported and access should be taken off Neil Hare Road on the southern boundary or Gideon Basson Road. 8.6 A temporary access across the railway line during the 2 February Mr J Massyn Noted, thank you. construction phase can be considered. 2016; email City of Cape Town: Transport for Cape Town 8.7 A conceptual Stormwater Management Plan in terms 2 February Mr J Massyn A stormwater management plan will form part of the EMPr of Council's relevant policies should form part of the 2016; email which can be reviewed in the Draft EIR. scoping report. City of Cape Town: Transport for Cape Please also see Appendix I. Town 8.8 It is noted that internal roads will be required. Page 7 8 February M. Engelbrecht Thank you, noted. of Chapter 2 of the SR indicates that the proposed 2016; Fax internal roads will be approximately 5m wide. Department of We have included Listed Activity 24 of GN R983 as stated in the However, Page 2 of Chapter 4 of the SR indicates that Environmental report: the proposed project may entail the construction of the proposed internal roads will be approximately Affairs and access roads or roads within the facility that are wider than 8 8m wide. The correct width of the proposed internal Development meters. roads must be provided. If the width of the proposed Planning: roads is less than 8m wide, Activity 24 of (SN No. Development R983 of 04 December 2ol4 will not be applicable. Management Region 1

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 45 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1.3 ISSUES AND RESPONSES TRAIL (DRAFT SCOPING REPORT – OCTOBER 2016)

The section presents the issues raised following the release of the Draft Scoping Report of October 2016, together with a response from the EIA team. A synthesis of issues to be addressed in the Specialist Studies is provided in the Plan of Study for EIA (Chapter 7).

The results of the Specialist Studies will be made available to I&APs for comment as part of the Draft EIA Report. All comments received prior to the release of the Final Scoping Report, through meetings and written correspondence are attached as Appendix E to this report.

NOTE: This Issues and Responses trail is formatted according to a request from the Competent Authority in their comments on the Draft Scoping Report (14th November 2016). Issues and Responses Trails for this process will follow this format here on out.

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP 1.1 14/11/2016 i. Please ensure that all relevant listed activities are applied for, EAP: CSIR thanks the Department for these comments. Each will are specific and that it can be linked to the development be responded to separately as per the numbering in the comment Email activity or infrastructure as described in the project column. description. Department of i. With regards to the listed activities and point (ii), CSIR has

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 46 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP Environmental Affairs: ii. It appears that the study area will be confined to within the submitted an amended application form (dated 24th Integrated urban edge; the EAP must ensure that applicable activities November 2016) to the Department along with this Final Environmental are applied for. The following activities are applicable to Scoping Report. The amendment included the removal of Authorizations areas located outside the urban area edge: GN R983 Activity the following listed activities: 24 and GN R984 Activities 7 and 9.  GN R983 Activity 24 Mr. Sabelo Malaza  GN R984 Activity 7 iii. If the activities applied for in the application form differ from ii. As per the response above, GN R984 Activity 7 was those mentioned in the final SR, an amended application removed (Please see Chapter 4 Table 4.1) as this form must be submitted. Please note that the Department’s proposed project lies within an urban area/industrial application form template has been amended and can be complex. Activity 9 of GN R984 was not removed, as downloaded from the following link although the proposed site is inside an industrial https://www.environment.gov.za/documents/forms. complex/urban area, the powerlines may transverse through rural areas in order to reach the Omega- iv. Please ensure that the application form is signed by the Sterrekus Substation (approximately 13 km south of the applicant and that the land owner consent form has been Atlantis area on the farm Groot Olifantskop 81). signed. iii. As mentioned above, an amended application form has been submitted along with this Final Scoping Report. This v. The EAP must ensure that all relevant activities have been form was downloaded from the recommended website. identified and are included in the application form and will be iv. The application form was signed by the Applicant (CoCT) assessed during the ElAr process. This should also include all who are also the land owners. activities that has been authorised as part of the previous EA v. The activities that were approved as part of the previous for the manufacturing plant, and these must be included and EA were the following (EIA Regulations 18 June 2010): assessed.  GN R544 Activity 38  GN R545 Activity 15 vi. It is note that no GN R. 985 activities have been identified for  GN R546 Activity 12 the proposed development. Should any such activities be  GN R546 Activity 13 identified, they must be thoroughly assessed. Written comments must be obtained from the relevant authorities and submitted to this Department. In addition, a graphical representation of the proposed development within the respective geographical areas must be provided.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 47

DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP vii. The final SR must provide evidence that all identified relevant The similarly listed activities in the 2014 EIA regulations competent authorities have been given an opportunity to were included in the original application form and can be comment on the proposed development. seen in Chapter 4 Table 4.1 namely (following the order of the list above): viii. The Public Participation Report must contain clear and legible  GN R983 Activity 41 copies of the newspaper adverts.  GNR 984 Activity 15  GNR 985 Activity 12 ix. Please ensure that all issues raised and comments received  There is no similarly listed activity for this old during the circulation of the draft SR from registered l&APs listed activity (GN R 984 Activity 15 covers the and organs of state which have jurisdiction in respect of the clearing of more than 20 hectares of land). proposed development are adequately addressed in the Final SR. Proof of correspondence with the various stakeholders Please also note that one listed activity was added, must be included in the Final SR. Should you be unable to namely: obtain comments, proof should be submitted to the  GN R983 Activity 11 Department of the attempts that were made to obtain comments. The Public Participation Process must be vi. This is incorrect; Activity 12 of GN R985 was included conducted in terms of Regulation 39, 40 41, 42, 43 and 44 of in the Draft Scoping Report. It may be possible that the EIA Regulations 2014. this was mistakenly omitted from the original

application form, however, the latest amended x. A comments a response trail report (C&R) must be submitted with the final SR. The C&R report must incorporate all application form (submitted with this report) will historical comments for this development. The C&R report contain this listed activity. Please see Chapter 2 and 3 must be a separate document from the main report and the for a graphical representation of the proposed format must be in the table format as indicated in Annexure 1 project in a geographical context. In addition, the of this comments letter. Applicant (GreenCape) has provided a response to the approach in Appendix O page 49 – very NB for this comment) xi. Further to the above, this Department requires comments vii. Please see Appendix E for Correspondence to I&APs from this Department’s Biodiversity and Conservation Directorate, the Climate Change Directorate as well as the Air and Appendix C for a list of the 84 I&AP’s that were Quality Directorate and the Department of Energy. provided an opportunity to comment.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 48 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP xii. Please provide a description of any identified alternatives for viii. Please see Appendix D for a copy of the Newspaper the proposed activity that are feasible and reasonable, Advertisements. In order to see the date of the including the advantages and disadvantages that the newspaper, a zoomed out tear slip is provided for proposed activity or alternatives will have on the both newspapers as well as a clear copy of the environment and on the community that may be affected by contents of the advertisement, on the page before, the activity as per Appendix 2 of the EIA Regulations, 2014. for each (English and Afrikaans). Alternatively, you should submit written proof of an ix. Please see Appendix E for proof of correspondence investigation and motivation if no reasonable or feasible to I&APs for the Draft Scoping Report of December alternatives exist in terms of Appendix 2. 2015 and October 2016. x. Please consult this Appendix (Appendix H) for all xiii. It is noted with concern that the LNG supply for the historical comments and responses for this process. proposed development depends on the finalisation of the The latest comments table has been updated to the proposed gas pipeline between Saldanha Bay and the Caltex desired format and all Comments and Responses Tableview Refinery. This may present a fatal flaw for the Trails will follow this format here on out. development as essentially there is no gas for the facility. The xi. The EAP only received comments from the applicant is therefore advised to identify other gas supply Biodiversity Directorate (see below). Proof that the alternatives and clearly assess all associated impacts. other Directorates were consulted can be seen in Appendix E (courier waybill slips and follow up emails xiv. Should the applicant insist on the LNG supply from the sent by EAP). The Department of Energy is on the proposed gas pipeline between Saldanha Bay and the Caltex I&AP database and has received communication Tableview Refinery, the FSR must clearly identify the regarding this project throughout. preferred connection route and indicate the terms of xii. Please see Chapter 5 for Alternatives including inserts reference for assessment of all associated impacts. from the Environmental Screening Study conducted for this project in order to do site screening. This provides detailed information on which site was xv. The FSR must clearly indicate information on services more suitable from an environmental, social and required on the site, e.g. sewage, refuse removal, water and technical perspective. electricity.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 49 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP xvi. It is noted that the study area was subjected to specialist A map and table (5.4.3) indicating nearby human assessments under a previous EIA process which were attributes clearly highlights the selected site poses recommended by specialists and subsequently authorised. less threat to the Atlantis community that the The FSR must include impact statements from specialists on alternative. Please also see Chapter 1: 1.1.2 for Needs the proposed development and associated impacts. The and desirability of the proposed project. impact xiii. CSIR notes the Departments concern. It is our statements must also comply with comment (xviii) of this respectful submission that the energy supply comments letter for the following specialist studies: relevant to the proposed facility falls beyond the  Terrestrial ecology scope of this EIA process. While the need and  Palaeontology desirability of the said facility needs to be motivated  Archaeology. for, as per Appendix 2, regulation 2(f) of the 2014 EIA xvii. This Department advises that a specialist study investigates Regulations; such need and desirability does not and assesses the climate change risks associated with the include, nor require certainty in relation to upstream proposed development. or downstream project requirements. As indicated in this Scoping Report; a gas pipeline is proposed

xviii. The final SR must investigate and identify all possible impacts between the Port of Saldanha and the Caltex including visual impacts and avifaunal impacts. The powerline Tableview refinery and is proposed to supply gas to route alternative must be recommended by a certified ornithologist. the existing Eskom Ankerlig CCGT situated across the road from the proposed Atlantis Gas-to-Power xix. Should the appointed specialists specify contradicting facility. It is manifest that this pipeline is integral to recommendations, the EAP must clearly indicate the most the long-term existence of both the Eskom Ankerlig reasonable recommendation and substantiate this with CCGT and the Caltex Tableview refinery. As a result, defendable reasons; and where necessary, include further the likelihood of pipeline construction is considered expertise advice. to be sufficiently probable to justify an application for environmental authorisation. Please see Appendix S page 47 for information re. The pipeline planning from DEA&DP (very important to substantiate our response to this comment) is attached as Appendix S.

APPENDIX H – ISSUES AND RESPONSES TRAIL

pg 50

DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP xx. Where specialist studies are conducted in-house or by a As highlighted in this letter (Page 47 to 48, Appendix specialist other than a certified specialist in the relevant field S), the pipeline is part of Operation Phakisa, and this such specialist reports must be peer reviewed by a certified gas infrastructure is of national significance, which external specialist in the relevant field. The terms of highlights it’s potential for success. reference for the peer review must include: CSIR furthermore submits that in terms of the Spatial  A CV clearly showing expertise of the peer reviewer; and Land-Use Management Act (“SPLUMA”) (Act 16  Acceptability of the terms of reference; of 2013) authorisations related to planning (i.e.  Is the methodology clearly explained and energy-, infrastructure- and spatial planning) acceptable; rightfully vests in the City of Cape Town as the  Evaluate the validity of the findings (review data competent municipal authority. evidence); xiv. As per the above response, the pipeline route for the  Discuss the suitability of the mitigation measures import of gas will not form part of this EIA. In and recommendations; addition, Listed Activity 7 of GNR R 984, which deals  Identify any short comings and mitigation measures with the bulk transportation of gas, was removed to address the short comings; (from the FSR and amended application form) as per  Evaluate the appropriateness of the reference request from the Department (comment ii) and thus literature; will not be assessed in this S&EIA process.  Indicate whether a site-inspection was carried out as xv. Please see Chapter 3, Section 3.3.11 on a description part of the peer review; and of the Municipal Services required. Please also see  Indicate whether the article is well-written and easy Appendix I for a description and run-down of the to understand. Municipal Services in the area. xvi. Please see the first page of Appendices J, K and L for statements from the specialists with regards to this. xvii. Dr. Mark Zunckel (uMoya-Nilu) who is conducting the Air Quality Specialist study for he proposed project will incorporate climate change considerations and impacts into his study, including the impacts of increasing Greenhouse gases on the receiving Environment. Please see Chapter 7 (7.7.1) for ToR’s of this study.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 51 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP xxi. Due to the presence of a similar electricity generation facility xviii. Please see Chapter 6 and table 6.1 for inclusion of in the area, all the specialist assessments must include a visual and avifaunal impacts in the impact cumulative environmental impact assessment for all assessment to be conducted in the EIA phase (note identified and assessed impacts. The cumulative impact this is a very high level scoping assessment and will assessment must indicate the following: be expanded on thoroughly in the EIR). For visual  Identified cumulative impacts must be clearly impacts, please also see Chapter 3, figure 3.13 for the defined, and where possible the size of the identified buffers around the project site and potentially impact must be quantified and indicated, i.e. sensitive receptors. During the ESS conducted for hectares of cumulatively transformed land. this project, it was determined that there will be no  Detailed process flow and proof must be provided, significant visual impacts due to the fact that the site to indicate how the specialist’s recommendations, is zoned for “General Industrial” and is surrounded mitigation measures and conclusions from the by Industrial Buildings and a similar power station various similar developments in the area were taken (Ankerlig Power Station neighbouring). The selected into consideration in the assessment of cumulative site is further away from the community than the impacts and when the conclusion and mitigation alternative (site 1), making it even less visually measures were drafted for this project. intrusive. In addition, the Atlantis Industrial area has  The cumulative impacts significance rating must also been identified as a Special Economic Zone and inform the need and desirability of the proposed earmarked for development, which included a development. number of feasibility studies done by the City of Cape  A cumulative impact significance statement on Town. The location of this site actually has benefits whether the proposed development must proceed. for visual intrusion as opposed to other sites, as it is in the centre of an Industrial area. xxii. The final SR must investigate and identify all traffic impacts and geotechnical impacts associated with the proposed The Department’ request for avifaunal (bird) impacts and a transmission line route to be recommended by development. an ornithologist is noted. Kindly note the following regarding the proposed transmission line route: (1) xxiii. The final Scoping Report must indicate all private and The route already contains an existing 400kV line government nature protection areas in the area, including which connects the neighbouring Eskom Ankerlig any Important Bird Areas. CCGT with the Omega substation (i.e. potential bird impacts will be limited to one area) – See Chapter 2;

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 52 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP xxiv. The final Scoping Report must indicate and describe the (2) This transmission line route has been approved for the competing land uses in the area including the proposed Eskom Ankerlig CCGT in 2008 (i.e. the environmental project. This must further motivate the desirability of locating impact of a transmission line was already considered); (3) the proposed facility at the preferred location. The EIA prepared for the Eskom Ankerlig CCGT found the vegetation along the proposes transmission line route to xxv. In accordance with Appendix 2 of the EIA Regulations 2014, be so severely degraded that the proposed transmission the details of- line development was deemed to have no noticeable (i) the EAP who prepared the report; and impact on terrestrial fauna (i.e. the route is highly (ii) the expertise of the EAP to carry out Scoping and degraded in terms of biodiversity). Environmental Impact assessment procedures; must be submitted. Accordingly, the proposed transmission line route is, objectively speaking; the best practicable environmental xxvi. You are further reminded that the final SR to be submitted to option in terms of the planned transmission line and the this Department must comply with all the requirements in opinion of an ornithologist will have no impact on this terms of the scope of assessment and content of scoping finding. In light of the above, it should also be reports in accordance with Appendix 2 and Regulation 21(1) appreciated that the proposed transmission line route is of the EIA Regulations, 2014. not merely the product of one specialist opinion (i.e avifauna), but is rather determined in light of the overall xxvii. Further note that in terms of Regulation 45 of the EIA environmental impact the proposed development is likely Regulations 2014, this application will lapse if the applicant to have. fails to meet any of the timeframes prescribed in terms of the these Regulations, unless an extension has been granted in Therefore, CSIR kindly requests the Department to note terms of Regulation 3(7). that only one transmission line route is being proposed as part of this EIA. Subsequently, no avifauna impact You are hereby reminded of Section 24F of the National statement to motivate for the adoption of a preferred Environmental Management Act, Act No 107 of 1998, as amended, line route will be submitted as only one route is that no activity may commence prior to an environmental proposed. authorisation being granted by the Department.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 53 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP Furthermore, CSIR assumed a risk averse approach whereby a full avifaunal (bird) impact study is proposed in this Scoping Report’s Plan of Study. Given the

environmental realities mentioned above, and

subsequent to extended field work during the EIA-phase, a duly qualified ornithologist may conclude that a full avifaunal impact assessment is not required. However, until proven otherwise, the worst case scenario will be assumed.

xix. This is noted. xx. This is noted, however, there are no specialist studies being conducted in-house or by an “uncertified” specialist. Please see Chapter 7, table 7.5 for a list of the specialists involved in this S&EIA process. xxi. Please see Chapter 7 for ToR’s of the Specialist Studies (7.4.1). In addition, please see Chapter 6 (6.2.9) for the high level scoping assessment of the potential cumulative impacts. The EIA phase will include the following for the specialist studies:  Where possible, the size of the identified impact must be quantified and indicated, i.e. hectares of cumulatively transformed land.  Detailed process flow and proof must be provided, to indicate how the specialists recommendations, mitigation measures and conclusions from the various similar developments in the area were taken into consideration.  Cumulative impacts significance rating must also inform the need and desirability of the proposed development.  A cumulative impact significance statement on whether

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 54 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP the proposed development must proceed xxii. Please see Chapter 6, Table 6.1 for inclusion of traffic impacts in the impact assessment to be conducted in

the EIA phase (note this is a very high level scoping

assessment and will be expanded on thoroughly in the EIR). In addition, a high level assessment of traffic impacts has been included in Chapter 6 (6.2.9). In terms of geo-technical impacts, due to the fact that the proposed project will not entail excavation of any sort (other than establishing the foundations),

geotechnical considerations will only be introduced

in the engineering and design phase. The Services Report, done as part of the 2012 BA process for this site (Appendix I) contains information regarding topography, geology and the AWRMS.

Furthermore, similar structures are located in very close proximity (<1 km radius) to the proposed facility (i.e. the Ankerlig CCGT). During the construction of

these facilities, no special geotechnical challenges

were reported. Accordingly, it is highly unlikely that the local geology under the proposed site will be noticeably different from the geology in close proximity to the proposed site. Accordingly, geotechnical impacts cannot reasonably be

considered as a ‘significant impact’ in terms of

regulation 1 of the 2014 EIA Regulations.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 55 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP xxiii. Please see Chapter 3, Section 3.3.7.1 for a description of the nature protection areas in the area as well as other conservation information (including maps).

xxiv. Please see Chapter 3, section 3.3.4 to 3.3.8 for a

description of the types of land uses in the area, as well as Chapter 1, Table 1.2.1 for a very in depth needs and Desirability Assessment for the proposed project. xxv. Please see Appendix A and B. xxvi. Please see Chapter 1, Table 1.3 for all the

requirements of a Scoping Report in terms of

Appendix 2 of the EIA Regulations and where each can be found in this Final Scoping Report. xxvii. Thank you, noted. Please also note that the Application for EA was submitted on the 18th October 2016 (Please see courier waybill signed In Appendix E, Page 36). Therefore the EAP is required to submit

the FSR 44 days after this date (days begin counting th the day after, which is the 19 ) which brings the st submission date of the FSR to 1 December 2016.

(end of responses to this commenter)

1.2 15/11/2016 For the directorate biodiversity conservation to make an informed decision, the following recommendations must be included on the Email final EIA phase and be implemented in order to protect the

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 56 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP biodiversity of the area: EAP: CSIR thanks the Department for these comments. Department of Environmental Affairs: i. The extend of the impacts that will be caused by the i. Please see Chapter 6 for a full description of which Biodiversity proposed Atlantis gas to power facility must be explored and impacts will be assessed in the EIA phase as and Conservation explained carefully with all the mitigation measures in place Chapter 7 for a ToR for the specialist studies to be to limit impacts on biodiversity. conducted. Please note: Appendix J contains the Ms. Wilma Lutsch ii. A sensitivity map must be produced and show all the Botanical Assessment which has already been sensitive areas with buffer zones and also indicates all the “no g0 areas" on site. conducted for this site. In addition, Appendix N iii. Avifaunal studies must be conducted by appointed specialist contains information and a report on the Biodiversity to evaluate how they will be impacted by the development. offset which is already in place for the entire Atlantis iv. The artificial NFEPA wetland is a habitat to water birds Industrial Area, including the proposed project site. species and other species so the functionality of the wetland ii. Please see Chapter 2 for a description of the receiving must be studied and a report must be produced. environment, including excerpts from the v. All sensitive habitats with buffer zones, such as wetlands must be clearly demarcated with fencing or orange mesh Environmental Screening Study that was conducted netting and be regarded as no "go area" and be shown on for the site, showing sensitive area and species of the maps for the final EIAR phase. special concern. Ina addition, the Botanical vi. The proposed development exist close to a number of Assessment Appendix J) will have all the relevant protected areas so comments from authorities of these areas information regarding this. Please note that apart for must be acquired, considered and included on the final the wetland in the bottom left-hand corner of the report. site – the entire site is going to be cleared and no vii. It is recommended that a walk through must be done to confirm any other sensitive habitats on the site and to sensitive species are going to be avoided due to the confirm species of conservation concern and a report must fact that there is a biodiversity offset in place. be included on the final EIAR. iii. Please see Chapter 7 for Avifaunal Study ToR. viii. It is recommended that final Ecological Report and Avifaunal iv. This wetland is not going to be removed or specialist report must be submitted together with a full constructed upon/in. Therefore it will remain intact. layout plan overlaid with the development footprint and v. Noted. sensitive areas to allow the directorate to make an informed vi. Please see Please see Chapter 3, Section 3.3.7.1 for a decision. ix. The following mitigation hierarchy 1. Avoid 2. Minimise, 3. description of the nature protection areas in the area

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 57 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP Restoration, 4. Offset must be followed in this order as well as other conservation information (including throughout the planning of the development. maps). Please note that CapeNature has submitted x. Clear layout plan overlaying all sensitive areas within the comment for this project and has no objection – development footprint EMPr must be attached and it must Appendix N. show all the mitigation measures proposed on site to limit

impacts on the receiving environment and it must show all vii. The Ecological Report has already been conducted; the rehabilitation plans. however, the Avifaunal study will assess the powerline route to be used as well as the footprint of CONCLUSION the entire site- as the entire site is going to be cleared. The proposed development will have impacts on important species viii. Noted. and about 38 hectares of vegetation will be impacted so the extent to ix. Please see Chapter 3 for a map of the sensitive which the biodiversity of the area will be impacted must be clearly studied and proper planning and mitigation measures should be features on site overlaid onto the project site area. applied. The proposed site is of national importance due to the protected vegetation on site, NFEPA wetland and species of Please note: all considerations in terms of biodiversity have been conservation concern occurring on site. The layout plan with the lay made with the security that there is a finalized (and audited) down areas of the project must be designed to avoid all sensitive biodiversity offset in place for the entire Atlantis area (Appendix areas on site as far as possible. N). The botanical specialist and CapeNature are in agreement with this approach highlighting that the impacts of removing the vegetation and faunal habitat would be compensated for by the offset, which is actually “a gain for biodiversity conservation” (Appendix J, Page 26).

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 58 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF NO COMMENT RESPONSE FROM EAP/APPLICANT/SPECIALIST COMMENT, NAME OF ORGANIZATION/I&AP 1.3 26/10/2016 The draft Scoping Report dated October 2016 and received by this EAP: Thank you for the acknowledgement of the receipt of the Department on 19 October 2016, refers. Draft Scoping Report, we will await your comments to be received Letter before 17th November 2016. i. This letter serves as an acknowledgement of receipt of Western Cape the draft Scoping Report by this Directorate. Department of ii. This Directorate will now review the draft Scoping Environmental Affairs Report and provide comments on the draft Scoping and Development Report accordingly. Planning This Department reserves the right to revise or withdraw comments Head of Department or request further information based on any information received. 1.4 19/10/2016 With reference to the above-mentioned matter, the department EAP: Thank you for your comment. This is duly noted. wishes to inform you that it has no objection against the proposed Letter Atlantis- Gas-to-Power facility. This is on condition that no development will take place on cultivated areas and that Department of rehabilitation is done afterwards. Agriculture, Forestry and Fisheries: Land use This comment does not exempt any person from any provision of any and soil management other law, with special reference to the Conservation of Agricultural Resources Act, 1983 (Act 43 of 1983) and does not purport to Dr. ME Tau interfere with the rights of any person who may have an interest in the agricultural land.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 59 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1.4 ADDENDUM TO THE ISSUES AND RESPONSES TRAIL (DRAFT SCOPING REPORT – OCTOBER 2016)

The section presents the issues raised following the release of the Draft Scoping Report of October 2016, together with a response from the EIA team. A synthesis of issues to be addressed in the Specialist Studies is provided in the Plan of Study for EIA (Chapter 7). The issues raised below were submitted after the closing date of the public comment period (and after the Final Scoping Report was submitted), however, CSIR felt that these authorities are key commenting authorities and their issues should be considered by the Competent Authority making the decision.

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 1 30/11/2016 The Draft Scoping Report (“DSR”) and Plan of Study for Environmental Impact Assessment EAP: CSIR thanks DEA&DP for (“EIA”) dated 6 October 2016 and received by the Department on 19 October 2016 refer. The these comments. Email following consolidated comment by various directorates in the Department is hereby Responses will following Adri La Meyer offered. numerically according to the Department of comments. Environmental Affairs 2. It is understood that the City of Cape Town proposes the construction of a combined cycle 2. This information is correct and Development gas turbine (“CCGT”) facility on an area of approximately 38.65ha that will consist of: apart from (2.4): please note Planning, Western Cape that the gas pipelines for the Government (DEA&DP) 2.1 Combustion/engine turbines located in power blocks and producing up to a maximum of inflow of gas onto site have 1500 Megawatt; Directorate: been omitted from this EIA. The Development 2.2 Heat recovery steam generators with associated chimneys; transmission lines for power Facilitation evacuation, however, will be 2.3 An electrical generator and administration buildings; and assessed.

2.4 Associated infrastructure (i.e. gas pipelines for the transmission, distribution and 3.1 This is correct. reticulation of natural gas on site and transmission lines for the evacuation of electricity). 3.2 The project overview in the

Draft EIA report will be amended Directorate: Development Management (Region 1) – Keagan-leigh Adriaanse (Keagan- to include this information, [email protected]; Tel: (021) 483 8349): thank you. 3.3.1 The Final Scoping Report showed a “development 3.1 Application history footprint” that will be used 3.1.1 An application for environmental authorisation was submitted to the overlaid onto the project site.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 60 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP Department of Environmental Affairs (“DEA”) on 12 December 2015 along with a Please note that the entire site is DSR; being cleared as there is a biodiversity offset in place for 3.1.2 The Final Scoping Report was submitted to the DEA for consideration on 9 the removal of the vegetation February 2016; for the entire site. 3.1.3 The DEA issued a refusal environmental authorisation on 5 April 2016; 3.3.2 Please note: The proposed 3.1.4 An appeal was submitted to appeal administrator on 26 April 2016 and an project entails the development appeal decision was issued by the appeal authority on 5 July 2016; and of either the gas to power facility or the manufacturing 3.1.5 The appeal decision directed the applicant to resubmit the Scoping Report to facility (should the gas-to-power the DEA for reconsideration inclusive of all specialist studies conducted as part of facility not be feasible), not both the previous EIA application, and to obtain detailed comments from this Department on the same site. The other site on the resubmitted DSR. allocated for development by CoCT may be used for the manufacturing facility. 3.2 Project overview 3.3.3 Please note that the Final 3.2.1 The project overview provided in Chapter 1 of the DSR must be amended to Scoping Report has been include/indicate the following: amended to include the (i) That the applicant obtained an environmental authorisation from this following information pertaining Department on 16 April 2013 (DEA&DP reference 16/3/1/1/A1/2/3036/12) for to this: the proposed development of a green technology manufacturing facility on “Option 1: Integration at the Portions 1 and Portion 4 of Cape Farm No. 1183, Atlantis. The overview must Ankerlig Busbar confirm that this application under review is for the proposed development of a gas-to-power facility and associated infrastructure on the site and that a The first option is that the facility portion of the site is intended to be used for the proposed green will be integrated at the Ankerlig technology manufacturing facility. (Please refer to comment 3.3.4 below for busbar only, as opposed to discrepancies in the property descriptions.) connection to the Omega- Sterrekus Substation. (ii) The project overview must indicate that a copy of the previous Connection at 400 kV may be environmental authorisation obtained is included in Appendix H of the DSR. possible with a loop-in and out as opposed to dedicated

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 61 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 3.3 Activity Description feeders. This may rely on the completion of the planned new 3.3.1 Section 1.1 of the DSR (Project Applicant and Project Overview) states “The double circuit 400 kV Ankerlig- preferred site (i.e. site 2) for the proposed Atlantis gas-to-power project includes Sterrekus 400 kV line (around approximately 38.65ha, however, the proposed gas-to-power facility and associated 2019) to aid with power infrastructure only requires a development area of approximately 32ha (as shown in evacuation under N-2, Chapter 2 of this Scoping Report.” Please be advised that the development footprint considering that this new of the proposed gas-to-power facility has not been provided in Chapter 2 of the DSR. generation will form part of a 3.3.2 The project description must be amended to include the development of the generation pool (Koeberg + gas-to-power facility on approximately 32ha of the site and the development of the Ankerlig). Clarification will be green technology manufacturing facility on the remainder of the site. (Please also gained as to whether the newly refer to comment 3.3.4 below.) built 132 kV busbar is dedicated for the offsite supply or whether 3.3.3 Table 4.1 (page 4-3) of the DSR indicates that “the proposed development will it can be zoned to accommodate result in the need for the existing Omega substation (approximately 13km south of the customers/generators. In Atlantis area on the farm Groot Olifantskop 81) to be expanded”. However, no further summary, integration will most information pertaining to the proposed expansion of the Omega substation has likely be at 400 kV and will be been provided. dependent on the planned new 3.3.4 The cover letter received with the DSR on 19 October 2016 and the DSR indicate double circuit 400 kV Ankerlig- that the CCGT facility and associated infrastructure is proposed on Portion 1 of Sterrekus 400 kV line scheduled Portion 4 of Cape Farm No. 1883, Atlantis. However, Table 4.1 (page 4-3) of the DSR for completion in 2019.” states that “The proposed Gas-to-Power facility will be constructed on Portions 1 and 4 Thus, any information pertaining of Cape Farm 1183 in Atlantis” and Table 6.3 (page 6-9) refers to “Site 2 - Cape Farm to the upgrade of the substation 1183 portions 1 and 4.” Section 2.1 of the DSR indicates the 21 digit Surveyor-General will follow on from the potential (“SG”) code of the preferred site, which provides 2 sets of SG digit codes, assuming new circuit scheduled for to be for Portion 1 and Portion 4 of Cape Farm No. 1183, Atlantis. The Final Scoping completion in 2019. Report to be submitted to the competent authority must indicate what the correct property description is, i.e. whether site 2 (the preferred site) will be located on 3.3.4. The correct portions are Portion 1 and Portion 4 of Cape Farm No. 1183; or on Portion 1 of Portion 4 of Cape Portion 1 and Portion 4 of Cape Farm No. 1183, Atlantis. Farm 1183, and the SG codes in the Draft EIA report as well as

the errors mentioned in your

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 62 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 3.4 Applicable listed activities comment, will be amended accordingly. 3.4.1 Activity 14 of Government Notice (“GN”) No. R. 983 of 4 December 2014 may be triggered by the proposed development. Confirmation of whether dangerous goods 3.4.1 No dangerous goods will be will be stored on the proposed site and the volume thereof (if any) must be provided stored on site, and this is why in the EIA Report. this activity has been omitted. 3.4.2 Activity 28 of GN No. R. 984 of 4 December 2014 will be triggered by the 3.4.2. Please note that this proposed development as an Atmospheric Emissions Licence (“AEL”) in terms of the activity will be included as an National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) amendment to the application (“NEM:AQA”) is required. following the submission of the Air Quality Impact Assessment. 3.4.3 A revised Application Form may have to be submitted to the competent authority upon confirmation of the above-mentioned listed activities. 3.4.3 Please see above, thank you for highlighting this.

3.5.1 Agreed. The EIA report will 3.5 Alternatives investigate technology 3.5.1 According to the DSR, two site alternatives were identified and a site selection alternatives for these sites. matrix was undertaken to determine the preferred location of the proposed 3.6.1 This was included in the development. This includes site 1 (Cape Farm No. 1183 and Portion 93 of Cape Farm FSR, Chapter 6. No. 4, Atlantis) and site 2 (Portion 1 of Portion 4 of Cape Farm No, 1183, Atlantis). It is further noted that site 2 is the preferred site alternative based on the environmental 3.6.2. Noted, thank you. Chapter attributes, spatial character and proximity to sensitive human structures. 7 9Plan of Study) highlights the Alternatives for the generation of electricity from a non-renewable resource have ToR’s for all the studies which been identified, but were considered as not feasible for further assessment. The EIA are being conducted, as well as Report must therefore provide an assessment of the technology alternatives to be the three studies already considered for the proposed development. When selecting the preferred conducted. alternative, please be advised that the alternative with the least environmental 3.6.3. Noted, thank you. impacts must be deemed as the most reasonable and feasible alternative. 3.7.1. Correct.

3.7.2. This will be verified and 3.6 Impact assessment updated. 3.6.1 It is noted that a preliminary scoping phase impact assessment was conducted

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 63 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP based on existing information and the results of this preliminary assessment will be 3.7.3. Correct. Please note that verified by the relevant specialists during the EIA phase. A list of the potential an Avifaunal Assessment is also impacts associated with the proposed development must be provided in the Final going to be conducted to assess Scoping Report to be submitted to the competent authority. the impacts of the transmission lines. 3.6.2 All the potential impacts associated with the proposed development are to be assessed and/or reported on in the EIA Report. 3.8. An Emergency Response Plan will be included in the Draft 3.6.3 A detailed description of storm water and effluent management must be EIA report, which will be able to included in the EIA Report and the Environmental Management Programme be commented on and amended (“EMPr”) must provide suitable prevention/ mitigation measures for these aspects. accordingly.

3.9. The EAP will obtain this 3.7 Specialist reports confirmation in the EIA phase. 3.7.1 It is understood that the following specialist reports (conducted as part of a 3.10.1 Noted, thank you. previous EIA process) will be used to assess some of the potential impacts identified

as part of this EIA application:

(i) Botanical Assessment (compiled by Bergwind Botanical Surveys and Tours, dated June/July 2012); (ii) Paleontological Assessment (compiled by G. Avery, dated July 2012); and (iii) Archaeological Input (compiled by ACO Associates, dated 10 July 2012). 3.7.2 The mentioned specialist reports along with updated statements have been included in the DSR. It is important to note that the specialist reports all refer to the

development on Portion 1 and Portion 4 of Cape Farm No. 1183, Atlantis.

3.7.3 It is further understood that the following specialist assessments will be undertaken as part of the EIA reporting phase, being an Air Quality Impact Assessment; Noise Impact Assessment; and a Risk Assessment.

3.8 Plan of Study for EIA

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 64 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 3.8.1 The Plan of Study for EIA must include the compilation of an Emergency Response Plan (as per the City of Cape Town’s requirements) since the proposed site

is located within the 16km Urgent Protective Zone of the Koeberg nuclear power plant.

3.9 Confirmation of services 3.9.1 Confirmation that the local authority has sufficient, spare unallocated capacity to provide water, sewage disposal, refuse removal and electricity services must be

included in the EIA Report.

3.10 General

3.10.1 The DSR incorrectly refers to this Department’s Guideline on Need and Desirability, 2010. The correct reference is the Guideline on Need and Desirability dated March 2013, which forms part of the EIA Guideline and Information Document

Series (March 2013).

4. Directorate: Waste Management – Gary Arendse ([email protected]; Tel: (021) 483 3872):

4.1 Section 4.2.1 of the DSR must be amended to include the applicability of the National 4.1 This is noted, thank you. Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) and its subordinate Please note no hazardous and/or legislation to the proposed development. Your attention is drawn to GN No. No. 926 of 29 general waste will be stored on November 2013: National Norms and Standards for the Storage of Waste. Please be advised site and this legislation does not that the storage of hazardous and general waste in excess of 80m³ and 100m³ respectively, apply. excluding the storage of waste in lagoons or the temporary storage of such waste, would 4.2 The Draft EMPr will contain require the applicant to comply with said norms and standards. detailed information regarding the disposal and management of

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 65 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP waste. 4.2 The EIA Report must provide detailed information on the volume of waste to be 4.3. Noted, this will be included. generated and how waste from the proposed CCGT plant and associated infrastructure

during the construction and operational phase will be managed. The waste management hierarchy (reduction, re-use and recycling of waste) must be implemented to ensure that the disposal of waste should only be as a last resort. Any resulting waste generated during the

construction/commissioning and operation of the proposed development which cannot be re-used or recycled, must be disposed of at a licensed waste disposal facility.

4.3 The EMPr to be included with the EIA Report must address the prevention and management of potential leaks and spillages of hazardous substances. Any hazardous

substances and fuel must be kept in storage areas that are bunded and with a capacity to contain 110% of the volume of any hazardous substances and fuel. Spill kits must be available on-site for clean-up of potential spills.

5. Directorate: Air Quality Management – Peter Harmse

([email protected]; Tel: (021) 483 8343):

5.1 Noise and dust management: 5.1.1 This is noted and these 5.1.1 The Air Quality Impact Assessment to be undertaken during the EIA phase must impacts will be taken into take cognisance of the National Dust Control Regulations (GN No. R. 827) of 1 consideration. November 2013, promulgated in terms of NEM:AQA. These regulations prohibit a person from conducting any activity in such a way as to give rise to dust in such 5.1.2 The Draft EIA report will quantities and concentrations that the dust or dust fall may have a detrimental include this regulation, as well as effect on the environment, including health. the Draft EMPr. 5.1.2 It is noted that a Noise Impact Assessment will be conducted during the EIA 5.2.1. Odour may be briefly phase. Please be advised that Section 8.7.2 of the Plan of Study for EIA must be discussed in the DEIR, however, amended to indicate that noise generated from the installation and operation of the this is not deemed a significant

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 66 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP CCGT facility (gas turbines/gas engines, electric generators, dry cooling systems, impact in the Scoping Phase. possible rail car noise, etc.) must comply with the Western Cape Noise Control 5.2.2. Please note that an Air Regulations (Provincial Notice 200/2013) of 20 June 2013. Quality Impact Assessment is being conducted for the proposed development. 5.2 Impact management: 5.2.3 Noted, thank you. 5.2.1 The EIA Report must indicate whether the proposed development will result in any offensive odour impacts. Your attention is drawn to Section 35(2) of NEM:AQA, which states that an occupier of the premises must take all reasonable steps to

prevent the emission of any offensive odour caused by any activity at the gas-to- power plant. Any offensive odour complaints must be recorded, reported and investigated, should it be required.

5.2.2 It is expected that possible emissions to air from a gas turbine facility would

include carbon dioxide, water vapour, carbon monoxide, oxides of nitrogen, and minor emissions of metals and metal compounds and organics. 5.2.3 Other emissions of air pollutants are expected from gas venting during commissioning, maintenance shutdowns and from process vents. The Air Quality

Impact Assessment must identify appropriate management and mitigation measures to address the emission sources from the proposed CCGT facility.

5.3 Atmospheric emission listed activities: 5.3.1 Section 4.2.1 of the DSR must be amended to indicate that an AEL is required 5.3.1 This will be included in the and must indicate the atmospheric emission listed activity(ies) that will be triggered DEIR. by the proposed CCGT facility. 5.3.2 Thank you, this will be considered in the specialist study. 5.3.2 The proposed development triggers the following atmospheric emission listed activity identified in GN No. 893, promulgated in terms of Section 21 of NEM:AQA, being Category 1 (Combustion Subcategory 1.4 (Gas Combustion Installations) which

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 67 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP is described as “Gas combustion (including gas turbines burning natural gas) used primarily for steam raising or electricity generation” and is applicable to “All

installations with design capacity equal to or greater than 50MW heat input per unit, based on the lower calorific value of the fuel used”.

5.3.3 The proposed development may also include the storage of petroleum 5.3.3 At the Scoping Level products. It should be noted that Subcategory 2.4 (Storage and Handling of assessment, it is not foreseen Petroleum Products) is applicable to “All permanent immobile liquid storage facilities that any petroleum will be at a single site with a combined storage capacity of greater than 1 000 cubic meters”. stored on site, however, this will The EIA Report must indicate the petroleum storage capacity of the CCGT facility to be investigated further in the EIA determine whether Subcategory 2.4 of GN No. 893 is triggered by the proposed phase. development.

5.3.4. Noted, thank you. 5.3.4 The design and operation of the CCGT facility must comply with the Minimum

Emission Standard as listed under the above-mentioned subcategories. 5.3.5. This comment is being

considered after the Final 5.3.5 Please be advised that in terms of Section 36(5)(c) of the NEM:AQA, 2004 that Scoping Report has been the Minister responsible for environmental affairs is the licensing authority for the submitted to the Competent AEL application. This Directorate strongly recommends that the AEL application be Authority, however, due to the submitted to the licensing authority when the Final Scoping Report is submitted to December shutdown period of the competent authority. the DEA as per the regulations, the EAP will aim to submit the

AEL application with the Draft 6. Please direct all enquiries to the officials indicated in this correspondence should you EIA report, so as to streamline require any clarity on any of the issues/comments provided. the process. 6. Noted, thank you. 7. The Department reserves the right to revise initial comments and request further 7. Noted, thank you. information based on the information received.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 68 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 2 1/12/2016 1. Spatial Planning and Urban Design (Ms L Steenkomp / L. Kruger-Fountain) EAP: CSIR thanks CoCT for these comments. Email 1.1 The Spatial Planning & Urban Design department's previous comment has sufficiently been included in the revised draft scoping report. 1.1 Noted, thank you. Morné Theron 2.1 Thank you for this comment Environmental and and apologies for no prior Heritage Management 2. City of Cape Town: Transport for Cape Town (Mr J Massyn) clarification. A scoping-level Branch-Environmental 2.1 City of Cape Town: Transport for Cape Town (TCT) indicated in the City's previous Traffic Assessment for these Resource Management comment that the proposed access off Neil Hare Road on the northern end of the site which routes has been included in the Department (ERMD) necessitates a level crossing across the railway line, is not supported. TCT indicated that FSR (Chapter 6). Following this City of Cape Town access should be taken off Neil Hare Road on the southern boundary or Gideon Basson Road. comment, we will revise our Municipality This comment by TCT was included in the revised scoping report's comments and responses traffic assessment to consider table, but no response from the EAP is recorded against this comment. these comments in the Draft EIA report.

2.2 The Traffic Assessment 2.2 In addition Chapter 2 (page 2-7) states that the access from the north is preferable whilst (Chapter 6 FSR) stated the it also states that the access from the south is more viable. Conversely if is again stated in the following: Services Report (Appendix I. Section 8.1, page 10) that the preferred access to the site if off Neil Hare Road on the northern end of the site. The aforementioned contradictions are Section 8 of the GIBB report confusing and it should be clarified which access will be used. discusses the proposed road access to this site. The proposed

access roads to be used are 2.3 TCT reiterates that only the access to the site should be taken from the south off Neil showed in Figure 6.2 below. The Hare Road or Gideon Basson Road. The primary reason for a southern access point being that preferred access onto the local it will eliminate the railway crossing. road network will be at the northern end of the site onto

Neil Hare Road. Neil Hare Road is 3. City of Cape Town: Specialized Health Services: Air Quality Branch (Ms L. Motthys) linked to Dassenberg Road via an “unnamed” road. The junction 3.1 The revised draft scoping report has sufficiently incorporated the initial comments between the site access and Neil submitted by the Air Quality Branch. As such the Branch is satisfied with the initial impacts Hare Road, as well as the identified by the EAP and included in the proposed Plan of Study for the EIA. junction of Neil Hare Road and

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 69 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP “unnamed” road and “unnamed” road and 4. City of Cape Town: Economic Development (Mr C. Hewett) Dassenberg Road will all have to be widened to accommodate the sweep area for extra-large 4.1 The Department indicated that it is satisfied with the EAP's response to its comments on vehicle turning requirement. the initial draft scoping report (DSR) as outlined in chapter 5 of the revised DSR. It is worth to note that the department is fully supportive of renewable energy generation in Atlantis. The The access location from the site City of Cape Town established a green technology manufacturing and renewable energy hub onto Neil Hare Road will result in in Atlantis in 2011 in response to the Department of Energy's Renewable Energy Independent crossing an operational railway Power Producer Programme (REIPPP). Localisation of manufacturing and the resultant job track. A level crossing and right creation is one of the key priorities of government through the REIPP programme. of way servitude will have to be negotiated with Transnet to

facilitate a road over rail level 5. City of Cape Town: Environmental Resource Management (Mr M. Theron) crossing to gain access onto Neil Hare Road. 5.1 It has come to the City of Cape Town's attention that the Surveyor General's office converted all Cape Farms in Atlantis Industrial (which are zoned Industrial) to Atlantis 2.3 As seen above, this Industrial Erven. The City's Corporate 315 system has recently converted all Cape Allotment contradicts the route proposed (CA) or farm numbers, to the new erf numbers. As such the erf numbers reflected in the in the FSR. The access routes will revised draft scoping report are outdated. be re-assessed to consider your comments. 5.1.1 Option 1's new erf number is 171 (was previously Remainder CFM 1183 and Portion 4 of CFM 93): and 3.1 Noted, thank you. 4.1 Noted, thank you. 5.1.2 Option 2's new erf number is 277 (was previously Portion l and 4 of CFM 1 183) 5.1 Thank you for bringing this to our attention; this will be

amended going forward. This 5.2 Chapter 1, Introduction, Locality Map (pg 1-3): Specify the property erf numbers on the will form part of the EA. plans. Site 1 (Erf 171) and Site 2 (Erf 277) for ease of reference. 5.2 This will be amended in the DEIR. 5.3 All other comment on, and/or errors to the previously DSR raised by the Environmental

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 70 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP Resource Management department have adequately been addressed in the revised DSR. 5.3 Noted, thank you, Noted, thank you. The City therefore concurs with the proposed Plan of Study for the EIA phase as well as the Terms of References for the specialist studies. The abovementioned comment must be included in the draft EIR. Kindly submit the draft Environmental Impact Assessment Report (once available) to this office in the form of l x hard copy and l x CD version.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 71 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1.5 DEA’s COMMENTS ON THE FINAL SCOPING REPORT

The section presents the issues raised following the submission of the Final Scoping Report to DEA. A copy of these comments is included in Appendix G of this Draft EIA report.

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 1 01/02/2017 The Scoping Report (SR) and Plan of Study for Environmental Impact Assessment Response from EAP: (PoSEIA) dated November 2016 and received by this Department on 06 January 2017 Email refer. i. Noted. Please see Chapter 6 for the full Impact Assessment. Mr. Sabelo Malaza This Department has evaluated the submitted SR and the PoSEIA dated November ii. Noted. Please Chapter 4 for a list 2016 and is satisfied that the documents comply with the minimum requirements of of the activities applied for. Chief Director: IEA the Environmental Impact Assessment (EIA) Regulations, 2014. The SR is hereby iii. Please see Chapter 2, Section 2 accepted by the Department in terms of Regulation 22(a) of the EIA Regulations, Department of 2014. where this table provided by Environmental Affairs DEA has been included. You may proceed with the EIA process in accordance with the tasks contemplated in iv. Please see Chapter 2, Section 2.1 the PoSEIA and the requirements of the EIA Regulations, 2014. for the corner co-ordinates of the site, as well as Chapter 2 for All comments and recommendations made by all stakeholders and Interested and a map indicating the corner co- Affected Parties (I&APs) in the draft SR and submitted as part of the final SR must be taken into consideration when preparing an Environmental Impact Assessment ordinates of the site. Please note report (EIAr) in respect of the proposed development. Please ensure that all that all this GIS information as mitigation measures and recommendations in the specialist studies are addressed requested has also been and included in the final EIAr and Environmental Management Programme (EMPr). submitted electronically on a CD to DEA along with this report. Please ensure that comments from all relevant stakeholders are submitted to the v. Please see Chapter 2 for a map Department with the final EIAr. This includes but is not limited to the Western Cape of the proposed layout of the Department of Environmental Affairs and Development Planning, the Department of Agriculture, Forestry and Fisheries (DAFF), the provincial Department of Agriculture, facility drawn to scale, and

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 72 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP SENTECH, the Department of Transport, the Department of Water and Sanitation Chapter 2 for a description of all (DWS), the South African National Roads Agency Limited (SANRAL), the South associated infrastructure. African Heritage Resources Agency (SAHRA), the Endangered Wildlife Trust (EWT), vi. This Appendix H of the report BirdLife SA, the Department of Mineral Resources, Cape Nature and the Department (Appendix H) provides a detailed of Environmental Affairs: Air Quality Management and Biodiversity and Conservation Directorates. comments and responses report for the scoping phase (and all You are also required to address all issues raised by Organs of State and l&APs prior iterations of the scoping reports to the submission of the EIAr to the Department. to date) and the process up to date. Please ensure that the EIAr and EMPr comply with Appendix 3 and Appendix 4 of vii. Please see Chapter 4 Regulation 2014, before submission to the Department. You are also required to highlighting the public address all issues raised by organs of state and l&APs prior to the submission of the ElAr to the Department. participation process undertaken for this project to Proof of correspondence with the various stakeholders must be included in the EIAr. date. Appendices C to H include Should you be unable to obtain comments, proof should be submitted to the proof of the steps taken in the Department of the attempts that were made to obtain comments. PPP. viii. Please see the comments and The EAP must, in order to give effect to Regulation 8, give registered l&APs access responses above and how the to, and an opportunity to comment on the report in writing within 30 days before submitting the final EIAr to the Department. comments on the Draft Scoping Report were addressed. In addition, the following additional information is required for the EIAr: ix. CSIR agrees that long-term planning is desirable for all i. The draft EIAr must provide an assessment of the impacts and environmental management mitigation measures for each of the listed activities applied for. activities. However, we ii. The listed activities represented in the ElAr and the application form must be the same and correct. respectfully submit that it is iii. The EIAr must provide the technical details for the proposed facility in a neither practical, not physically table format as well as their description and/or dimensions. A sample possible to pre-empt potential for the minimum information required is listed under point 2 of the EIA infrastructure and/or technology

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 73 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP information required for gas facilities below. which may, or may not replace iv. The EIAr must provide the four corner coordinate points for the the proposed development in 30 proposed development site (note that if the site has numerous bend years’ time. Firstly, any future points, at each bend point coordinates must be provided) as well as the development of the site, post- start, middle and end point of all linear activities. v. The ElAr must provide clearly indicate the following: decommissioning, is subject to a  The envisioned area for the proposed facility; i.e. placing of all separate and wholly unrelated associated infrastructure should be mapped at an appropriate Environmental Authorisation scale. (EA) application process which  Areas of the facilities to be utilised during the different phases of cannot reasonably be conflated the operation. with the present EA application  Indicate the power output for all phases of the development. to develop a gas-to-power  The preferred layout and length of the 132kV power line. facility. Secondly, the rate of  Description of all associated infrastructure. This description must technological advance, include, but is not limited to the following: o Power lines; particularly within the field of o Internal roads infrastructure; and; energy generation technology, o All supporting onsite infrastructure such as laydown area, precludes the possibility of any guard house and control room etc. reasonably accurate speculation o All necessary details regarding all possible locations and as to future upgrading of the sizes of the proposed satellite substation and the main facility to more advanced substation. vi. The ElAr must also include a comments and response report in technologies. Thirdly, it stands accordance with Appendix 2 h (iii) of the EIA Regulations, 2014. to reason that speculation vii. The EIAr must include the detail inclusive of the PPP in accordance with regarding uncertain future Regulation 41 of the EIA Regulations. developments, unrelated to the viii. The EIAr must adhere to the all the comments issued by this current application, and based Department on the draft SR dated 14 November 2016. on potential future technology; ix. Details of the future plans for the site and infrastructure after should not form part of a facts- decommissioning in 20-30 years and the possibility of upgrading the proposed infrastructure to more advanced technologies. based EIA assessment. Lastly, CSIR is not in a position to

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 74 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP x. The terms of reference (ToR) for the following specialist studies are speculate on the content of accepted to be assessed in the assessment phase: future Integrated Resource Planning (IRP) and Integrated Electricity Planning (IEP) policy NAME ORGANISATION ROLE/STUDY TO BE documents which would UNDERTAKEN ultimately determine whether Mr Mark Zunckel uMoyo-Nilu Consulting Air Quality Specialist Study the proposed facility should be (Pty) Ltd decommissioned or upgraded Dr Brian Williams SafeTech Noise Impact Study once it reached the end of its Mr. Mike Riscom (Pty) Ltd Risk Assessment operational life. Oberholzer x. Noted. Dr. Graham Avery N/A Palaeontology Study xi. Your attention is respectfully Dr. Lita Webley ACO Associates Archaeology Assessment drawn to Chapter 6 (Traffic) of Dr. David Bergwind Botanical Terrestrial Ecology Study the EIA Report. This section McDonald Surveys and Tours presents the findings of a Mr Chris van Chris van Rooyen Avifauna (birds) previous Traffic Impact Rooyen Consulting Assessment Assessment (TIAs) conducted in connection with proposed industrial-scale developments on xi. A traffic impact assessment must be conducted and included in the Portion 1 of Portion 4 of Cape draft EIAr. The terms of reference for the traffic impact assessment must include: Farms 1183 (i.e. Site 2), and the a. Evaluation of the impacts of the proposed development on existing neighbouring Eskom Ankerlig road network and traffic volumes; Gas-to-Power development. b. Identification of the position and suitability of the preferred access Your attention is further drawn road alternative; to the findings contained under c. Evaluation of the roadway capacity of the road network; the heading “Traffic Impact d. Confirmation of the associated clearances required for the Statement” on page 6-18 of the necessary equipment to be transported from the point of delivery Scoping Report, which states

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 75 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP to the various sites; that, based on the available e. Confirmation of the freight and transport requirements during evidence as per the previous construction, operation and maintenance; traffic studies conducted for the f. Propose origins and destinations of equipment; and two projects quoted above; no g. Determination of (Abnormal) Permit requirements if any. TIA for the proposed Atlantis xii. A social impact assessment must be conducted and included in the draft Gas-to-Power project is required. EIAr. The terms of reference for the social impact assessment must Subsequently, it is the EAP’s include: considered opinion that a SIA is a. A description of the socio-economic context of the area; not required for the present b. A description of the development planning context; application. c. Discussion of the social benefits for the area; xii. Your attention is respectfully d. Identification and assessment of the socio-economic impacts of the proposed development in the area throughout all the phases of the drawn to paragraph 4.10, page development; and 18 of Appendix H to the Scoping e. Recommendation of the mitigation of identified negative impacts Report, which contains the and enhancement of identified positive impacts. Environmental Authorisation xiii. A specialist study must be conducted to investigate and assess the issued by the Western Cape climate change risks associated with the proposed development. Department of Environmental xiv. The air quality assessment must also Identify and predict the significance of direct, indirect and cumulative risks / impacts arising Affairs and Development from the activity for the key stages of the project including Planning (DEADP) for the preconstruction, construction, operation and post-closure; and identify development of a green management and mitigation measures and actions that addresses the manufacturing facility on Portion direct, indirect and cumulative risks and impacts. 1 of Portion 4 of Cape Farms 1183

xv. It is noted that the LNG supply for the proposed development depends (i.e. Site 2). According to on the finalisation of the proposed gas pipeline between Saldanha Bay paragraph 4.10, DEADP already and the Caltex Tableview Refinery, as such, the EIAr must clearly assess the preferred connection route and indicate the terms of reference for considered the impact of an assessment of all associated impacts. industrial-scale development on xvi. The EIAr must clearly indicate information on services required on the the socio-economic conditions site, e.g. sewage, refuse removal, water and electricity.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 76 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP xvii. Where specialist studies are conducted in-house or by a specialist other of the study area, and than a suitably qualified specialist in the relevant field, such specialist subsequently concluded that an reports must be peer reviewed by a suitably qualified external specialist industrial facility, developed on in the relevant field. The terms of reference for the peer review must Portion 1 of Portion 4 of Cape include: a. A CV clearly showing expertise of the peer reviewer; Farms 1183, will not have a b. Acceptability of the terms of reference; detrimental impact socio- c. Is the methodology clearly explained and acceptable; economic impact. On the d. Evaluate the validity of the findings (review data evidence); contrary, DEADP finds that such e. Discuss the suitability of the mitigation measures and a development will have an recommendations; employment creation and f. Identify any short comings and mitigation measures to address the economic growth benefit to the short comings; g. Evaluate the appropriateness of the reference literature; larger Atlantis area. h. Indicate whether a site-inspection was carried out as part of the Subsequently, it is the EAP’s peer review; and considered opinion that a SIA is i. Indicate whether the article is well-written and easy to understand. not required for the present xviii. Should the appointed specialists specify contradicting application. recommendations, the EAP must clearly indicate the most reasonable xiii. Please note that the ToR for the recommendation and substantiate this with defendable reasons; and Air Quality Specialist study was where necessary, include further expertise advice. xix. It is imperative that a reliable water source is secured for the success of amended to include climate this project. The Department requests proof of availability of water for change impacts for the the facility from the relevant authority. proposed project. Please see xx. The ElAr must adequately assess and provide a comparative analysis for Appendix M for the Air Quality alternative water sources for the proposed development. The preferred and Climate Change Specialist water source alternative must further motivate the preferred Study. technology choice for the facility.

xxi. A cumulative assessment must be undertaken for the sourcing of water xiv. Please see the impact as the facility is located in a water stressed area. assessment section of Appendix xxii. The ElAr must assess the impacts of use of water on site (sourcing, M. treating, disposing etc.) xv. The gas supply pipeline does not

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 77 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP xxiii. The ElAr must provide a detailed description of the need and form part of this EA application desirability, not only providing motivation on the need for clean energy and is not part of the proposed in South Africa of the proposed activity. The need and desirability must project infrastructure. It is also indicate if the proposed development is needed in the region and if therefore our respectful the current proposed location is desirable for the proposed activity compared to other sites. The need and desirability must take into submission that the gas pipeline account cumulative impacts of the proposed development in the area. route and its associated studies xxiv. Due to the presence of a similar electricity generation facility in the fall beyond the scope of this EIA area, all the specialist assessments must include a cumulative process. environmental impact assessment for all identified and assessed xvi. Please see Appendix I for a full impacts. The cumulative impact assessment must indicate the municipal services report for this following: site. A more specific description a. Identified cumulative impacts must be clearly defined, and where possible the size of the identified impact must be quantified and is provided in Chapter 3, Section indicated, i.e. hectares of cumulatively transformed land. 3.3.11. Please note the City of b. Detailed process flow and proof must be provided, to indicate how Cape Town Municipality was the specialists recommendations, mitigation measures and consulted for this information. conclusions from the various similar developments in the area were xvii. There are no specialist studies taken into consideration in the assessment of cumulative impacts conducted in house. Please see and when the conclusion and mitigation measures were drafted for the Appendices pertaining to the this project. c. The cumulative impacts significance rating must also inform the specialist studies which include need and desirability of the proposed development. CV’s. d. A cumulative impact environmental statement on whether the xviii. Noted. proposed development must proceed. xix. Please refer to Appendix M for the municipal services report. xxv. Please note that information on location of renewable energy We would like to strongly developments can be accessed from https://www.environment.gov.za/mapsgraphics. reiterate that the operation of xxvi. A copy of the final site layout map and alternatives. All available this facility will be implementing biodiversity information must be used in the finalisation of the layout a dry-cooling system specifically map. Existing infrastructure must be used as far as possible e.g. roads. due to the fact that this is a

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 78 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP The layout map must indicate the following: water scarce region. Only a. Positions of the power island, steam turbine and generator, fuel domestic water will be needed storage tanks, water storage reservoir and tanks, water and gas and this will be provided by the supply pipelines; municipality. Please refer to b. Permanent laydown area footprint; c. Internal roads indicating width (construction period width and Chapter 2 where it is stated that operation period width) and with dry cooling technology is d. numbered sections between the other site elements which they preferred for this project. serve (to make commenting on sections possible); xx. Please refer to response xix e. Wetlands, drainage lines, rivers, stream and water crossing of roads above and note that this facility and cables indicating the type of bridging structures that will be will be dry cooled. used; xxi. Please refer to response xix f. The location of sensitive environmental features on site eg. CBAs, heritage sites, wetlands, drainage lines etc. that will be affected by above and note that this facility the facility and its associated infrastructure; will be dry cooled. g. Substation(s) and/or transformer(s) sites including their entire xxii. Please refer to Part B: EMPr for a footprint; description of waste and storm h. Connection routes (including pylon positions) to the water management. Appendix distribution/transmission network; M also highlights what municipal i. All existing infrastructure on the site, especially roads; services are prepared for this j. Buffer areas; k. Buildings, including accommodation; and site. l. All “no-go” areas. xxiii. Please see Chapter 1, Table 1.1 xxvii. An environmental sensitivity map indicating environmental sensitive for detailed information on areas and features identified during the EIA process. needs and desirability. xxviii. A map combining the final layout map superimposed (overlain) on the xxiv. Please refer to Chapter 6 for a environmental sensitivity map. full assessment of the xxix. A shapefile of the preferred development layout/footprint must be submitted to this Department. The shapefile must be created using the cumulative impacts for the Hartebeesthoek 94 Datum and the data should be in Decimal Degree proposed project. Format using the WGS 84 Spheroid. The shapefile must include at a xxv. Noted. minimum the following extensions i.e. .shp; .shx; .dbf; .prj; and, .xml xxvi. Please see Chapter 2 for the final

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 79 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP (Metadata file). If specific symbology was assigned to the file, then the site layout map including all the avl and/or the .Iyr file must also be included. Data must be mapped at a listed requirements. scale of 1:10 000 (please specify if an alternative scale was used). The xxvii. Please see Chapter 2 and 3 for an metadata must include a description of the base data used for environmental sensitivity map. digitizing. The shapefile must be submitted in a zip file using the EIA

application reference number as the title. The shape file must be xxviii. Please see Chapter 2 for a map submitted to: layout map superimposed with environmental sensitivities. xxix. Shapefiles with the mentioned Postal Address: requirements are being Department of Environmental Affairs submitted to the Department Private Bag X44? electronically along with this Pretoria 0001 Draft EIA report.

Physical address: EMPr: Environment House 473 Steve Biko Road i – xvii. Please note all of these Pretoria requirements have been included in the EMPr which is attached to this report as For Attention: Muhammad Essop Part B. Integrated Environmental Authorisations Strategic Infrastructure Developments Other responses from the EAP: Telephone Number: (012) 399 9406 Email Address: [email protected]  Please see Heritage Western Cape’s comment on this The Environmental Management Programme (EMPr) to be submitted as part of the application in Appendix Q. ElAr must include the following:  Please see comments below i. All recommendations and mitigation measures recorded in the ElAr and the specialist studies conducted. from Eskom on this project as ii. The final site layout map. requested by DEA in their iii. Measures as dictated by the final site layout map and micro-siting. acceptance of Scoping

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 80 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP iv. An environmental sensitivity map indicating environmental sensitive (01/02/2017). areas and features identified during the EIA process.  Please note that all information v. A map combining the final layout map superimposed (overlain) on the requested in Annexure A of this environmental sensitivity map. letter were submitted to the vi. An alien invasive management plan to be implemented during construction and operation of the facility. The plan must include Department, either mitigation measures to reduce the invasion of alien species and ensure electronically (i.e. the GIS that the continuous monitoring and removal of alien species is information) or herewith undertaken. contained in this report. vii. A plant rescue and protection plan which allows for the maximum transplant of conservation important species from areas to be transformed. This plan must be compiled by a vegetation specialist familiar with the site and be implemented prior to commencement of the construction phase. viii. A re-vegetation and habitat rehabilitation plan to be implemented during the construction and operation of the facility. Restoration must be undertaken as soon as possible after completion of construction activities to reduce the amount of habitat converted at any one time and to speed up the recovery to natural habitats. ix. An open space management plan to be implemented during the construction and operation of the facility. x. A traffic management plan for the site access roads to ensure that no hazards would result from the increased truck traffic and that traffic flow would not be adversely impacted. This plan must include measures to minimize impacts on local commuters e.g. limiting construction vehicles travelling on public roadways during the morning and late afternoon commute time and avoid using roads through densely populated built-up areas so as not to disturb existing retail and commercial operations. xi. A storm water management plan to be implemented during the construction and operation of the facility. The plan must ensure compliance with applicable regulations and prevent off-site migration

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 81 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP of contaminated storm water or increased soil erosion. The plan must include the construction of appropriate design measures that allow surface and subsurface movement of water along drainage lines so as not to impede natural surface and subsurface flows. Drainage measures must promote the dissipation of storm water run-off. xii. A fire management plan to be implemented during the construction and operation of the facility. xiii. An erosion management plan for monitoring and rehabilitating erosion events associated with the facility. Appropriate erosion mitigation must form part of this plan to prevent and reduce the risk of any potential erosion. xiv. An effective monitoring system to detect any leakage or spillage of all hazardous substances during their transportation, handling, use and storage. This must include precautionary measures to limit the possibility of oil and other toxic liquids from entering the soil or storm water systems. xv. Measures to protect hydrological features such as streams, rivers, pans, wetlands, dams and their catchments, and other environmental sensitive areas from construction impacts including the direct or indirect spillage of pollutants. xvi. An air quality management plan. xvii. Emergency preparedness response plan.

The EAP must provide detailed motivation if any of the above requirements is not required by the proposed development and not included in the EMPr.

The EAP must provide the final detailed Site Layout Plan as well as the final EMPr for approval with the final ElAr as this Department needs to make a decision on the EA, EMPr and Layout Plan.

Please ensure that all the relevant Listing Notice activities are applied for, that the Listing Notice activities applied for are specific and that they can be linked to the

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 82 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP development activity or infrastructure in the project description.

You are hereby reminded that should the ElAr fail to comply with the requirements of this acceptance letter, the project will be refused in accordance with Regulation 24t1 Nb) of the EIA Regulations, 2014.

The applicant is hereby reminded to comply with the requirements of Regulation 45 with regard to the time period allowed for complying with the requirements of the Regulations, and Regulations 43 and 44 with regard to the allowance of a comment period for interested and affected parties on all reports submitted to the competent authority for decision-making. The reports referred to are listed in Regulation 43(1).

Furthermore, it must be reiterated that, should an application for Environmental Authorisation be subject to the provisions of Chapter II, Section 38 of the National Heritage Resources Act, Act 25 of 1999, then this Department will not be able to make nor issue a decision in terms of your application for Environmental Authorisation pending a letter from the pertinent heritage authority categorically stating that the application fulfils the requirements of the relevant heritage resources authority as described in Chapter II, Section 38(8) of the National Heritage Resources Act, Act 25 of 1999. Comments from SAHRA and/or the provincial department of heritage must be provided in the ElAr.

You are requested to submit two (2) electronic copies (CD/DVD) and one (1) hard copies of the ElAr to the Department as per Regulation 23(1) of the EIA Regulations, 2014.

Please also find attached information that must be used in the preparation of the ElAr. This will enable the Department to speedily review the ElAr and make a decision on the application.

You are hereby reminded of Section 24F of the National Environmental Management Act, Act No 107 of 1998, as amended, which stipulates that no activity may

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 83 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP commence prior to an Environmental Authorisation being granted by the Department. 2 09/02/2017 I have previously provided feedback to Rudolph du Toit wrt “grid connectivity and capacity”. You were copied in the email. See attached: Email A major project is planned for the Koeberg 400 kV busbar, and that project has been Mr. Ahmed Hansa subjected to many technical hurdles. It is therefore recommended that we consider integration at Ankerlig only. Eskom Grid Planning (Western Cape) Ankerlig has constraints with regards to servitudes and line crossings that will have to be overcome. There are also Eskom plans to increase the generation at this Power Station in the long term.

On the 400 kV side, we have opted to utilise one of the 400/132 kV transformer bays as a feeder bay for the new Ankerlig-Sterrekus Double Circuit Line so 400 kV spare feeder bays are limited, possibly non-existent. Connection at 400 kV may be possible with a loop-in and out as opposed to dedicated feeders. We would possibly have to wait for this double circuit line to be completed to aid with power evacuation under N-2 considering that this new generation will form part of a generation pool (Koeberg + Ankerlig) already exceeding 2000 MW. This is a Grid Code requirement for generation exceeding 1000 MW.

With one transformer bay available, integration at 132 kV will therefore be reliant on a single 400/132 kV 500 MVA transformer which will not suffice for more than 500 MW, a site visit will have to be undertaken to determine the availability of space for a second transformer, possibly a third. We also have to avoid crossing a planned 132 kV dedicated offsite supply line for Koeberg. This makes access to the substation very restrictive, a cable solution may have to be evaluated at 132 kV if this is a preferred integration option which is quite unlikely. We may also need clarification as to whether the newly built 132 kV busbar is dedicated for the offsite supply or whether it can zoned to accommodate customers/generators. Nonetheless, it will require 400/132 kV transformation.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 84 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP

In summary, integration will most likely be at 400 kV and will be dependent on the planned new double circuit 400 kV Ankerlig-Sterrekus 400 kV line scheduled for completion in 2019.

Additional information pertaining to you query can be sourced from the following: The Grid Connection Capacity Assessment of the 2022 Transmission Network (GCCA- 2022) document will help you to establish the available capacity across the national grid for the connection of new generation at the substations on the Eskom transmission network that may be in service by 2022 based on both approved and proposed new transmission infrastructure projects. The GCCA-2022 includes all of the projects that are expected to be completed by 2022 as contained in the Transmission Development Plan (TDP) for the period 2015-2024 (issued in October 2014). This is to provide developers and investors with an indication of the potential available capacity for the connection of new generation at or within the supply areas of the transmission substations on the Eskom transmission network by 2022 based on the 2014 TDP.

You may also find additional information related to your query in the current version of the TDP (2016-2025) (released in October 2015).

Should you require additional information to that contained in the above, kindly contact the Grid Access Unit (GAU) with regards to a formal application.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 85 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

1.6 COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT (version 1 of 22 nd March 2017)

The section presents the issues raised following the submission of the Draft Environmental Impact Report (DEIR) for public comment from the 22nd March 2017 to the 24th April 2017. A copy of these comments is included in Appendix G of this Draft EIA report.

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 1 21/04/2017 This Department has the following comments on the abovementioned application: Thank you for the comments.

Email i. Please ensure that all relevant listed activities are applied for, are specific and i. Please see listed activities in Chapter 2 that it can be linked to the development activity or infrastructure as described in and how they relate to the project Mr. Sabelo Malaza the project description. description. ii. If the activities applied for in the application form differ from those mentioned ii. As of this version, the listed activities Chief Director: IEA in the final EIAr, an amended application form must be submitted. Please note included herein are the same as the that the Department's application form template has been amended and can be Department of downloaded from the following link application form which was Environmental Affairs https//wwwenvironment.gov.za.documents/forms. submitted on the 20 March 2017. iii. Please ensure that all issues raised and comments received during the circulation iii. All comments received on the first of the draft ElAr from registered I&APs and organs of state which have version of the DEIAR are included in jurisdiction (including this Department’s Biodiversity Section) in respect of the this section with their responses. proposed activity are adequately addressed and included in the final ElAr. Proof Please also see Chapter E for proof of of correspondence with the various stakeholders must be included in the final ElAr. Should you be unable to obtain comments, proof should be submitted to correspondence and Chapter G for the Department of the attempts that were made to obtain comments. The copies of comments from I&APs. If Public Participation Process must be conducted in terms of Regulation 39, 40 41, any new comments are received on 42, 43 and 44 of the HA Regulations 2014 as amended. Version 2 of the DEIAR (this version) iv. A Comments and Response trail report (C&R) must be submitted with the final they will also be included in the ElAr. The C&R report must incorporate all historical comments for this FEIAR. development. The C&R report must be a separate document from the main iv. This section of the report (Appendix report and the format must be in the table format as indicated in Annexure 1 of this comments letter. Please refrain from summarising comments made by H) contains all historical comments I&APs. All comments from I&APs must be copied verbatim and responded to from I&APs throughout this process,

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 86 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP clearly. Please note that a response such as “noted" is not regarded as an and the FEIAR will include all the adequate response to l&AP's comments comments from the two versions of v. Please note that the final ElAr must comply with all conditions of the acceptance the DSR as well as both versions of of the scoping report (SR) signed on 01 February 2017 and must address all the DEIAR. comments contained in the final SR and this letter. The Department notes with

concern that the draft ElAr does not contain all requested information and that v. Please see all responses to the the EAP's reaponses to this request has been “that the requested information acceptance of scoping as well as the falls outside the scope of this EIA process.” This is unacceptable and the EAP is responses in this table to the DEIAR. strongly advised to ensure that the final EIAr complies with the acceptance of The response will direct the reader to the SR, and your attention is drawn to Appendix 3, 3(v) of the EIA Regulations, the relevant section of the report 2014 as amended, for ease of reference. where more information is contained. vi. The Atlantis Sand Fynbos (Critically Endangered) and the Cape Flats Dune vi. Please see the EMPr (Part B) which Strandveld (Endangered) vegetation types will be affected by the development. In addition to the offset plan, the Department requires the EAP to provide has been updated to include a plant additional mitigation measures for the protection of sensitive species on the rescue and protection plan. development site. As such, the Department requires that a plant rescue and vii. Please see comments from the CoCT protection plan form part of the final EIAr. on the DEIR version 1 below vii. The preferred site is located within the 5-16km Urgent Protection Zone (UPZ) (24/04/2017) – Comment and boundary of the Koeberg Nuclear Power Station (KNPS). This will result in response number 2. The City of Cape increased movement of people and vehicles within the UPZ. The Department Town, who has jurisdiction over the notes that no further information is provided in the draft EIAr, nor the Risk Assessment Report regarding the implications of the results from the KNPS KNPS UPZ, has approved the TEM Traffic Evacuation Model (TEM) and any relevant mitigation measures. model for this project which was viii. The motivation provided for not including an emergency and preparedness and included in Chapter 3. response plan with the EMPr is not accepted due to the possible risk associated viii. Please see the EMPr (Part B) which with the facility and location within the UPZ. The EAP is advised to include an has been updated to include an emergency and evacuation plan with the final EIAr. The following information emergency preparedness measures in must form part of the plan: the specific project related mitigation  Identification of areas where accidents and emergency situations may occur; measures section.  Communities and individuals that may be impacted; ix. Please see the EMPr (Part B) which

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 87 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP  Response procedure; has been updated to include  Designation of responsibilities; alien/invasive plant management  Communication line; and report; plant rescue and protection  Training schedule to ensure effective response to potentially affected report; and re-vegetation and habitat communities. rehabilitation report. ix. The EMPr must include a provision to make the following reports available to x. The most recent guideline have been the Department and applicable competent authority on request: alien/invasive plant management report; plant rescue and protection report; and re-vegetation adhered to. and habitat rehabilitation report. xi. This comment and concern by the x. Please ensure that all mitigation recommendations are in line with applicable Department is noted, but the EAP and most recent guidelines. would like to respectfully re-iterate xi. This Department reiterates that the preferred connection route for the gas the following re. the pipeline pipeline must be identified and impacts thereof assessed in the final EIAr. This connection: Department does not accept the response provided by the EAP in the draft EIAr as this is a huge information gap and may result in an uninformed decision being  The construction of the pipeline made by the Department. (estimated for 2020) does not xii. Should there be any other similar projects within a 3okm radius of the proposed affect the viability of the development site, the cumulative impact assessment for all identified and proposed project, as gas can be assessed impacts must be refined to indicate the following: trucked in until such a pipeline is  Identified cumulative impacts must be clearly defined, and where possible determined. The trucking in of the size of the identified impact must be quantified and indicated, i.e. gas has been discussed and the hectares of cumulatively transformed land.  Detailed process flow and proof must be provided, to indicate how the impacts thereof assessed in the specialists recommendations, mitigation measures and conclusions from the Traffic Impact Study (Appendix various similar developments in the area were taken into consideration in T). Thus, pipeline aside, the the assessment of cumulative impacts and when the conclusion and proposed project is economically mitigation measures were drafted for this project. and logistically viable and there  The cumulative impacts significance rating must also inform the need and should not be cause for an desirability of the proposed development. information gap.  A cumulative impact environmental statement on whether the proposed development must proceed.  The proponent (or applicant) for

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 88 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP xiii. The EIAr must provide the technical details for the proposed facility in a table the gas pipeline will in all format as well as their description and/or dimensions. probability be another entity xiv. The preferred Layout Plan with the preferred substation, service routes, existing other than the CoCT (applicant roads and new roads, and construction camp must be indicated in the final EIAr. for this project) thus it does not A map combining the final Layout Plan superimposed (overlain) on the environmental sensitivity map must also be included in the final EIAr. fall upon this applicant to xv. The ElAr must clearly indicate the following: conduct an EIA for the pipeline,  The envisioned area for the proposed facility; to placing of all associated which will only potentially be infrastructure should be mapped at an appropriate scale. constructed in 2020.  The preferred layout and length of the evacuation powerline.  In addition, as this applicant is not  Description of all associated infrastructure. This description must include, the proponent for the pipeline, but is not limited to the following: they are not responsible for the o Powerlines; route and technical information, o Access and internal roads infrastructure; and o All supporting onsite infrastructure such as laydown area, guard and would not be able to assess house and control room. the impacts thereof at this early xvi. A copy of the final site layout map must be submitted with the ElAr. All available on in the process. Should the biodiversity information must be used in the finalisation of the layout map. pipeline be constructed, an EIA Existing infrastructure must be used as far as possible e.g. roads. The layout map by the entity responsible for it must indicate the following: will be conducted and the  Positions of the power island, steam turbine and generator, fuel storage impacts thereof assessed. tanks, water storage reservoir and tanks, water and gas supply pipelines;  Permanent laydown area footprint;  Your attention is respectfully  lntemal roads indicating width (construction period width and operation drawn to Appendix S Page 40, period width) and with numbered sections between the other site elements where the Western Cape which they serve (to make commenting on sections possible); Department of Economic  Access route; Development and Tourism have  Wetlands, drainage lines, rivers, stream and water crossing of roads and discussed the LNG import and the cables indicating the type of bridging structures that will be used; pipeline infrastructure, and the  The location of sensitive environmental features on site e.g. CBAs, heritage sites, wetlands, drainage lines etc. that will be affected by the facility and its studies that have been

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 89 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP associated infrastructure; commissioned. There is also a link  Substation(s) and/or transformer(s) sites including their entire footprint; in this letter to the EIA screening  Connection routes (including pylon positions) to the that this Department has done distribution/transmission network; for the proposed pipeline.  All existing infrastructure on the site, especially roads;  It is for the above reasons that it  Buffer areas; is not possible for the applicant  Buildings; and  All “no-go” areas. to conduct an impact assessment for the pipeline, as they are not xvii. Please ensure that all hardcopy and softcopy maps are clear and legible. the proponent driving this Hardcopy maps must be at least A3 size. infrastructure and process. As xviii. The EAP is further requested to ensure that the electronic version of the mentioned above, it does not final ElAr is one concise pdf file, and not separate chapters to ensure a smooth affect the viability, as trucking and efficient review of the report. has been proposed and assessed. xix. You are further reminded that the final ElAr to be submitted to this Department must comply with all the requirements in terms of the scope of assessment and xii. Please see Chapter 6 for a description content of the ElAr in accordance with Appendix 3 of the EIA Regulations, 2014 of all the similar developments within as amended. the Atlantis Industrial area and a xx. Please also verify the listed activities applied for against the listed activities in description of the cumulative the EIA Regulations 2014 as amended on 7 April 2017. impacts. It must be noted that there xxi. Further note that in terms of Regulation 45 of the EIA Regulations 2014 as is only one gas-to-power facility amended, this application will lapse if the applicant fails to meet any of the timeframes prescribed in terms of these Regulations, unless an extension has within a 30km radius of the proposed been granted in terms of Regulation 3(7). project (Ankerlig Power Station) and xxii. The EAP is requested to contact the Department to make the necessary this has been considered. arrangements to conduct a site visit prior to the submission of the final ElAr. xiii. Please see Table 2.1 in Chapter 2 for this table. You are hereby reminded of Section 24F of the National Environmental Management xiv. Please see Chapter 2 for the Site Act, Act No 107 of 1998, as amended, that no activity may commence prior to an Layout. environmental authorisation being granted by the Department. xv. Please see Chapter 2 for the inclusion

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 90 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP of most of these parameters on the site layout. xvi. See response above. Please note that this comment requires a high level of detail to be mapped and due to time restrictions it could not be added to this version of the report, however, it will be made available in the FEIAR. xvii. All hard copy maps are in A3 and are printed in the finest resolution possible. xviii. Please see minutes of the pre- application meeting (Appendix S) where it was requested by DEA that the electronic CD of the report be split up Chapter by Chapter. This new request is now noted and the report will be one PDF file on the CD going forward. Please note that the report is an extremely large file, so the website version has to be split so as to be uploaded to the website. xix. Agreed, thank you. xx. Please note the application form was submitted in March 2017, and thus the listed activities applied for were in line

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 91 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP with the EIA regulations of December 2014. xxi. Thank you this is noted and this response refers to the letter by DEA dated 10 May 2017 where DEA acknowledged an extension to 156 days as per regulation 23(1) and 23(2) of the NEMA EIA regulations (as amended, 2017). xxii. Please see Appendix S for proof of request by the EAP for DEA to provide a suitable date for a site visits, with no response. Please note that a site visit can be conducted in a later stage (i.e. once the FEIAR has been submitted) should DEA feel they would like one.

Thank you for your comments. Please submit any additional comments on this version of the DEIAR (version 2) if need be.

2 24/04/2017 Thank you for your comments. Your 1. The Draft Scoping Report (“DSR”) dated October 2016, the Department’s comments will be responded to as per Email comments thereto dated 30 November 2016 and the Draft Environmental the numbering in your letter. Please note Impact Assessment (“EIA”) Report dated March 2017 that was received by the for clarification of the response Adri La Meyer Department on 20 March 2017, refer. The following consolidated comment from various directorates in the Department is hereby offered. numbering that only the “comments”

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 92 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP Directorate: will be responded to, as some of the Development 2. Directorate: Development Management (Region 1) – Keagan-leigh Adriaanse points are written as facts (i.e. 2.2.1). Facilitation ([email protected]; Tel: (021) 483 3763): 2.1 Activity Description 2.1.1 Please see updated EMPr as Department of 2.1.1 A detailed description of storm water management was not provided in the Part B to this report for a Draft EIA Report and must be included in the Final EIA Report to be Environmental Affairs Stormwater Management submitted to the competent authority. and Development Plan which highlights that in 2.1.2 This Directorate’s comments on the DSR dated 30 November 2016 indicated Planning that Activity 14 of Government Notice (“GN”) No. R. 983 of 4 December the design phase a detailed 2014 may be triggered by the proposed development. Page 63 of the stormwater plan will be Western Cape Comments and Responses Report (“CRR”) indicates that no dangerous drawn up with approval Government goods will be stored on the site. However, page 2-4 of the Draft EIA Report from CoCT. 3 indicates that 1 x 10 000m storage vessel for the storage of gas and other 2.1.2 The 10 000m3 storage vessel fuels is proposed. In addition, the Atmospheric Impact Assessment Report that has been proposed was (compiled by Umoya-Nilu dated March 2016) and the Risk Assessment (compiled by Riscom (Pty) Ltd dated 16 June 2016) refer to the storage of added to the project approximately 10 000m3 of diesel which may be used during emergencies or description for use in prior to the availability of liquefied natural gas. The Risk Assessment further emergencies. The specialist indicates that a filling station, which will be used to fill company vehicles studies assed this impact with diesel and petrol, was assessed as part of the study. should this be a necessity.

2.1.3 The Environmental Management Programme (“EMPr”) includes mitigation GNR 983 will be applied for measures related to the storage of ammonia, hydrogen and chlorine. in an amended application However, the storage of these substances was not included in the activity description. form with the FEIAR once 2.1.4 A description of the dangerous goods and volumes to be stored on site this has been further must be provided in the activity description. reviewed. Thank you for bringing this to the 2.2 Applicable listed activities attention of the EAP. Please 2.2.1 On 7 April 2017, the Minister of Environmental Affairs made amendments to note that table 2.1 in the EIA Regulations, 2014, published under GN No. R. 982 in Gazette No. Chapter 2 has been updated 38282 of 4 December 2014 in terms of sections 24(5) and 44 of the National Environmental Management Act, 1998 (Act No. 107 of 1998). The to include the storage

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 93 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP amendments to the EIA Regulations of 2014 and its listing notices came into volumes of said substances. effect on 7 April 2017. 2.1.3 Please see response above 2.2.2 The applicable similarly listed activities in terms of the EIA Regulations, 2014 re. dangerous goods on site. (as amended) must be included in the Final EIA Report. 2.1.4 Please see response 2.1.2 2.2.3 Since more than 500m3 of dangerous goods may be stored on the site, Activity 4 of GN No. R. 984 of 4 December 2014, as amended, may be above re. dangerous goods triggered by the proposed development and should be applied for, if on site applicable. 2.2.2 Please see Chapter 4, Table 2.2.4 The road reserve width of the proposed internal roads must be provided. 4.1 for the inclusion of the Should the proposed internal roads have a reserve of less than 13.5m, similarly listed activities in Activity 4 of G No. R. 985, as amended, will be triggered by the proposed the amended EIA development since the proposed site is located outside an urban area and regulations of 7 April 2017. contains indigenous vegetation. 2.2.3 Please see response 2.1.2 2.3 Power evacuation regarding this listed activity. 2.3.1 Two options have been identified for the evacuation of electricity. Page 2-12 2.2.4 Please note that the existing of the Draft EIA Report indicates that the preferred option for power evacuation is road leading into site will be Option 1, which is proposed to integrate at the Ankerlig busbar only. However, the used (See maps in Chapter activity description on page 2-4 of the Draft EIA Report includes the development of 2), additionally this site is a transmission line from the proposed development to the Omega substation, which zoned “Industrial” and lies will be approximately 13km in length (Option 2). Clarity is therefore required. within and Industrial Area, 2.4 Specialist input thus it is not deemed to lie 2.4.1 This Directorate notes that a Traffic Impact Assessment (“TIA”) and Social outside the Urban fringe. Impact Assessment (“SIA”), as requested by the Department of Environmental Affairs (in their correspondence dated 1 February 2017), has 2.3.1 Apologies for this unclear not been undertaken. description, Chapter 2 has been amended 2.4.2 Page 6-56 of the Draft EIA Report refers to a previous traffic assessment in the activity description to further conducted for the Ankerlig power station conversion and transmission highlight that Option 1 is preferred, which integration project (compiled by Savannah Environmental (Pty) Ltd dated is integration at the Ankerlig Busbar. October 2008). Although a traffic assessment was previously undertaken for the development of the Ankerlig power station, the assessment is outdated

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 94 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP and the findings of the previous traffic assessment cannot be directly 2.4.1 Please note that a Traffic Impact applied to the potential traffic impacts associated with the proposed Study has now been undertaken for the development. proposed development, which is why the 2.4.3 Page 6-64 of the Draft EIA Report refers to the environmental authorisation DEIAR has been released for a second issued by this Directorate on 16 January 2013 (reference 16/3/1/1/A1/2/3036/12), which indicates that the green manufacturing facility round of public participation. Please find will not have a detrimental impact on the socio-economic environment. the TIA attached as Appendix T. It must 2.4.4 Although the potential traffic and social impacts were assessed as part of further be noted that a Social Impact the previous EIA application for the development of a green manufacturing Study has not been undertaken for facility, the potential traffic and social impacts associated with the proposed several reasons (however, the socio- gas-to-power facility may result in additional impacts. It is therefore advised economic impacts of the development that a TIA and SIA be conducted for the proposed development. have still been considered in Chapter 6 2.4.5 This Directorate is pleased to note that greenhouse gases and potential impacts on climate change have been reported on as part of the and the EMPr). The further reasoning for Atmospheric Impact Report. this can be found in Chapter 6, section 6.1.8. 2.5 Services 2.5.1 You are reminded that confirmation that the local authority has sufficient, 2.4.2 Please see reponse above, a TIA has spare and unallocated capacity to provide water, sewage disposal, refuse removal been conducted following these and initial electricity services must be obtained and included in the Final EIA Report comments and the impacts have been to be submitted to the competent authority. included in Chapter 6 as well as attached

as Appendix T. 2.6 EMPr 2.6.1 The recommended mitigation measures provided in the Risk Assessment 2.4.4. Please see response 2.4.1 above. must be included in the EMPr. 2.6.2 Page 64 of the EMPr refers to “Outsiders moves into the Kenhardt area”. This 2.5.1. The EAP is in the process of error must be corrected. obtaining this information from the CoCT 2.7 General and this will be included in the FEIAR. 2.7.1 A map of the proposed powerline route must be provided. 2.7.2 This Directorate’s comments on the DSR dated 30 November 2016 indicated 2.6.1 Please see section 9 of the EMPr for that the correct property description for the preferred alternative site must these mitigation measures. Please note

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 95 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP be provided. Page 62 of the CRR indicates that the correct property the EMPr has been updated to include description is Portion 1 of Portion 4 of Cape Farm No. 1183. However, emergency response and preparedness sections of the Draft EIA Report refer to Portion 1 and Portion 4 of Cape measures. Best practise for gas-to-power Farm No. 1183. This error must be corrected. facilities as well as general safety 2.7.3 Page 2-12 of the Draft EIA Report refers to Appendix S, page 47 for important information by DEA&DP regarding the pipeline and pages 56 – 58 precautions have also been included in for information regarding the powerline capacity at Ankerlig. Please be the EMPr. advised that Appendix S ends at page 44. 2.7.4 The information regarding the pipeline is located on pages 40 – 41 of the 2.6.2 Thank you for pointing out this Draft EIA Report and is supplied by the Western Cape Government error, it has been amended. Department of Economic Development and Tourism (and not this Department). 2.7.1. Please see Chapter 2, Figure 2.7. 2.7.5 The information regarding the powerline capacity is located on pages 42 – 44 of the Draft EIA Report. These errors must be corrected. 2.7.2. This error has been corrected, please note that the correct description 3. Directorate: Waste Management – Gary Arendse is: Portion 1 and Portion 4 of Cape Farm ([email protected]; Tel: (021) 483 3872): No. 1183. 3.1 This Directorate is satisfied that that its comments on the DSR dated 30 November 2016 have been addressed and incorporated in the Draft EIA 2.7.3 Thank you for highlighting this, this Report and EMPr. No further comment is offered. error in Chapter 2 has been amended to

reflect the correct page numbers. 4. Directorate: Air Quality Management – Peter Harmse ([email protected]; Tel: (021) 483 8343): 2.7.4 Noted, please see response above. 4.1.1 This Directorate notes that that its comments on the DSR dated 30 November 2016 have been addressed and incorporated in the Draft EIA This has been amended. Report and EMPr. No further comment is offered. 2.7.5 Please see response(s) above, this 5. Please direct all enquiries to the officials indicated in this correspondence should has been amended. you require any clarity on any of the issues/comments provided.

6. The Department reserves the right to revise initial comments and request further information based on the information received.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 96 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP

24/04/2017 The abovementioned draft EIR report, dated March 2017, as compiled by CSIR, 1) Apologies for this mistaken refers. omission, a copy of your letter Email has now been included in 1) A copy of the City of Cape Town comment, dated 30 November 2016, on the Appendix G. Morné Theron revised draft scoping report has not been included in the draft EIR (Appendix G).

Please include in the final EIR? It is however noted that the content of the 2) The Koeberg TEM is included in Senior Environmental aforementioned omitted comment was recorded in the Issues and Responses Chapter 3, page 3-23. You are Practitioner: Trail (Appendix H). correct in pointing out this error Environmental & 2) During the BID it was requested that the Koeberg Nuclear Power Station Traffic in figures. It must be noted that Heritage Management Evacualion Model (TEM) proforma table must be populated and included in the the correct figures pertaining to various scoping and environmental impact assessment reports (also refer to personnel are the ones used in Section 1.1 of the Issues and Responses Trail (Appendix H)). Environmental the Koeberg Model, and all 2.2 On page 3-21 of the draft Scoping Report, dated October 2016, and again on Management page 3-21 of the draft EIR the anticipated population increase is stated as others references have been Department 200 construction workers and 20 permanent workers. These figures of 200 updated to reflect this. Thus, (temporary) and 20 (permanent) anticipated population increases where these figures as first run in the City of Cape Town tested in the TEM and it was confirmed that the current road network can model are correct. Municipality accommodate the safe evacuation of the population within the prescribed 3) Please note that Chapter 6, timetrames. section 6.1.7 has been updated 2.3 Yet on page 7-13 of the draft EIR these figures are contradicted by suddenly to include the input from the stating that between 90 and 150 skilled and 400 and 460 unskilled employment opportunities are expected to be created during the Traffic Specialist, indicating the construction phase. The draft EIR further continues to state that 20 skilled preferred access route, the same and 40 unskilled employment opportunities will be created during the route as suggested by CoCT in operational phase. Therefore the worst-case scenario amounts to 610 these comments and preceding temporary construction phase jobs and 60 permanent operational phase comments. Please note that jobs will be generated. There is a huge difference between a 200 CoCT’s comments regarding the (temporary) and 20 (permanent) anticipated population increase. versus a 610 (temporary) and 60 (permanent) anticipated population increase. preferred access road were Please be consistent throughout the report and provide the correct figures taken into consideration, and

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 97 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP in order to rerun the TEM model. the project description adapted accordingly. In terms of flexible Until such time as the correct TEM figures have been provided the City cannot engineering and design, the confirm whether the proposed development can be safely evacuated. route that is not supported is

3) It is acknowledged that the preferred road access onto the local road network thus only listed as “the will be at the southern end of the site onto Neil Hare Road or Gideon Basson. On alternative option” as a worst- page 6-56 reference is made to the proposed access road shown in Figure 6.1 l. case scenario. The preferred The incorrect figure is stated. Indeed there is no figure in the document that option will be southern end of illustrates the preferred access road. Please correct in order to clarify any Future the site onto Neil Hare Road or contusion. Gideon Basson. It is acceptable 3.1 The City of Cape Town: TDA: Asset Management & Maintenance (former that this forms part of the TCT) consistently indicated through the preceding EIA phases that a proposed access off Neil Hare Road on the northern end of the site, which conditions of EA. necessitates a level crossing across the City owned railway line, is not 4) This was an error and it has been supported. Yet it is noticed that the EAP persists to include this road access edited, thank you for bringing as an alternative option. It is questioned why this is done and why the this to our attention. option is not omitted in its entirety? 3.2 It is requested that the preferred road access be included as a proposed conditions of the EA within section 7 of the final EIR. and/or as a mitigation measure in the EMPr.

4) Part 8.6, item 12.14 (Page 64) of the draft EMPr refers to ‘outsiders moving into the Kenhardt area'. It must be assumed that this is a copy-and-paste mistake as the Kenhardt areas does not relate to Atlantis. Please remove. 25/04/2017 CapeNature would like to thank you for the opportunity to comment on the Thank you for your comments. proposed development and would like to make the following comments. Please Email note that our comments only pertain to the biodiversity related impacts and not to Please see an updated description of the the overall desirability of the proposed development. biodiversity offset, as described in your Mr. Rhett Smart comments. Introduction Manager (Scientific CapeNature has previously commented on the Background Information Document,

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 98 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP Services) Draft Scoping Report and the Amended Draft (Final) Scoping Report. It is noted that Please note that integration at the CapeNature’s comments on the Amended Draft Scoping Report have not been Ankerlig busbar is preferred, as this will CapeNature included within the appendices for Draft Environmental Impact Assessment (EIA) have less environmental impacts. Report, including the issues and responses trail. We have therefore submitted this comment again, as it remains relevant to the comment on the Draft EIA Report. It Please see the updated EMPr (part B) should be noted that the latter comments also addressed statements contained which has addressed your comments. within the Refusal Decision and Appeal Decision from the Department of Please note that new plans have been Environmental Affairs (DEA). added to the EMPr i.e. plant rescue and Biodiversity Offset protection. As has been stated in our previous comments, a key factor for consideration of the application with regards to the impacts on biodiversity on the site is the biodiversity offset that has been secured. We did however recommend that further explanation should be provided regarding the biodiversity offset in terms of the relevant policies and guidelines, particularly considering the statements included within the Appeal Decision.

It is noted that the Integrated Reserve Management Plan (IRMP) for the Klein Dassenberg Nature Reserve has been included as the Biodiversity Offset Report, as the Klein Dassenberg Nature Reserve has been secured as the receiving offset site for the subject development site.

The following discussion of the biodiversity offset is in reference to the Draft National Biodiversity Offset Policy which is currently available for public comment (GN40733, 31 March 2017) and the Draft Western Cape Guideline on Biodiversity Offsets. It should be noted that the provincial guideline was drafted to be complementary to the national policy providing more detailed and specific guidelines within the framework of the policy.

With reference to both the policy and guideline:  Biodiversity offsets are required if the residual impact following the mitigation hierarchy is of high or medium significance. The mitigation

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 99 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP hierarchy for addressing impacts is to first avoid, then minimize, then mitigate/restore and only then offset the residual impact. According to the botanical specialist study, the impact prior to mitigation is of high negative significance. The only acceptable mitigation that was recommended was a biodiversity offset, as the other mitigation measures were not considered to be adequate.  In terms of following the mitigation hierarchy, reference should be made to the need and desirability of the project, as well as the alternatives analysis. The need and desirability is addressed in Table 1.1 in Chapter 1 and the alternatives are discussed in Chapter 5.  It should be noted that the ratios for offsets that were referred to in the botanical specialist study were relevant when the study was undertaken (2012). These ratios have since been refined.

The ratios used were: 1:1 (lost:conserved) for Endangered vegetation types (Cape Flats Dune Strandveld) within the urban edge which occurs over ±90% of the site; and 1:2 for Critically Endangered vegetation types (Atlantis Sand Fynbos) which occurs over ±10% of the site.

The initial site which was acquired (Portion 9 of Farm 20), is 256.32 ha, which was used to offset both sites of the “Atlantis Green Technology Hub” (i.e. both site alternatives) which are 68 ha in total, resulting in a ratio of 1:3.77. Therefore the area conserved was in excess of the calculated ratios and as such the conservation area could function as a receiving area for further biodiversity offsets. It should be noted that further land has been acquired to form the Klein Dassenberg Nature Reserve (further detailed in the IRMP discussed above) with a total area of 535.94 ha resulting in a ratio of 1:7.88, although it should be noted that the nature reserve is already a receiving area for additional biodiversity offsets.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 100 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP  The Draft EIA Report should have discussed the biodiversity offset with reference to the biodiversity offset policy and guideline as we have above, and had recommended in previous comments.

Project Alternatives

Chapter 5 deals with project alternatives. In terms of the two site alternatives, the impacts on biodiversity can be considered to be similar taking into consideration that the impact on terrestrial biodiversity for the entire extent of both sites has been offset off-site. Bearing this in mind, the no-go alternative is therefore likely to still result in the loss of all the natural vegetation on site due to the existing development rights which have not been exercised.

The selection has of Site 2 as the preferred alternative has been made based on socio-economic factors. CapeNature does not object to the selection of Site 2 as the preferred location alternative.

In terms of alternatives for energy generation, it should be noted that CapeNature does not comment on issues related to air quality and climate change, however as a general statement we do support the investigation and implementation of technologies which reduce the potential for climate change as a result of greenhouse gases, as this indirectly impacts on biodiversity.

Project Components In terms of the project description, a basic conceptual layout is now available. The proposed facility will encompass the majority of the site. It is assumed that a more detailed layout will require finalization regarding the source of gas and the evacuation of electricity from the site before this can be completed. Since the offset is relevant to the entire site, we do not object to evaluation of the current basic conceptual layout, however as mentioned in previous comments, we still encourage best practice management on the sections of the site which will not be built upon.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 101 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP Two alternatives have been presented for evacuation of power from the facility, namely either integration at the Ankerlig Busbar or a powerline following the same route as the existing powerlines to the Omega Substation south of the site. These alternatives are not discussed in the alternatives section or evaluated in terms of the potential impacts. It is likely that the integration at the Ankerlig Busbar will be preferred from a biodiversity perspective, as this will not require a powerline of several kilometres in length.

Based on the information provided, it is assumed that the evacuation of power has not been included for authorisation, but instead to present the project in a broader context.

An avifaunal specialist assessment has been included, which has focused on the powerline linking to Omega Substation. The proposed powerline will not traverse important bird habitats or flyways and only two species were highlighted as potentially being of concern, namely Blue Cranes and Great White Pelicans. The location adjacent to an existing line would reduce the impacts as opposed to an alignment where there is no existing impact. The findings of the avifaunal study were that the proposed powerline would be acceptable provided the recommended mitigation measures are implemented, which CapeNature agrees with, although as stated above the integration with the Ankerlig Busbar is the preferred alternative.

The powerline alternative would need to be assessed within a specialist study in terms of the impact on terrestrial habitat should this be considered for authorisation within this application. It should be noted that the alignment does traverse Critical Biodiversity Areas (CBAs) in terms of the Biodiversity Network for the City of Cape Town and the Western Cape Biodiversity Spatial Plan.

Environmental Management Plan

In the correspondence for acceptance of the Scoping Report, DEA listed several requirements for inclusion in the Environmental Management Plan (EMP) for the

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 102 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP proposed project, including an alien invasive management plan, a plant rescue and protection plan, a revegetation and habitat rehabilitation plan, an open space management plan, a stormwater management plan, a fire management plan and an erosion management plan.

These issues have been more or less addressed in the EMP. The following should however be implemented:  The Alien Invasive Management Plan (Section 4) should stipulate that alien clearing should be undertaken according to standard best practice i.e. cut- stump and herbicide.  The Open Space Management Plan should stipulate that even although the site has been offset, clearing of vegetation should be restricted to the development footprint apart from alien invasive species.  Although search and rescue is not considered as mitigation for habitat loss, the opportunity should be provided for collection of plant material from the site for habitat restoration elsewhere, particularly of the three threatened species encountered on site.  The specimens of Leucospermum parile along Neil Hare Road can be retained, if not located within the development footprint (refer to Figure 2.10 in the EIA Report and Figure 4 of the botanical specialist report). The same applies to the other threatened species present.  The stormwater management plan must be approved by the Catchment and Stormwater Management Branch of the City of Cape Town.

In conclusion, CapeNature does not object to the proposed project, however the EIA Report should be amended to address the above comments.

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

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 103 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 26/04/2017 The Directorate: Biodiversity Conservation evaluated and reviewed the EIR and the Thank you for your comments. following were noted: Email Below are the responses to your  The proposed development fall within Portion 1 and 4 of the farm Cape 1183 recommendations (in order): Ms. Wilma Lutsch which is situated in the Atlantis Industrial Area.  Director; Biodiversity The proposed development falls within two vegetation types namely Cape  Please note that a plant rescue and Conservation Flats Dune Strandveld and Atlantis Sand Fynbos. protection plan has now been  The two vegetation types merge along. the southern portion of the included in the EMPr. I would also proposed site. Cape Flats Department of like to direct you to the Site Layout Environmental Affairs  Dune Strandveld is classified as endangered and Atlantis Sand Fynbos is plan in Chapter 2, as well as the classified as critically endangered. Therefore, proper mitigation measures must be implemented to prevent further decline of the species. comments directly above from  The site is surrounded by a mix of open but alien infested land, industrial CapeNature (25/04/2017) regarding buildings, railway lines and roads. biodiversity offset information  The vegetation within the proposed site is recognised as critically important which is relevant to these areas for biodiversity importance. recommendations.  There are also high numbers of the endangered mesemb Ruschr'a indecora  Please see Chapter 2 for the site throughout the site, particularly the periphery and disturbed portions of the layout and which areas on site will natural vegetation wo artificial wetlands or retention ponds were identified, which includes a small excavated pond towards the middle of the site and a not be disturbed. larger retention pond at the south-eastern comer located at waypoint.  Please note the artificial wetland will  The development of the site would results in loss of all vegetation on the not be disturbed by the site, with intact vegetation and important species. development and this has been addressed in the specialist studies.

 Please see response above re. the RECOMMENDATIONS biodiversity offset which is audited After the evaluation of the Avifaunal, Botanicaland Faunal Assessment Reports by CapeNature. In addition, please submitted for the proposed development, the following is recommended to be see the report in Appendix R as well included in the Environmental Authorisation: as a description in Chapter 3 all related to the biodiversity offset.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 104 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP  Sensitive areas should be allocated as conservation areas, in particular the  Agreed. intact Cape Flats Dune Strandveld. The CBAs, ESAs, and areas identified as  Agreed and noted. sensitive during this study should be used as the basis for developing a  Please see this Appendix for all conservation plan that ensures that the natural vegetation surrounding the historical comments from proposed development is responsibly managed, and  All the No-Go areas must be avoided from the construction phase and CapeNature who has been consulted proper mitigations must be implemented to maintain the intact Cape Flats throughout the process, and who Dune Strandveld. have commented on all of the  All watercourses within the proposed area must be avoided by development documents thus far. Please see activities, including a suitable buffer zone to avoid impacts on these water Appendix G for copies of these courses. comments.  The position of the intact vegetation means that the development  Thank you, this will be adhered to. alternative is only likely if a biodiversity offset is offered to compensate for loss of biodiversity important species. Therefore, The Sub-Directorate:  Please see the updated EMPr (Part Biodiversity Planning must be consulted for further offset investigations and B) with these plans included. submission of the offset management plan.  Mitigation Options must be considered in terms of the following hierarchy: (1) avoidance, (2) minimization, (3) restoration and (4) offsets.  Recommendations by the Botanical Impact Assessment Specialist must be adhered to.  Cape Nature must be consulted for comments and their comments should be adhered to prior to an Authorisation issued.  For all species protected in terms of National and Provincial Legislation within the proposed development areas, permits must be obtained from relevant authorities before construction commence.  Rehabilitation and Re-vegetation together with the Protected Plant Rescue and Protection Plans are supported and must be implemented and adhered to.

CONCLUSION

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 105 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT (VERSION 2) for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP The Directorate: Biodiversity Conservation has noted that the proposed industrial development would impact on two vegetation types, which includes a large portion, and several smaller portions of endangered good quality Cape Flats Dune Strandveld within the northern half of the site, with high numbers of the endangered mesemb Ruschia indecora. The second portion of vegetation occurs along the southern boundary in a relatively narrow strip, comprising critically endangered, medium quality, Atlantis Sand Fynbos. Both vegetation types, in particular the large portion of Cape Flats Dune Strandveld and the population of Leucospermum parile are of high conservation importance. The proposed offset would be supported as it will ensure the conservation of an un-fragmented area greater than the existing site that will be lost and it would become a well-managed conservation area. Therefore, the directorate would not have any objections if the above mentioned recommendations is adhered to and further included in the Environmental Authorisation.

APPENDIX H – ISSUES AND RESPONSES TRAIL pg 106 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT Scoping and Environmental Impact Assessment for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

APPENDIX I:

Municipal Services Report for the site

GREEN - CAPE

Atlantis Industrial Factory Site Portion of CA1183-4-1

Neil Hare Road

Services Report on Existing Civil and Electrical Infrastructure

October 2012

J31157

Arcus GIBB (Pty) Ltd Reg. 1992/007139/07

Cape Town, South Africa 14 Kloof Street, Cape Town, 8000 Tel: +27 (0)21 469 9100 Fax: +27 (0)21 424 5571

ATLANTIS FACTORY SITE PORTION OF CA1183-4-1 NEIL HARE ROAD SERVICES REPORT ON EXISTING CIVIL AND ELECTRICAL INFRASTRUCTURE

CONTENTS

Chapter Description Page

1 INTRODUCTION 3

2 ATLANTIS WATER RESOURCES MANAGEMENT SCHEME (AWRMS) 3

3 TOPOGRAPHY AND GEOLOGY 3

4 SITE PREPARATION 4

4.1 Introduction 4

4.2 Terracing 4

4.3 Construction and Lay-down Areas 5

4.4 Roads 5

4.5 General comments 6

5 POTABLE WATER FOR DOMESTIC CONSUMPTION AND FIRE- FIGHTING 6

6 FOUL SEWER (WASTE WATER) 7

7 STORM WATER DRAINAGE 8

7.1 Municipal Network (background) 8

7.2 Municipal Policy Governing Storm Water Drainage 8

7.3 Management of Drainage off Site 9

8 ROAD ACCESS 10

8.1 Local Road Network 10

8.2 Access route to N7 Freeway 10

9 ELECTRICAL 10

10 REFUSE REMOVAL 11

11 SITE CLEARANCE AND BULK EARTHWORKS COST (ESTIMATE) 11

Atlantis 2nd Factory Sites Services Report 1 October 2102.docx Rev 2 / Oct 2012

12 CONCLUSION 11

12.1 Geology 11

12.2 Site Survey 12

12.3 Storm Water Drainage 12

12.4 Potable Water and Foul Sewer 12

12.5 Effluent (Foul Sewer) 12

12.6 Traffic Access 12

12.7 Electrical 13

APPENDICES

Appendix 1: Industrial Area Site Layout Appendix 2: Access onto Neil Hare Road Appendix 3: Vehicular Routing to N7 via Dassenberg Road (R307), West Coast Road (R27) and Melkbosstrand Road (M19) Appendix 4: Schedule of Quantities with estimated rates (based on recent / similar projects)

Atlantis 2nd Factory Sites Services Report 1 October 2102.docx Rev 2 / Oct 2012

1 INTRODUCTION

This document reports on existing infrastructure services, site preparation, traffic access requirements and site clearance and bulk earthworks cost to a vacant site within the Atlantis Industrial area with respect to the establishment of a factory manufacturing components for wind power generation industry. The site location is indicated on Appendix 1 and is approximately 45.45 hectares in extent, rectangular in shape roughly 300 m wide by 1515 m long.

This report comments on site features, site preparation and existing infrastructure services as follows:

1. Topography and Geology 2. Site Preparation 3. Potable Water 4. Foul Sewer (domestic and industrial effluent) 5. Storm Water 6. Electrical 7. Refuse Waste 8. Road Access and traffic

It also includes acknowledgement of guidelines concerning disposal of stormwater run-off and effluent (domestic and industrial) discharge as proposed by Atlantis Water Resource Management Scheme.

2 ATLANTIS WATER RESOURCES MANAGEMENT SCHEME (AWRMS)

There are strict guidelines set out by the AWRMS concerning the disposal of stormwater and effluent from sites within the Atlantis Industrial Zone. The purpose of these guideline is to ensure quality of potential waste water (stormwater and effluent), which is used to artificially recharge the Atlantis Aquifer, is of a quality which minimise contamination of ground water resource used as potable water supply for the Atlantis district, alternatively to dispose of unsuitable effluent to prevent contamination of the ground water.

3 TOPOGRAPHY AND GEOLOGY

The site is densely covered with Port Jackson trees and appears to be rising in elevation from south to north. Observations indicate the site profile was re-shaped and bulk earthworks has occurred sometime in the past, however the dense growth of vegetation makes it difficult to form a reliable assessment of the terrain.

3 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

Emanating from a limited walk about inspection of the site, the site generally indicates a likely probability of uniform underlay of aeolian (wind-blown deposited) sand. Usually these aeolian deposited sands are typically loose within the upper horizon (up to 1.5 m depth) becoming more dense with increasing depth.

No detailed geotech investigation has been undertaken, however based on observation of improvements (development) on adjacent sites, particularly the metal foundry to the east of the site, it is possible to achieve appropriate founding conditions for buildings, hard-stand storage areas and vehicle access circulation.

4 SITE PREPARATION

4.1 Introduction

This section provides general recommendations for the following site preparation operations:

Terracing Construction and lay-down areas Access roads

4.2 Terracing

Prior to commencement of construction the site will have to be terraced to form a level platform on which the plant installations can be constructed. The terrace can be constructed using compacted sand excavated from the site (natural or stabilised), or using selected imported fill of G7 minimum standard. A wearing course for the terrace may be constructed of stabilised sand using a minimum of 8 % cement (requires laboratory verification), or alternatively from imported commercial gravel (G5). However, a stabilised wearing course will be liable to cracking under loads. In order to prepare the terrace we recommend the following sequence of earthworks:

1. Over the entire area of the proposed site, strip all vegetation and organic soils and spoil on site to form screening berms.

Prepare the exposed in-situ surface sands by sub-grade compaction: o Compacted layer thickness ±200 mm o Density 90 % Mod AASHTO o Moisture OMC ±2 %

2. Terrace fill can be constructed using the aeolian sands or imported gravel material. The thickness of the fill will be determined by the settlement criteria of light structures that are to be founded in the terraced fill.

Compacted layer thickness 150 mm

4 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

o Density 100 % Mod AASHTO for aeolian sand o 95 % Mod AASHTO for G7 imported fill o Moisture OMC ±2 %

3. In load bearing areas (ie building ffotprints), cut sections should be over- excavated and backfilled to create a terrace similar to the fill sections, i.e. thickness and density. The terrace should be capped with a wearing course at least 300 mm thick of selected imported commercial fill (G6 or better compacted to min 95 % Mod AASHTO density) should be used to form a wearing course in preference to stabilised in-situ sands.

During construction of the engineered fill, the contractor should conduct regular density tests as required by SANS 1200 DM (or similar specification) using either the Nuclear Density Method or the Sand Replacement Method. The moisture contents from the nuclear density tests should always be confirmed by oven drying tests. Occasional checks on the accuracy of the nuclear test results should be carried out by conducting sand replacement tests in parallel with the nuclear tests to verify Nuclear Density Method results.

The side slopes of temporary excavations within the loose erodible sands should be trimmed back to approximately 1:1.5. Fill slopes and permanent cut slopes should be trimmed at 1:2 and should be protected against wind and run-off erosion.

4.3 Construction and Lay-down Areas

Once the site has been leveled and terraced as described in Section 4.2, the resulting surface should be adequate to service construction traffic, serve as lay down areas and for supporting temporary structures.

Light, temporary structures such as site offices can be founded on slab-at-grade foundations on the terrace.

Crane outriggers may require local strengthening of the terrace, or other measures to safely carry these relatively high and concentrated loads.

4.4 Roads

Plant access roads must be designed for the expected traffic. The design should be based on the following sub-grade classes (refer TRH4):

In-situ sand, un-compacted CBR < 3 In-situ sand compacted to 90% Mod AASHTO CBR ~3 In-situ sand compacted to 95% Mod AASHTO CBR 3 to 7 Sand fill compacted to 100% Mod AASHTO CBR 7 to 15 Compacted Terrace of imported selected fill CBR > 15

5 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

Blend of in-situ sand and imported gravel compacted to 96% Mod AASHTO density CBR > 25

Materials for sub-base and base layers will have to be imported commercial gravel or crushed stone (min G5 or better compacted to minimum 96 % Mod AASHTO density).

4.5 General comments

It may be difficult to effectively remove the vegetation and organic soils from the aeolian sands without stripping large volumes of the surface sands. Since the soils are predominantly non-plastic and fine grained, they will erode easily under the action of wind and water. For this reason protection measures such as vegetation must be introduced to reduce erosion or wash-away on banks and in areas where there is no terrace capping.

The soils on site are also low in nutrient content, allowing only the hardiest of vegetation to survive. Topsoil may have to be imported to form a thin mantle over the non-terraced areas of the site. Alternatively, fertilisers will have to be added to sustain growth in the sands.

Due to the fine grading of the soils, dust may be a problem and dust suppression will be required during construction. This can be mitigated by use of water sprinkler system to suppress airborne dust during earthworks and construction.

Soils in both cut and fill are likely to be non-plastic with low cohesion, gradients up to 3 m in height should not be steeper than 1 vertical and 1,5 horizontal for temporary slopes and 1:2 or flatter for permanent slopes. Higher slopes, whether cut or fill, will need to be assessed as part of the bulk earthworks design once a materials management programme has been established. It may be necessary to provide lateral support for higher cuts and fills in the form of geotextile reinforced concrete- block retaining walls, gabions or similar.

Bulk earthworks and terrace construction should be completed before commencing with the piling contract in order to provide access and a stable platform for the piling operations and that the foundation excavations be formed into the completed terrace rather than constructing the foundations on a partially formed terrace and then completing the terrace construction around the foundations. Backfill above the foundations should be compacted to the same density as the remainder of the terrace to avoid zones of high porosity and permeability around the foundations.

5 POTABLE WATER FOR DOMESTIC CONSUMPTION AND FIRE-FIGHTING

The site is serviced from a 150 mm diameter pressurised pipe-line located along the western boundary of the site. The municipal pipeline provides for both domestic and fire-fighting requirements. Pressure within the pipeline is maintained between 7 to 9 bars, should water be required at higher pressure then booster pumps will have to be installed by the developer.

6 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

6 FOUL SEWER (WASTE WATER)

In the Atlantis district there are two parallel municipal gravity pipeline in the adjacent road network. Generally effluent is divided into two categories namely:

1. Domestic effluent generated from toilets, showers, hand basins and kitchen sinks. 2. Industrial effluent which could include noxious effluents (bye produfrom manufacturing process).

Industrial effluent is be treated on site in a “bioretention” facility to remove heavy and noxious elements. The “bioretention” facility then discharges into a separate municipal waste-water system specifically provided for effluent not suitable for recharging the ground water aquifer. Ideally this facility should be located such that “scrubbed/treated” effluent can gravitate into the dedicated municipal pipeline for industrial effluent.

Buildings which generate domestic effluent, and which require connection to the municipal sewerage reticulation should be situated close to the adjacent road to ensure domestic effluent can gravitate into the dedicated municipal pipeline for conveyance to treatment works for domestic wastewater.

The site is serviced by a 300 mm gravity pipeline adjacent to the western and south section of the eastern boundary. Buildings requiring connection into the municipal pipeline should be situated as close to the municipal sewer lines to ensure waste water can gravitate into the municipal pipeline without pumping.

7 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

7 STORM WATER DRAINAGE

7.1 Municipal Network (background)

The pipe network in the adjacent municipal roads is designed to take the pre- development 1:2 year recurrence interval storm run-off for low traffic volumes areas to 1:10 year recurrence interval storm run-off for prime commercial developments. The balance of the run-off is conveyed within defined overland flow routes utilising streets to discharge into green belts comprising parks and playing fields where flood peak attenuation techniques are applied in accordance with the CoCT’s Management of Urban Storm Water Impacts Policy” document

7.2 Municipal Policy Governing Storm Water Drainage

7.2.1 General Comments

During May 2009 the City of Cape Town (CoCT) introduced a “Management of Urban Storm Water Impacts Policy” document for the purpose of minimising the undesirable impact of storm water runoff from developed areas into natural watercourses and wetlands via storm water culverts.

The policy document requires existing and new developments to comply with the following:

1. Ensure storm water discharged into the municipal drainage network is free from urban pollutants thereby improving the quality of the run-off discharging into natural watercourses and wetlands. 2. Control the quantity and rate of runoff to protect municipal infrastructure, downstream properties and floodplains from frequent nuisance floods and adverse impacts from extreme flooding.

7.2.2 Consequence of new Municipal Policy

The new policy came into effect in May 2009 and consequently requires brownfield and new developments to comply with the policy protocol in respect to the quality and quantity of stormwater runoff emanating from improvements to property.

The consequence to property owners / developers are as follows:

1. Construction of structures at source (i.e. on site) to remove in addition to suspended solids (SS) and total phosphates (TP),and trap litter, oil and grease, to approved levels to ensure a minimum standard of the quality of runoff discharged from developed sites. 2. Attenuate runoff to pre-development levels for 1:10 year recurrence interval

Run-off from surfaced / improved areas (i.e. hard-stands, etc) will have to be conveyed to a lined bio-retention facility, to:

1. improve the quality of the water

8 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

2. Monitor the quality of the water before its released into the appropriate municipal infrastructure. (ie poor quality water into the industrial effluent network).

7.3 Management of Drainage off Site

The AWRMS describes stormwater run-off as three distinct categories on the grounds of water quality namely:

1. Base flow – run-off/drainage from watering activities and subsoil drains. 2. “First flush” - generated from run-off produced by showers from the earlier part of the rainy season. 3. “Better quality water” – from heavier downfalls in the latter part of winter rainy season.

In the instance of development of this site, only items 2 and 3 above are applicable

It is possible to construct infrastructure to manage the disposal of “first flush” run-off and “better quality run-off” by means of a diversion mechanism at the outlet of an on- site “lined bio-retention” basin. This will ensure contaminated run-off can be diverted into the waste-water system for industrial effluent and as the quality of retained water improves, if suitable for aquifer recharge, it can be diverted into the municipal network conveying effluent to the treatment works linked to recharge basin.

9 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

8 ROAD ACCESS

8.1 Local Road Network

The preferred access onto the local road network will be at the northern end of the site onto Neil Hare Road (refer Appendix 2) to avoid:

1. Road under Rail Bridge on Neil Hare Road to the west of the site. 2. Circuitous route if access was on the south side of the site onto Neil Hare Road.

Neil Hare Road is linked to Dassenberg Road via an “unnamed” road. The junction between the site access and Neil Hare Road, as well as the junction of Neil Hare Road and “unnamed” road and “unnamed” road and Dassenberg Road will all have to be widened to accommodate the sweep area for extra-large vehicle turning requirement.

The access location from the site onto Neil Hare Road will result in crossing an operational railway track. A level crossing and right of way servitude will have to be negotiated with Transnet to facilitate a road over rail level crossing to gain access onto Neil Hare Road.

8.2 Access route to N7 Freeway

Access to the N7 freeway will be as follows (refer Appendix 3):

1. Westward along Dassenberg Road (R307) to the junction with the West Coast Road (R27). 2. Southward along the West Coast Road to the intersection with Melkbosstrand Road (M19). 3. Eastward along Melkbosstrand Road (M19) to the junction with the N7 freeway.

Localised road widening of junctions and intersection en route will require municipal (CoCT) and Provincial Roads Department approvals.

A Traffic Impact Assessment (TIA) study is not required, however a study of vehicle movements to and from the industrial area onto the major routes must be considered.

9 ELECTRICAL

The City of Cape Town is the supplier of electricity to the Atlantis Industrial area. Currently the power supply network capacity in the area is limited.

The municipality indicates they could provide up to 2MVA to the site. Anything larger than 2 MVA can be accommodated, but with significant implications to their network.

10 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

10 REFUSE REMOVAL

The removal of refuse (solid waste) is managed by the municipality, alternatively this service can be provided by private contractors, depending on developers needs.

11 SITE CLEARANCE AND BULK EARTHWORKS COST (ESTIMATE)

Based on the footprint required for development (i.e. the north half of the site, approximately 20 hectares) the estimated cost for site clearance and bulk earthworks is approximately R7,200,000.00 (refer Appendix 4) for breakdown of cost.

12 CONCLUSION

12.1 Geology

A geological survey is required to guide the engineering and manage the use of in- situ materials to achieve cost effective construction of terracing, construction and lay- down areas and roads.

Based on heavy construction recently completed in the area (namely the Eskom Ankerlig Power Generation Plant) the following general considerations apply to this site:

1. The natural near-surface soils are loose and unsuitable for founding. 2. Basic preparation of the site should comprise cut, fill and compaction of the aeolian sands, once the site has been cleared of vegetation. 3. The terrace can be constructed using the aeolian sands (natural and/or stabilised) from the site or using imported selected fill. 4. To provide a trafficable surface and a stable platform for piling and/or other construction activities it is recommended that the plant terrace is capped with a minimum 300 mm thick layer of cement stabilised sand using 8 % cement or with an imported commercial (G5) gravel wearing course. 4. Light and flexible structures can be founded directly on the compacted terrace. The thickness of the terrace will govern the settlement of these foundations. 6. Heavy, dynamically loaded or settlement sensitive structures, such as the turbine units, should be founded on pile substructure. 7. If necessary seismic considerations and corrosion protection should be designed by specialist consultants. 8. The design of dynamic loaded structures should be confirmed once the plant layout is finalised. It is recommended that further geophysical tests are carried out once the terrace has been constructed to verify the dynamic properties of the terrace and sub-soils.

11 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

12.2 Site Survey

A topographical survey of the site is necessary to:

1. Determine platform levels for the building footprint and storage areas relative to the adjacent road levels and 2. Plan earthworks to minimise contamination of materials and calculate extent of earthworks.

12.3 Storm Water Drainage

Storm water retention / attenuation will have to be provided in the form of lined bio- retention facilities to comply with municipal by-laws and the Atlantis Water Resources Management Scheme to ensure control release of site discharge into appropriate municipal network. These facilities are to be designed such that they effectively contain and prevent accidental leakage and discharge of retained run-off.

12.4 Potable Water and Foul Sewer

Generally service connections (potable water and foul sewer) to the site are installed by the developer (i.e. the City of Cape Town), however they might not be in the position dedicated by the preferred placement of the building footprint. In this instance an application to the Municipality for new service connections would be necessary.

12.5 Effluent (Foul Sewer)

A dual on site effluent piped conveyance system will have be provided to separate domestic effluent from industrial effluent and these will have to be connected into the dual parallel Municipal network. Domestic effluent can be discharged directly into the municipal network provided for conveyance thereof and industrial effluent treated on site before release into the municipal network.

12.6 Traffic Access

As no rezoning is necessary there is no requirement for a Traffic Impact Assessment. However, due to the abnormal transport vehicle operating from the site, irrespective of whether access is onto the municipal of provincial road network, substantial localised road widening will be required. Applications for these improvements would have to be addressed with the relevant authorities.

12 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

12.7 Electrical

Once details of electrical requirement are received from the developer further discussions will be engaged with the Municipality to determine accommodating the power requirement within their local network.

13 Q:\P8424\Atlantis Factory Site Services Report Rev 2 / November 2011

Appendix 1

Industrial Area Site Layout

Appendix 2

Access onto Neil Hare Road

ALL DIMENSIONS AND LEVELS ARE TO BE VERIFIED ON SITE BY THE CONTRACTOR BEFORE COMMENCING ANY WORK.

This document and all the information thereon remains the property of ARCUS GIBB (Pty) Ltd. and may not be copied, reproduced or transmitted in part or in full without the written consent of ARCUS GIBB (Pty) Ltd. This document should not be relied on nor used in circumstances other than those for which it was originally prepared and for which ARCUS GIBB (Pty) Ltd. was commissioned, as defined on this document. Refer to the contract for full terms and conditions.

ARCUS GIBB (Pty) Ltd. shall not be liable for the consequences of using this document other than for the purpose for which it was commissioned. Any user and any other person using or relying on the document for such other purpose, will by such use or reliance be taken to confirm his agreement to indemnify ARCUS GIBB (Pty) Ltd. for all loss or damage resulting there from.

ON ORIGINAL

15 25 5 0 10 20 30 40MM

GENERAL NOTES:

N Ch Ap Date Details o d pd Revisions

Client

GREEN CAPE

14 Kloof Street, Cape Town 8001 Tel : +27 21 469-9100 PO Box 3965, Cape Town 8000 Fax: +27 21 424-5571

Approved By

Drawn By Designed By Reviewed By

B MENTOR

Project ATLANTIS INDUSTRIAL FACTORY SITE PORTION OF CA1183-4-1 NEIL HARE ROAD

Description

SITE 1 LAYOUT 1 ACCESS TO NEIL HARE ROAD

Scale Date 1 : 2 500 SEPT 2011

Project No Drg. No Rev P8424 102

Appendix 3

Vehicular Routing to N7 via Dassenberg Road (R307), West Coast Road (R27) and Melkbosstrand Road (M19)

Appendix 4

Schedule of Quantities with estimated rates (based on recent / similar projects)

DOCUMENT CONTROL SHEET (FORM IP180/B)

CLIENT : GREEN CAPE PROJECT NAME : ATLANTIS FACTORY SITES PROJECT No. : J31157 TITLE OF Services Report on Existing Civil and Electrical Infrastructure DOCUMENT : ELECTRONIC P:\J31157 (LAND AVAILABLILITY IN ATLANTIS)\Doc\Reports\Atlantis 2nd Factory LOCATION : Sites Services Report 21 November 2011.docx Approved By Reviewed By Prepared By ORIGINAL NAME NAME NAME AN MacKAY DATE SIGNATURE SIGNATURE SIGNATURE 30 November 2011

Prepared by Prepared By Prepared By ORIGINAL NAME NAME NAME

DATE SIGNATURE SIGNATURE SIGNATURE

Approved By Reviewed By Prepared By REVISION NAME NAME NAME AN MacKAY DATE SIGNATURE SIGNATURE SIGNATURE November 2011

This report, and information or advice, which it contains, is provided by Arcus GIBB solely for internal use and reliance by its Client in performance of Arcus GIBB duties and liabilities under its contract with the Client. Any advice, opinions, or recommendations within this report should be read and relied upon only in the context of the report as a whole. The advice and opinions in this report are based upon the information made available to Arcus GIBB at the date of this report and on current SA standards, codes, technology and construction practices as at the date of this report. Following final delivery of this report to the Client, Arcus GIBB will have no further obligations or duty to advise the Client on any matters, including development affecting the information or advice provided in this report. This report has been prepared by Arcus GIBB in their professional capacity as Consulting Engineers. The contents of the report do not, in any way, purport to include any manner of legal advice or opinion. This report is prepared in accordance with the terms and conditions of the Arcus GIBB contract with the Client. Regard should be had to those terms and conditions when considering and/or placing any reliance on this report. Should the Client wish to release this report to a Third Party for that party's reliance, Arcus GIBB may, at its discretion, agree to such release provided that: (a) Arcus GIBB written agreement is obtained prior to such release, and (b) By release of the report to the Third Party, that Third Party does not acquire any rights, contractual or otherwise, whatsoever against Arcus GIBB and Arcus GIBB, accordingly, assume no duties, liabilities or obligations to that Third Party, and (c) Arcus GIBB accepts no responsibility for any loss or damage incurred by the Client or for any conflict of Arcus GIBB interests arising out of the Client's release of this report to the Third Party.

Arcus GIBB (Pty) Ltd Website : www.arcusgibb.co.za Postal Address : PO Box 3965, Cape Town Physical Address : 14 Kloof Street, Cape Town Contact Person : Adrian MacKAY Email Address : [email protected] Telephone No. : +27 (0)21 469 9225 Fax No. : +27 (0)21 424 5571

File original in relevant section in the Quality File. Rev 2 / Sept 2009 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT Scoping and Environmental Impact Assessment for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

APPENDIX J:

Botanical Assessment Bergwind Botanical Surveys & Tours CC.

14A Thomson Road

Claremont

Cape Town 7708

28 September 2016

TO WHOM IT MAY CONCERN

Confirmation of applicability of botanical impact assessment on Farm CA1183 Portion 1 of Portion 4, Atlantis Industrial Area (‘the property’)

A botanical survey and impact assessment was carried out on Farm CA1183 Portion 1 of Portion 4, Atlantis Industrial Area (‘the property’) by my associate Mr Paul Emms in June / July 2012. The assessment examined the clearing of the property for development purposes. The intended development did not proceed.

The property is now (2016) earmarked for development of the Atlantis Gas-to-Power Facility. This would require the same clearing of the property as it would have for the former development.

This letter serves to confirm that the anticipated impact of clearing the property of vegetation would have no greater or lesser negative impact now with development of the Atlantis Gas-to-Power Facility than it would have had the former development proceeded on the same property.

Yours sincerely,

Dr D.J. McDonald Pr. Sci. Nat. Botanical Specialist Director / Owner

tel +27 21 671-4056 mobile 082-876-4051 e-mail [email protected] web www.bergwind.co.za

CK2005\138289\23

Botanical Assessment for proposed industrial development on Farm CA1183 Portion 4 and Portion 1, Atlantis Industrial Area, City of Cape Town

Paul Emms in association with

Dr David J. McDonald Bergwind Botanical Surveys & Tours CC. 14A Thomson Road, Claremont, 7708 Tel: 021-671-4056 Fax: 086-517-3806

Prepared for Doug Jeffery Environmental Consultants

June 2012 / July 2012 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

DECLARATION

This botanical assessment was conducted by Mr Paul Emms in collaboration with Dr David J. McDonald BSc. Hons. (Botany), MSc (Botany) and PhD (Botany), a botanical ecologist with over 30 years’ experience in the field of Vegetation Science. Dr McDonald is registered as an Ecological Scientist with the South African Council for Natural Scientific Professions (SACNASP), Registration No. 400094/06.

General declaration: • We have acted as the independent specialist in this application • We have performed the work relating to the application in an objective manner, even if this has resulted in views and findings that are not favourable to the applicant • We declare that there are no circumstances that may compromise our objectivity in performing such work; • We have expertise in conducting the specialist report relevant to this application, including knowledge of the Act, regulations and any guidelines that have relevance to the proposed activity; • We will comply with the Act, regulations and all other applicable legislation; • We have no, and will not engage in, conflicting interests in the undertaking of the activity; • We undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority; • All the particulars furnished by us are true and correct; and • We realise that a false declaration is an offence in terms of Regulation 71 and is punishable in terms of section 24F of the Act.

Dr David J. McDonald Pr. Sci. Nat.

2 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

CONTENTS

1. Introduction ...... 4 2. Terms of Reference ...... 4 3. Study Area ...... 5 3.1 Locality and general description ...... 5 3.2 Geology, topography and soils ...... 6 3.3 Climate ...... 6 4. Evaluation Method ...... 6 5. Limitations and assumptions ...... 7 6. The Vegetation ...... 9 6.1 General description and context ...... 9 6.2 The vegetation of Farm 1183 Portion 4 & Portion 1 ...... 9 7. Impact Assessment ...... 19 7.1 The ‘No-Go’ Alternative ...... 19 7.2 Direct impacts ...... 19 7.3 Indirect impacts ...... 26 7.4 Cumulative impacts ...... 26 8. Recommendations and Conclusions ...... 26 9. References ...... 27

3 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

1. Introduction

A proposed industrial development is planned for a strip of land (Farm CA1183 Portion 4 & Portion 1) in the Atlantis Industrial Area. The proposed site consists of an undeveloped, linear strip of land, sandwiched between the eastern loop of Neil Hare Road at the western side of Atlantis. The Atlantis Industrial Area contains several remnant patches of threatened vegetation types and species of conservation concern, which present an obstacle for an area zoned for industrial development. The remaining undeveloped portions of land within the Atlantis Industrial Area have therefore recently been acquired by the City of Cape Town (CCT) for the purpose of allowing for biodiversity offsets. A biodiversity offset is defined as ‘conservation actions intended to compensate for residual, unavoidable harm to biodiversity’ . (ten Kate et al ., 2004 in Brownlie and Botha, 2009). The purpose of biodiversity offsets is to secure and add priority conservation areas instead of achieving no net loss of habitat. The CCT has also acquired a substantial portion of land outside the Atlantis Industrial Area which contains the same or better quality vegetation which would allow for the possibility of offsets – adding substantially to the protection of these threatened ecosystems in a consolidated portion of land. The proposed offset ratios are 1:1 ha for ENDANGERED vegetation and 2:1 ha for CRITICALLY ENDANGERED vegetation types (inside urban edge).

The proposed industrial development site required a botanical assessment in order to determine the potential impacts on the vegetation and to describe any areas of sensitivity. In addition the feasibility of an offset option was considered. The environmental assessment process is being managed by Doug Jeffery Environmental Consultants who appointed Bergwind Botanical Surveys and Tours CC to carry out the botanical assessment.

2. Terms of Reference

The following additional terms of reference were considered:

• Provide a description of the vegetation of the site and areas of sensitivity. • Check for the possible presence of wetlands with reference to the City of Cape Town’s wetland mapping; • Identify and describe biodiversity patterns at community and ecosystem level (main vegetation type, plant communities in vicinity and threatened/ vulnerable ecosystems species), at species level (species of conservation concern, presence of alien species) and in terms of significant landscape features;

4 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

• Provide mitigation options with respect to the long-term management of vegetation affected. • Comment on whether or not biodiversity processes would be affected by the proposed project, and if so, how these would be affected. • Comply with DEA&DP’s Guideline for Involving Biodiversity Specialists in EIA Processes, the Fynbos Forum’s Ecosystem Guidelines for Environmental Assessment in the Western Cape (De Villiers et al. 2005) and Cape Nature’s standard requirements.

3. Study Area

3.1 Locality and general description

Farm 1183 Portion 4 and Portion 1 is situated in the Atlantis Industrial area. The study area consists of a linear strip of land contained in the western loop of Neil Hare Road. The eastern boundary is flanked by a railway line, whereas the western boundary is marked by a water- main servitude, which extends along most of the boundary length until the southern side meets Gideon Basson Road. At this point the boundary continues along the western side of a retention pond and joins Neil Hare Road. The site is surrounded by a mix of open but alien infested land, industrial buildings, railway lines and roads. Despite the fragmentary effects of the various surrounding features and possible fence barriers, the area experiences active exchange of ecological and biodiversity resources between adjacent portions of land. Of importance here is the proximity to the Atlantis dune plume situated about 1.5km to the west where the Witzands Aquifer Nature Reserve is located.

5 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 1 . Location of the proposed industrial development site on Farm CA1183 Portion 4 & Portion 1 in the Atlantis Industrial Area (green dot).

3.2 Geology, topography and soils

The site consists of low to moderate vegetated dunes, which are characteristic of the surrounding area. The dunes are of aeolian origin, underlain by fine- to medium- grained sand. These contain detrital carbonate (mainly finely broken sea shells) of the Witzand Formation. The sands associated with most of the site (except a relatively small portion along the southern boundary) are alkaline due to the high calcium content. The southern portion of the site also contains aeolian deposits, however, the detrital carbonate (sea-shells) has been leached from the original dune sands and they are therefore most likely acidic.

3.3 Climate

The Mediterranean climate within the region experiences rainfall mainly between May and August: MAP 290 – 660 (mean 440 mm), with temperatures ranging from a mean summer high (February) of 27.9 ˚C to a winter low (July) of 7˚C.

4. Evaluation Method

The study area was visited on 30 May 2012, and surveyed on foot. A combination of photographic records and sampling waypoints (using a Garmin ® GPSmap 60CSx) were

6 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

used to record important features. The vegetation and study area was described in terms of general quality and degree of disturbance, sensitivity and conservation importance Plant species were identified in the field or collected for identification. Potential impacts were measured against the following criteria: • Conservation planning : GIS shapefiles of The City of Cape Town’s Biodiversity Network (CCT BioNet) (2011) was used to show were Critical Biodiversity Areas (CBA’s) fall in relation to the study area. The CCT BioNet is of high importance since it provides information on priority biodiversity areas and the associated category of importance. Ground-thruthing of CBA’s is important since the sites may reflect a different scenario to the CCT BioNet. • Ecosystem status : ecosystem status of the vegetation type was the gained using the List of Threatened Terrestrial Ecosystems (Government Gazette, 2011). The gazette listings are crucial to commenting on the level of sensitivity in relation to natural vegetation quantity and quality. • Special habitats: the presence of rare or sensitive habitats such as wetlands and dunes. • Restoration potential and biodiversity corridors: degraded areas or alien-infested areas have the potential to be restored depending on the level of disturbance or transformation. Degraded and transformed areas may also be of importance if these areas link portions or remnants of good quality or highly threatened vegetation types.

5. Limitations and assumptions

Stands of alien invasive vegetation presented a limitation since in some portions of the site these were almost impenetrable. Access through heavy infestations was extremely difficult. Consequently it is possible that small patches of remnant species were missed during the survey, since the entire site could not be surveyed due to impenetrability. Of particular concern was lack of access due to dense alien stands towards the south-western portion of the site since scattered individuals of the ENDANGERED Leucospermum parile was found within the dense stands.

Although most plant species could be detected at the time of survey (late May), a survey outside of the peak spring flowering period makes it difficult to detect the full array of potential species, in particular geophytes (bulbs) which were still dormant. The number of species recorded would therefore probably be higher during a spring survey. This limitation is more of a concern within the disturbed area since the geophytes could be more important in such areas.

7 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 2. Google Earth ™ aerial image of the proposed industrial development site (red outline) on Farm 1183 Portion 4 & Portion 1 in relation to Atlantis; the Atlantis dune system and Klein Dassenberg Road.

8 Botanical Screening: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis, CoCT

6. The Vegetation 6.1 General description and context

Vegetation According to the Vegetation Map of South Africa, Lesotho, and Swaziland (Mucina, Rutherford and Powrie, 2005) there are two vegetation units within the study area (Figure 5). These are:

1) Cape Flats Dune Strandveld (CFDS): an ENDANGERED ecosystem, covering almost the entire site; and 2) Atlantis Sand Fynbos (ASF): a CRITICALLY ENDANGERED ecosystem, covering a small section along southern boundary.

Biodiversity plans The study area does not fall within the City of Cape Town’s Biodiversity Network (2011) since the CCT BioNet’s planning methodology preferentially selects areas outside of the urban edge but it is important to note that several large portions of important natural remnant vegetation were found.

Local context The study area forms part of the Atlantis dune ecosyste m also found in the Witzand Aquifer Nature Reserve. However, the site is somewhat isolated from the main dune system by roads; buildings; fences; cleared portions of land, and heavy infestations of invasive alien Port Jackson Willow ( Acacia saligna ) and ro oikrans ( Acacia cyclops ).

6.2 The vegetation of Farm 1183 Portion 4 & Portion 1

Approximately two thirds of the site has been transformed by invasive aliens vegetation (mainly Port Jackson Willow, with lower cover of rooikrans), which, in some areas - particularly the southern portion - is almost impenetrable due to high densities of 3 - 4m high saplings. The remaining areas contain intact, good -quality Cape Flats Dune Strandveld and a relatively small portion of Atlantis Sand Fynbos. The two vegetation t ypes (as a result of the interface between different soil types) merge along the southern portion of the site. This is significant since transition zones are recognized as critically important areas for driving speciation and for biodiversity importance (De Villiers et al. 2005).

The remnant portions of Cape Flats Dune Strandveld (Figure 4) are dominated by the small tree known as the dune olive ( Olea exasperata ). The tree has a dwarf habit, which may be a small 9

Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

form of the species. It is more likely that the tree is relatively slow-growing, and in the early stages of growth following a recent fire in the area. This is not entirely clear though, since alien stands tend to be a consistent height and are rapid colonizers, reaching maturity within a few years after fire. The high density of Port Jackson Willow saplings towards the southern side of the site reflect a recent fire. Of greater importance, however, is the large patch of Cape Flats Dune Strandveld occurring within the site, which is considered a highly important, albeit threatened, remnant due to the ecological state of the surrounding area. The area is considered to have a high restoration potential under the scenario of alien eradication and active long-term. clearing. Furthermore there are small pockets of good quality Cape Flats Dune Strandveld which would serve as important islands for the recovery potential.

The Cape Flats Dune Strandveld remnants have several dominant species which include Searsia laevigata subsp . villosa; Searsia glauca, Euclea racemosa, Osteospermum moniliferum, Thamnochortus spicigerus, Roepera morgsana, Ehrharta villosa, Limonium perigrinum, Asparagus capensis, Trachyandra sp ., Cissampelos capensis, Euphorbia mauritanica, Cynanchum africanum, Ruschia macowanii and Muraltia spinosa. There are also high numbers of the ENDANGERED mesemb Ruschia indecora throughout the site, particularly the periphery and disturbed portions of the natural vegetation . Additional species include Arctotis stoechadifolia , Lachenalia rubida, Brunsvigia orientalis, Thesium sp., Carpobrotus cf. quadrifidus, Euphorbia marlothiana, Lycium ferocissimum and Othonna coronopifolia .

The remnant portion of Atlantis Sand Fynbos along the southern boundary is partially disturbed and of medium quality. The land north of the medium quality vegetation is heavily infested with Port Jackson Willow and rooikrans (Figure 4). Within the heavily infested areas several species are present, including Phylica cephalantha , Trichocephalus stipularis , Diosma sp., Thamnochortus sp. and a few individuals of Erica mammosa and the ENDANGERED Malmesbury Pincushion ( Leucospermum parile ) (Figure 12). The most common widespread of these is Phylica cephalantha . The most southern portion has a low cover of alien vegetation where there is a remnant population of approximately 80 individuals of the ENDANGERED Leucospermum parile (Figure 4). All individuals were mapped (Appendix 1) to show the distribution. The population is a red flag since the species is steadily declining and will most probably be listed as CRITICALLY ENDAGERED in the future. Species associated with this population included Willdenowia incurvata, Othonna coronopifolia; Arctotis stoechadifolia; Trichocephalus stipularis; Diosma sp ., Aspalathus cf . spinosa; Metalasia muricata and Aspalathus ternata (VULNERABLE).

Two artificial wetlands or retention ponds were located. These included a small excavated pond (location: 33°36'3.65"S; 18°28'13.48"E) towards the middle of the site and a larger retention pond at the south-eastern corner located at waypoint 054: 33°36'14.68"S; 18°28'18.61"E). Both

10 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis ponds are covered with bulrush ( Typha capensis ) and are surrounded by alien vegetation. The possible presence of a wetland located at 33°36'1.72"S; 18°28'13.99"E was checked and found to be a grassy area with alien vegetation.

11 Botanical Screening: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis, CoCT

Figure 3. Google Earth ™ aerial image of the proposed industrial development site on Farm 1183 Portion 4 and Portion 1 in Atlantis Industrial in relation to the City of Cape Town’s Biodiversity Network (2011 ) (yellow shading). The CBA category within the site boundary is ‘Other Natural Vegetation’, which means the area is not part of the current CCT BioNet.

12

Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 4. Google Earth ™ aerial image of the proposed industrial development site on Farm 1183 Portion 4 and Portion 1 in Atlantis Industrial Area with the sample waypoints (labeled green icons). The good quality vegetation is indicated by the yellow shading (Cape Flats Dune Strandveld) and orange shading (Atlantis Sand Fynbos) whereas the remaining areas consist of heavy alien infestations of Port Jackson Willow and rooikrans. The red icons show the distribution of clumps of the ENDANGERED Malmesbury pincushion ( Leucospermum parile ). The blue shading indicates wetlands/retention ponds.

13 Botanical Screening: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis, CoCT

FFd4

FS6

AZd3

FS6 FFd4

AZi9

Figure 5. The proposed industrial development site (red outline) represented on a portion of the Vegetation Map of South Africa, Lesotho, and Swaziland (Mucina et al. 2005). FS6 = Cape Flats Dune Strandveld; FFd4 = Atlantis Sand Fynbos; AZi9 = Cape Inland Salt Pan s; Azd3 = Cape Seashore Vegetation

14

Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 6 . Portions of good quality Cape Flats Dune Strandveld, dominated by the dune olive (Olea exasperata ) extends over a large portion of the site. Sample at waypoint 038 (33°35'50.93"S; 18°28'6.73"E).

Figure 7 . The eastern boundary of the site showing the railway, industrial area and alien stands. Sample waypoint 047 (33°35'57.33"S; 18°28'17.06"E).

15

Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 8 . The area checked for the possible presence of a wetland in terms of the CoCT wetland mapping at 33°36'1.72"S; 18°28'13.99"E revealed a grassy patch covered with alien vegetation.

Figure 9 . The small wetland/retention pond within stands of Port Jackson Willow, which is dominated by bulrush ( Typha capensis ). Located at 33°36'3.65"S; 18°28'13.48"E.

16 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 10 . Dense stands of Port Jackson Willow cover most the study area. The southern half of the site contains patches alien vegetation and the common Phylica cephalantha . Located at waypoint 081 (33°36'7.61"S; 18°28'23.16"E).

Figure 11 . Large wetland/retention pond dominated by bulrush ( Typha capensis ) located at waypoint 054 (33°36'14.68"S; 18°28'18.61"E).

17 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Figure 12 . Remnant patch of Atlantis Sand Fynbos where the population of the ENDANGERED Malmesbury pincushion ( Leucospermum parile) occurs. Located at waypoint 063 (33°36'19.51"S; 18°28'22.35"E).

7. Impact Assessment

The ‘No Go’ scenario and the construction implementation scenario (i.e. industrial development of the area) were assessed, with the ‘No Go’ scenario coupled with an offset proposal. No alternatives were provided.

7.1 ‘No Go’ Alternative

In the case of the ‘No Go’ alternative, the proposed development would not go ahead. The status quo would consequently prevail with no immediate changes to the vegetation. In the medium to long term the site would be subject to increased invasion by Port Jackson Willow and rooikrans since alien clearing is unlikely to be controlled under the ‘No Go’ scenario.

7.2 Direct impacts

Direct impacts are impacts occurring directly on the vegetation of the site that would result from the proposed development. In this instance there would be loss of intact vegetation and species of importance in addition to loss of degraded, alien-infested

18 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

vegetation. The impacts on the two classes of vegetation and habitat due to the proposed construction are considered according to two identified potential impacts which are:
Loss of vegetation type – including intact vegetation, ecologically important species and species of conservation concern.
Loss of ecological processes – associated with the loss of intact vegetation, ecologically important species and species of conservation concern.

Direct impacts are assessed in Tables 1 – 4, which apply to the design, construction and operational phases of the project.

19 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Table 1. Impact and Significance – Loss of intact vegetation type, ecologically important species and species of conservation concern during the design and construction phase:

Alternative 1: Development Alternative 1: Development option option No-Go Alternative Comment Impact: Intact vegetation & species of Degraded vegetation & alien conservation concern infestations Nature of impact: Loss of natural vegetation Loss of natural vegetation Loss of natural vegetation Extent and duration of impact: National & Permanent Local & Permanent Local & Permanent Biodiversity offset mitigation Probability of occurrence: Likely Likely Unlikely measure Degree to which the impact can be reversed: Low Low High Degree to which the impact may cause irreplaceable loss of Low Low High resources: Low to Medium Low Biodiversity offset mitigation Cumulative impact prior to mitigation: High measure Significance rating of impact prior to mitigation High Low to Medium Low Degree to which the impact can be mitigated: Low Low High Proposed mitigation: Biodiversity offset Biodiversity offset None Cumulative impact post mitigation: High Low to Medium Low Significance rating of impact after mitigation High Low to Medium Low

20

Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Table 2. Impact and Significance – Loss of intact vegetation type, ecologically important species and species of conservation concern during the operational phase:

Alternative 1: Development Alternative 1: Development option option No-Go Alternative Comment Impact: Intact vegetation & species of Degraded vegetation & alien conservation concern infestations Nature of impact: Loss of natural vegetation Loss of natural vegetation Loss of natural vegetation Extent and duration of impact: National & Permanent Local & Permanent Local & Permanent Biodiversity offset mitigation Probability of occurrence: Likely Likely Unlikely measure Degree to which the impact can be reversed: Low Low High Degree to which the impact may cause irreplaceable loss of Low Low High resources: Low to Medium Low Biodiversity offset mitigation Cumulative impact prior to mitigation: High measure Significance rating of impact prior to mitigation High Low to Medium Low Degree to which the impact can be mitigated: Low Low High Proposed mitigation: Biodiversity offset Biodiversity offset None Cumulative impact post mitigation: High Low to Medium Low Significance rating of impact after mitigation High Low to Medium Low

21 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Table 3 Impact and Significance – Loss of ecological processes associated with loss of vegetation type during the design and construction phase: Alternative 1: Development Alternative 1: Development option option Loss of ecological process Loss of ecological processes No-Go Alternative Comment Impact: associated with intact associated with degraded vegetation & species of vegetation & alien infestations conservation concern Nature of impact: Loss of ecological processes Loss of ecological processes Loss of ecological processes Extent and duration of impact: National & Permanent Local & Permanent Local & Permanent Biodiversity offset mitigation Probability of occurrence: Likely Likely Unlikely measure Degree to which the impact can be reversed: Low Low High Degree to which the impact may cause irreplaceable loss of Low Low High resources: Low to Medium Low Biodiversity offset mitigation Cumulative impact prior to mitigation: High measure Significance rating of impact prior to mitigation High Low to Medium Low Degree to which the impact can be mitigated: Low Low High Proposed mitigation: Biodiversity offset Biodiversity offset None Cumulative impact post mitigation: High Low to Medium Low Significance rating of impact after mitigation High Low to Medium Low

22

Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Table 4. Impact and Significance – Loss of ecological processes associated with loss of vegetation type during the operational phase:

Alternative 1: Development Alternative 1: Development option option Loss of ecological process Loss of ecological processes No-Go Alternative Comment Impact: associated with intact associated with degraded vegetation & species of vegetation & alien infestations conservation concern Nature of impact: Loss of ecological processes Loss of ecological processes Loss of ecological processes Extent and duration of impact: National & Permanent Local & Permanent Local & Permanent Biodiversity offset mitigation Probability of occurrence: Likely Likely Unlikely measure Degree to which the impact can be reversed: Low Low High Degree to which the impact may cause irreplaceable loss of Low Very low High resources: Low to Medium Very low Biodiversity offset mitigation Cumulative impact prior to mitigation: High measure Significance rating of impact prior to mitigation High Low to Medium Very low Degree to which the impact can be mitigated: Low Low High Proposed mitigation: Biodiversity offset Biodiversity offset None Cumulative impact post mitigation: High Low to Medium Very low Significance rating of impact after mitigation High Low to Medium Very low

23 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

• Loss of vegetation type and important species identified

Development of the site would most probably result in loss of all vegetation on the site. The loss of all portions of intact vegetation and important species (i.e. Figure 4 & Appendix 1) would therefore result in HIGH NEGATIVE IMPACT for the design, construction and operational phases of the project and LOW to MEDIUM NEGATIVE IMPACT for degraded, alien-infested vegetation. Furthermore the impacts would have the same rating when considering the proposed mitigation (i.e. offset option). It would be difficult to avoid the intact vegetation since the largest patch occurs near the centre of the site.

• Loss of ecological processes

Loss of ecological processes is expected to be similar to impacts associated with the loss of vegetation. Ecological processes are difficult to assess since these are mostly unseen, however, based on the makeup, quality, size and connectivity of the habitat, such processes can be assumed to correlate with occurrence of patches of natural vegetation. The associated loss of ecological processes is therefore expected to result in HIGH NEGATIVE IMPACT for intact vegetation (e.g. Cape Flats Dune Strandveld and Atlantis Sand Fynbos) and species of conservation concern (e.g. Leucospermum parile ) and LOW to MEDIUM NEGATIVE IMPACT for degraded, alien-infested vegetation.

Mitigation

The position of the intact vegetation (i.e. in the center of the site, Figure 4) means that the development alternative is only likely if a biodiversity offset is offered to compensate for the loss. The proposed offset of 1:1 ha for ENDANGERED Cape Flats Dune Strandveld pertains to most of the site, whereas the ratio 2:1 ha for CRITICALLY ENDANGERED Atlantis Sand Fynbos would apply to the strip of land along the southern boundary. The offset option is thus considered the only feasible mitigation option available.

24 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

7.3 Indirect impacts

Indirect impacts are impacts that are not a direct result of the proposed activity (in this case the construction of industrial buildings and associated infrastructure), but occur away from the original source of impact. No indirect impacts in terms of the vegetation were identified in this regard.

7.4 Cumulative impacts

Cumulative impacts are spatially related impacts assessed on local, regional and national scales, as appropriate, that may be caused by several projects, strategic actions and existing trends.

The cumulative loss of vegetation within the Atlantis Industrial Area has led to extensive loss of two vegetation types, namely Atlantis Sand Fynbos (CRITICALLY ENDANGERED) and Cape Flats Dune Strandveld (ENDANGERED). The further loss of intact Cape Flats Dune Strandveld and Atlantis Sand Fynbos on the study site would result in a HIGH NEGATIVE CUMULATIVE IMPACT.

8. Recommendations and Conclusions

• The proposed industrial development would impact on two vegetation types, which includes a large portion, and several smaller portions, of ENDANGERED, good quality Cape Flats Dune Strandveld within the northern half of the site, with high numbers of the ENDANGERED mesemb Ruschia indecora present. The second portion of vegetation occurs along the southern boundary in a relatively narrow strip, comprising CRITICALLY ENDANGERED, medium quality, Atlantis Sand Fynbos. This area harbours about 80 individuals of the ENDANGERED Malmesbury Pincushion ( Leucospermum parile ). • The transitional area - where the soil interface gives rise to a changeover and interchange of species between the vegetation types is of high conservation importance since such ecotones usually drive speciation and are important in terms of ecological processes.

25 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

• Both vegetation types, in particular the large portion of Cape Flats Dune Strandveld and the population of Leucospermum parile are of high conservation importance. However, these occur within an area overtaken by alien vegetation and with limited connectivity to the Atlantis dune area. Restoration, although possible, is unlikely to occur in the near future, which means that the land will undergo further degradation through alien invasion. In order for the land to hold any conservation value in the future, the alien vegetation would have to be eradicated and biodiversity corridors created to link with the Atlantis dune area. Active and ongoing management of the site would be required.

• The proposed offset is supported since this would ensure the conservation of an unfragmented area greater than the existing site that will be lost and it would become a well-managed conservation area. Thus although the impacts would be HIGH NEGATIVE these would more than adequately compensate in the offset scenario - a gain for biodiversity conservation.

9. References

Brownlie, S. 2005. Guideline for involving biodiversity specialists in EIA processes: Edition 1. CSIR Report No. ENV-S-C 2005-053 C . Provincial Government of the Western Cape: Department of Environmental Affairs and Development Planning.

Brownlie, S. and Both, M. 2009. Biodiversity offsets: adding to the conservation estate, or ‘no net loss’? Impacts Assessment and Project Appraisal, 27(3), September, pp. 227-231.

DEA&DP. 2011. Information Document on Biodiversity Offsets, EIA Guideline and Information Document Series . Western Cape Department of Environmental Affairs & Development Planning (DEA&DP). October 2011.

De Villiers, C.C. Driver, A. Clark, B. Euston-Brown, D.I.W. Day, E.G. Job, N. Helme, N.A. Holmes, P. M. Brownlie, S. and Rebelo, A. G. 2005. Fynbos Forum Ecosystem Guidelines for Environmental Assessment in the Western Cape . Fynbos Forum, Cape Town, 94pp.

26 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Government Gazette No 34809, 9 December 2011. Department of Environmental Affairs, No. 1002 of 2011. Threatened Terrestrial Ecosystems in South Africa.

Holmes, P. Stipinovich, A. and Purves, A. 2011. City of Cape Town’s Biodiversity Network. Environmental Resource Management Department (ERMD), City of Cape Town.

Mucina, L., Rutherford, M.C., & Powrie, L.W. (eds.). 2005. Vegetation map of South Africa, Lesotho, and Swaziland 1:1 000 000 scale sheet maps. South African National Biodiversity Institute, Pretoria. ISBN 1-919976-22-1.

Mucina, L. & Rutherford, M.C. 2006. (eds.) The Vegetation of South Africa. Lesotho & Swaziland. Strelitzia 19 . South African National Biodiversity Institute, Pretoria.

Theron, N.T (compiler). 1990. 1: 250 000 Geological Series (Republic of South Africa): 3318 Cape Town. Government Printer, Pretoria.

______Report submitted: 11June 2012; revised 3 July 2012, 3 October 2012

27 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

Appendix 1 : Localities of Red List species recorded within the proposed industrial site on Farm 1183.

Waypoint reference Species and number of individuals Locality

057 Leucospermum parile (EN) X 1 plant 33°36'20.46"S

18°28'20.68"E

058 Leucospermum parile (EN) X 1 plant 33°36'20.92"S 18°28'20.47"E

059 Leucospermum parile (EN) X 15 plants 33°36'21.58"S

18°28'20.60"E

060 Leucospermum parile (EN) X 4 plants 33°36'19.98"S

18°28'22.14"E

061 Leucospermum parile (EN) X 2 plants 33°36'19.85"S

18°28'22.38"E

062 Leucospermum parile (EN) X 10 plants 33°36'19.64"S 18°28'22.45"E

063 Leucospermum parile (EN) X 10 plants 33°36'19.51"S 18°28'22.35"E

065 Leucospermum parile (EN) X 5 plants 33°36'19.17"S 18°28'22.63"E

066 Leucospermum parile (EN) X 1 plant 33°36'19.33"S

18°28'22.86"E

067 Leucospermum parile (EN) X 1 plant 33°36'20.11"S

18°28'22.85"E

068 Leucospermum parile (EN) X 2 plants 33°36'17.68"S 18°28'24.31"E

069 Leucospermum parile (EN) X 5 plants 33°36'17.28"S 18°28'23.47"E

070 Leucospermum parile (EN) X 4 plants 33°36'17.07"S 18°28'23.57"E

071 Leucospermum parile (EN) X 4 plants 33°36'17.04"S 18°28'23.88"E

072 Leucospermum parile (EN) X 4 plants 33°36'17.54"S 18°28'24.45"E

074 Leucospermum parile (EN) X 1 plants 33°36'16.08"S

28 Botanical Assessment: Proposed development of Farm CA1183 Portion 4 & Portion 1, Atlantis

18°28'27.73"E

075 Leucospermum parile (EN) X 1 plant 33°36'14.94"S

18°28'29.03"E

076 Leucospermum parile (EN) X 1 plant 33°36'14.44"S 18°28'29.97"E

077 Leucospermum parile (EN) X 4 plants 33°36'13.77"S 18°28'30.30"E

082 Leucospermum parile (EN) X 1 plant 33°36'7.06"S 18°28'22.07"E

29 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT Scoping and Environmental Impact Assessment for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

APPENDIX K:

Palaeontological Assessment Email confirmation from Dr. Graham Avery re. applicability of findings to the proposed Atlantis gas-to-power project

From: Graham Avery To: Date: 07/10/2016 09:12 Subject: Palaeontological Assessment: Proposed Development Farms CA1183 (Portions 1&4) and CA 4 (Portion 93), 3318CB Melkbosstrand

Dear Kelly,

Thank you for your enquiry re the basic palaeontological implications in my report: Avery, G. 2012. Palaeontological Assessment: Proposed Development Farms CA1183 (Portions 1&4) and CA 4 (Portion 93), 3318CB Melkbosstrand.

The information and recommendations therein still stand and I do not believe that a further study at this stage would change these materially.

Regards,

Graham Avery --

*Dr Graham Avery MRSSAf*

*Cell: 0834410028*

*Landline: 0214241285*

*Email: [email protected] *

*Archaeozoologist*

*Curator in Natural History Collections Department, Cenozoic Studies (retired)*

*Honorary Associate: Natural History Collections Department, Iziko Museums of South Africa, PO Box 61, Cape Town 8000*

*Honorary Research Associate, Archaeology Department, University of Cape Town* Palaeontological Assessment: Proposed Development Farms CA1183 (Portions 1&4) and CA 4 (Portion 93), 3318CB Melkbosstrand

Prepared by Graham Avery (Sole Proprietor)

Archaeozoology, Stone Age Archaeology and Quaternary Palaeontology

July, 2012

1

Contents Executive Summary ...... 3 Location of the proposed development ...... 3 Method ...... 4 Introduction ...... 4 Palaeontological potential ...... 4 Conclusion ...... 7 Recommendations ...... 7 Heritage Permits Required ...... 8 References...... 8

Executive Summary

Dr Graham Avery was commissioned by Jenna Theron on behalf of Doug Jeffrey Environmental Consultants to conduct a survey of the palaeontological potential on proposed development, Farms CA1183 (Portions 1&4) And CA 4 (Portion 93), 3318CB Melkbosstrand.

Applicant: City of Cape Town Proposed activity: Industrial Development (renewable energy) Location: Atlantis Industrial Area A review of published sources and personal observations indicates that the proposed development falls on land under which deposits of potential palaeontological significance may exist. The area is within the Duinefontyn Dune Plume where wind erosion has in other parts exposed deeper sediments that underlie the Holocene (<10 000 year old (10 ka) Witzand Formation. Vegetation comprises a mix of indigenous Strandveld and alien Acacia species. Absolute dates place some fossil material at 330 ka, but there are even older known marine fossiliferous deposits dating back to at least 5 Ma (Million years ago) at the coast. Sparse scatters of stone artefacts of probable Early Stone Age occur with some of the fossils; Middle and Later Stone Age artefacts also occur, the latter on or within the Witzand Formation and most likely the result of activities of Khoekhoe herders, who arrived in the Western Cape some 2000 years ago. Similar occurrences may have been located during the archaeological survey of the proposed area. The occurrence of fossils in underlying sediments is a strong possibility, especially if excavations for foundations cut through the Witzand Formation and penetrate into underlying older sediments in which wetland deposits and/or fossils may be encountered. Collaboration between the contractor and a suitably-qualified palaeontologist (or archaeologist with appropriate experience) will be required during excavations for foundations and infrastructure so that information and/or material can be recorded appropriately. Prior access to geotechnical information and accurate foundation depths would help to determine the likelihood of this and the best strategy. Provided that the recommendations of this assessment are complied with, there is no palaeontological reason why the erection of the proposed development should not proceed.

Location of the proposed development The proposed area falls on 1:50 000 topographical map 3318CB Melkbosstrand and see Figure 1.

3

Figure 1. The location of the proposed development on the edge of the Atlantis Industrial Area. Note the proximity of the Witsand Dune Field.

Method A desktop study was conducted, by Dr G. Avery, Archaeozoologist.

Introduction The Western Cape is yielding significant fossil remains, dating back several million years, relating to South Africa’s palaeontological, palaeoenvironmental and past animal and human heritage. Hendey (1983) provides general background. Most observations of the more ancient occurrences are within a kilometer of the coast and associated with dune plumes; large areas further inland are vegetated or under agriculture and subaerial sediments have not been exposed; so the overall extent of the fossiliferous deposits, while likely to extend well into the Duinefontyn Dune Plume (Roberts, et al. 2009), which continues inland ‘Northeast’ of the Dassenberg site, remains to be confirmed. Foundations of any depth may intersect fossil-bearing deposits and have the potential to provide opportunities for observations in sediments otherwise inaccessible.

Palaeontological potential This report is the result of a desk top study. Rogers (1982) describes the basic lithography of the area. Apart from reference to fossils, he notes that peaty deposits occur in deeper sediments. Traces of Pleistocene age terrestrial fossils have been located in sediments along the west bank of the Diep River entrance to Rietvlei and in sediments underlying Rietvlei (Avery 1995). Early Pliocene marine mammal remains (whale bone) have been recovered from the Potsdam Sewerage pumping station (GA pers. observation), on Milnerton Beach at the Diep River estuary and Ysterplaats 4

(Hendey 1969; Simpson 1973; Tankard 1975). During construction of the Koeberg Nuclear Power Station, Early Pliocene sediments yielded marine mammals, mainly whales. Further North, Middle Pleistocene terrestrial fossils and Middle Stone Age stone artefacts occur at Bokbaai (Mabbutt, et al. 1955). Elandsfontein (aka Hopefield Fossil Site) (Klein, et al. 2007), a major fossil occurrence in the Dune Plume extending from the Ysterfontein area (Roberts, et al. 2009) further North and some 20 km inland of Langebaan (Klein, et al. 2007), has yielded important Middle Pleistocene animal fossils (700 ka to 400 ka) and the earliest human remains (archaic Homo sapiens) found so far in the Western Cape. Late Pleistocene animal fossil occurrences occur along the coast from Melkbosstrand to Ysterfontein (GA pers. obs.) and at Elandsfontein (Inskeep 1966; Klein 1983). It is clear, therefore that the area is palaeontologically important. Witsand Dune Field Superficial dune sands cover most of the area and are <10 000 ka. Scatters of Later Stone Age pottery, stone artefacts and marine molluscs attest to human activity; remains of a black rhinoceros provide a specimen record confirming observations by the first European settlers in the area. Wind erosion in these areas does not penetrate the calcretes, which are often exposed. Pleistocene deposits undoubtedly exist below these. Duinefontein Dune Field Later Stone Age surface occurrences similar to those in the Witsand Dune Field occur in the dunes on Duinefontein (Stoch, L. unpublished records, Archaeology Section, Iziko Museums Social History Collections Department). During the 1950s and 1960s the Duinefontein dune field, which extended from Melkbosstrand to Groot Springfontein also yielded many fossils and early and Middle Stone Age artefacts (Hendey 1968; Hendey 1969), which were exposed and sandblasted. However, erosion also exposed better-preserved in situ reddish (ferrugenized) sediments, which have been carefully excavated and/or collected and published (Avery and Klein 2011; Cruz-Uribe, et al. 2003; Klein 1976; Klein, et al. 1999). DFT 1-4 Two major excavated samples, DFT 1, a hyaena den, and DFT2, ancient land surfaces around wetlands, have yielded 330 ka fossils of a wide range of mainly terrestrial mammals and birds and Early Stone Age artefacts (Cruz-Uribe, et al. 2003).

5

Figure 2. DFT 2 excavation with Koeberg Nuclear Power Station in background. The white dunes (top left) are the overlying Witzand Formation.

Figure 3. DFT 2 excavated surface with fossilized Eland vertebrae in reddish (ferrugenized sands).

DFT n This is a similar-aged temporary exposure, probably a hyaena accumulation, in the northernmost area of the Duinefontein Dune Field, which has yielded the earliest example of the South African Fur Seal, the species that lives around our coasts today, terrestrial mammals, marine and terrestrial birds and early Stone Age artefacts (Avery and Klein 2011).

6

Klein Springfontein A temporary exposure in the ‘Duinefontein Dune Field’ near the R27 yielded many fossils of terrestrial mammals, reptiles and birds, which were collected by GA and RG Klein and lodged in the Cenozoic Section of Iziko Museum’s Natural History Collections Department.

Koeberg Nuclear Power Station Excavations for the foundations of the Koeberg Nuclear Power Station yielded 14 m of terrestrial Middle Pleistocene deposits underlain by a further 14 m of highly fossiliferous marine deposits, dated to approximately 5 Ma, that extended to Malmesbury bedrock (Rogers 1979; Rogers 2006). Unique early Pliocene avian and marine mammal species, including a probable new species of Arctocephalus (the same genus the South African Fur Seal falls into), have been described from the site, e.g. (Avery and Klein 2011; Simpson 1975).

Human Burials Later Stone Age people inhabited the area as evidenced by surface scatters (above) and San and/or Khoekhoe burials may be encountered at any time or level e.g.(Pfeiffer and Van der Merwe 2004; Pfeiffer, et al. 1999).

Comments The background above serves to indicate the extensive heritage value of the area and the potential that fossiliferous deposits underlying the Witzand Formation may be encountered. It is also possible that sub-fossil remains of palaeontological interest could be encountered within Witzand Formation sediments. Good communication with contractors and periodic on-site monitoring during excavations will be required.

Conclusion From the above, it is clear that the proposed development is in an area under which potentially important palaeontological remains may occur. Such palaeontological remains are likely to be rare and sparsely distributed but, if encountered, must be carefully exposed and recorded by an appropriately qualified person. Provided that the recommendations in this report are followed, current information indicates that the proposed development will not impact significantly on palaeontological remains. Appropriately conducted the development may in fact provide opportunities to access rare fossil material and to better understand the local geological sequence. From the palaeontological perspective the development can be allowed to proceed.

Recommendations Excavations for foundations/infrastructure should be monitored by an appropriate palaeontologist. The frequency of this to be worked out a priori with the contractor to minimize time spent on site. 7

If possible, geotechnical information, together with the proposed depths of excavations for foundations and/or infrastructure, should be provided prior to the commencement of construction. This may enable a better estimation of the time(s) when monitoring will take place and even the extent of recovery work. Protocols for dealing with palaeontological monitoring/mitigation must be included in the Environmental Management Plan (EMP). Any such material is likely to be fragile and due care must be exercised. Any material recovered will be lodged in the collections of Iziko South African Museum. Funds must be available a priori to cover costs.

Heritage Permits Required The primary heritage legislation that needs to be considered is The South African Heritage Resources Act 25 of 1999 and regulations (details at www.sahra.org.za). All heritage material, including burials, is included. Clearance in terms of the National Heritage Act of 1999 will be required before the development can proceed. Locally, a permit will be required from Heritage Western Cape; in the event of a burial being exposed, SAHRA is the organization to contact along with the South African Police Services, but no bones should be further moved until an archaeologist or palaeontologist has assessed them. Although not required by the Act, it is suggested that, to obviate possible delays should fossil material be encountered, a permit be applied for before any excavation is initiated. This would enable the monitor to readily recover material, should it be encountered during construction activities.

References Avery, G. 1995 Archaeological and Palaeontological Survey: Milnerton Lagoon Mouth (3318CD). South African Museum. Avery, G., and R.G. Klein 2011 Review of fossil phocid and otariid seals from the southern and western coasts of South Africa. Transactions of the Royal Society of South Africa 61(1):14-24. Cruz-Uribe, K., et al. 2003 Excavation of buried Late Acheulean (Mid-Quaternary) land surfaces at Duinefontein 2, Western Cape Province, South Africa. Journal of Archaeological Science 30:559-575. Hendey, Q. Brett 1968 The Melkbos site: an Upper Pleistocene fossil occurrence in the South-Western Cape Province. Annals of the South African Museum 52:89-119. Hendey, Q.B. 1969 Quaternary vertebrate fossil sites in the south-western Cape Province. South African Archaeological Bulletin 24:96-105. 1983 Palaeoenvironmental implications of the late Tertiary vertebrate fauna of the fynbos region. In Fynbos Palaeoecology: a Preliminary Synthesis. H.J. Deacon, Q.B. Hendey, and J.J.N. Lambrechts, eds. Pp. 100-115. South African National Scientific Programmes Report, Vol. 75. Pretoria: South African National Sientific Programmes. Inskeep, R. R. 1966 Interesting association of bones from the Elandsfontein fossil site. Actes du V Congres Panafricaini de prehistoire et de L' Etude du Quaternaire.

8

Klein, R.G. 1976 A preliminary report on the Duinefontein 2 "Middle Stone Age" open-air site (Melkbosstrand, South-Western Cape Province, South Africa). South African Archaeological Bulletin 31:12-20. 1983 Palaeoenvironmental implications of Quaternary large mammals in the Fynbos biome. In Fynbos Palaeoecology: a Synthesis. Pp. 116-138. South African National Scientific Programmes Reports. Pretoria: CSIR. Klein, R.G., et al. 2007 The mammalian fauna associated with an archaic hominin skullcap and later Acheulean artifacts at Elandsfontein, Western Cape Province, South Africa. Journal of Human Evolution 52:164- 186. Klein, R.G.., et al. 1999 Duinefontein 2: An Acheulean Site in the Western Cape Province of South Africa. Journal of Human Evolution 37(2):153-190. Mabbutt, J.A., et al. 1955 Geomorphology, archaeology and anthropology from Bokbaai, Darling District, Cape Province. South African Archaeological Bulletin 10:85-93. Pfeiffer, S., and N.J. Van der Merwe 2004 Cranial injuries to Later Stone Age children from the Modder River Mouth, Western Cape Province, South Africa. South African Archaeological Bulletin 59(180):59-65. Pfeiffer, S., et al. 1999 Violent human death in the past: a case from the Western Cape. South African Journal of Science 95(3):137-140. Roberts, DL, et al. 2009 West coast dune plumes: climate driven contrasts in dunefield morphogenesis along the western and southern South African coasts. Palaeogeography, Palaeoclimatology, Palaeoecology 271:24-38. Rogers, J. 1979 The sedimentary succession at the Koeberg nuclear power station, Melkbosstrand [Abstracts]. 18th Congress of the Geological Society of South Africa, 1979, pp. 310-322. 2006 Sedimentology of the Late Cenozoic sediments, including the Pliocene Duynefontein Member of the Varswater Formation, Koeberg nuclear power station, Melkbosstrand, Cape Town. African Natural History 2:194-196. Rogers, J. 1982 Lithostratigraphy of Cenozoic sediments between Cape Town and Eland’s Bay. Palaeoecology of Africa 15: 121-137. Simpson, G.G. 1973 Tertiary penguins (Sphenisciformes, Spheniscidae) from Ysterplaats, Cape Town, South Africa. South African Journal of Science 69:342-344. 1975 Tertiary penguins from the Duinefontein site, Cape province, South Africa. Annals of the South African Museum 79(1):1-7. Tankard, A. J. 1975 The marine Neogene Saldanha Formation. Transactions of the Geological Society of South Africa 78(2):257-264.

Dr Graham Avery MRSSAf 13 Prince Street Oranjezicht 8001 Cell: 0834410028 Email: [email protected]

Honorary Associate: Iziko Museums, Natural History Collections Department

9

Honorary Research Associate: University of Cape Town, Archaeology Department

10

DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT Scoping and Environmental Impact Assessment for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape

APPENDIX L:

Archaeology Input

ACO Associates cc. Postal: 8 Jacobs Ladder, St James, 7945 Physical : Unit C26, Prime Park, Mocke Road, Diep River A rchaeology and Heritage Specialists

Tel: 021-7064104 / 0721796219

e-mail: [email protected]

Kelly Stroebel Environmental Assessment Practitioner CSIR PO Box 320 Stellenbosch 7599

22 September 2016 Dear Ms Stroebel

SCOPING AND ENVIRONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED ATLANTIS GAS-TO-POWER FACILITY ON PORTION 1 AND PORTION 4 OF CAPE FARM 1183, WESTERN CAPE

I refer to your email of the 20 September 2016.

My letter of exemption from further archaeological studies on Portions 1 and 4 of Cape Farm CA1183, dated 10 July 2012, considered that the likelihood of uncovering any significant material on the above property to be minimal.

I can confirm that my assessment of the impacts of clearing the site for the original intended development will be the same as the proposed development to which you refer. My letter of exemption from further studies therefore still applies.

Regards

Lita Webley for ACO Associates cc

ACO Associates cc. Company Reg: CK 2008/234490/23 VAT Reg: 4160257996 Members: D Halkett & T Hart Associates: J. Orton, L. Webley

ACO Associates cc. Postal: 8 Jacobs Ladder, St James, 7945 Physical : Unit C26, Prime Park, Mocke Road, Diep River Archaeology and Heritage Specialists Tel: 021-7064104 / 0731418606

Lita Webley: PhD Archaeology (University of Cape Town) e-mail: [email protected]

The Case Officer – Zwelibanzi Shiceka Heritage Western Cape Private Bag X9067 Cape Town 8000

Case No: 120621ZS31 File No: HM/FARM CA4, PORTION 93/1 ATLANTIS

10 July 2012

LETTER OF EXEMPTION FROM FURTHER ARCHAEOLOGICAL ASSESSMENT: PROPOSED DEVELOPMENT ON FARM CA1183 (PORTIONS 0, 1 & 4) AND FARM CA4 (Portion 93), ATLANTIS, WESTERN CAPE

1. Development Proposals

Portions 0, 1 & 4 of the Farm CA1183 and Portion 93 of the Farm CA4 belongs to the City of Cape Town (CoCT). They are located (Figure 1) within the Atlantis Industrial Area (inside the Urban Edge) and they are zoned for General Industrial use. The CoCT proposes to lease the vacant land to companies within the renewable energy sector to support the broader “Green Economy”. The industrial development on these portions of land would support “green technology” such as producing turbine blades, turbine towers, turbine assemblers, PV panel assembly plants and inverter manufacturers, etc. The upgrading of the existing electrical substation from 2MW to 4 MW on site will also be required.

This proposal will have significant socio-economic benefits for the community of Atlantis in terms of job creation, etc.

Figure 1: Map sheet 3318CB indicating the location of the two areas within the Atlantis Industrial Area which have been identified for further industrial development.

ACO Associates cc. Company Reg: CK 2008/234490/23 VAT Reg: 4160257996 Members: D Halkett & T Hart Associates: J. Orton, L. Webley

2. Archaeological Background

The terrain is largely flat and there are a number of dune fields (see Figure 2). Where agriculture is not taking place, alien plant species have taken over. Previous archaeological surveys have described the poor visibility due to dense ground cover of alien vegetation.

A large number of Heritage and Archaeological Impact Assessments have been conducted in this area, including a survey by Hart et al. (2007) which also covered the two sites identified for the current development (Figure 2). He reported that no significant archaeological material was recovered.

Hart 2007

Halkett 2004

Figure 2: The two portions of vacant land (outlined in red) fall within the land surveyed by Hart et al in 2007 (within the purple rectangle) for the Atlantis Open Gas Turbine (OCGT) while Halkett surveyed the land immediately to the south for the Atlantis Shooting Range in 2004.

The archaeological literature for the Atlantis area has been reviewed (Halkett 2004; Halkett 2005; Halkett 2006; Hart 2005; Hart et al. 2007; Hart 2008a; Hart 2008b & Webley 2008). While scatters of ESA material and some LSA material of low significance have been reported from surrounding areas, the authors of these reports have not recommended any further mitigation.

With regard human remains, two burials were reportedly excavated from the Groot Oliphantskop farm (to the south-west) in the mid-20 th century (Kaplan 1996) and Morris (1992) has catalogued human burials from Milnerton (13 listed), Blaauwberg (20 listed) and Melkbosstrand (22 listed). However, no human burials have been recorded from the Atlantis area.

3. Conclusions

A literature survey of the Atlantis area strongly suggests that the likelihood of uncovering any significant archaeological remains on Portions 0, 1 & 4 of the Farm CA1183 and Portion 93 of the Farm CA4 are minimal.

Prior surveys have been conducted on the same property which has been identified for the current proposed development. No significant archaeological remains were reported. ACO Associates cc. Company Reg: CK 2008/234490/23 VAT Reg: 4160257996 Members: D Halkett & T Hart Associates: J. Orton, L. Webley

The current development proposals are supported and no further archaeological studies are required prior to the commencement of the proposed activity.

However, human remains can occur anywhere on the landscape. In the event that human remains are uncovered, certain protocols must be observed. The area around the burial should be cordoned off and both Heritage Western Cape and the police must be notified. No further construction should take place until the authorities have investigated the remains and made their recommendations.

4. References

Halkett, D. 2004. An Archaeological Impact Assessment proposed facilities at the Atlantis Shooting Range. Unpublished report by Archaeology Contracts Office for Ninham Shand (Pty) Ltd.

Halkett, D. 2005. EIA for a new regional landfill site to service the City of Cape Town: Archaeology and Cultural Heritage Specialist Study. Unpublished report by the Archaeology Contracts Office for CCA Environmental (Pty) Ltd.

Halkett, D. 2006. A Heritage Scoping study of proposed sand mining on the farm Kleine Zoute Rivier, Portion 84, near Atlantis. Unpublished report by Archaeology Contracts Office for Atlantic Sands (Pty) Ltd.

Hart, T. 2005. A Heritage Impact Assessment (as part of an EIA) of the Farm 1183 and a portion of the Farm Witzand 2, Atlantis Industria Area. Atlantis Open Gas Turbine Project. Unpublished report by Archaeology Contracts Office for Bohlweki Environmental (Pty) Ltd.

Hart, T., Orton, J. & Schietecatte, L. 2007. Heritage Impact Assessment: The proposed capacity of the Atlantis Open gas Turbine (OCGT) Plant and associated infrastructure in the Western cape Province.

Hart, T. 2008a. Scoping Heritage Assessment for the proposed construction of a 400 kV transmission line between Ankerlig Power Station (Atlantis) and the proposed Omega substation, Groot Olifantskop. Unpublished report by the Archaeology Contracts Office for Savannah Environmental (Pty) Ltd.

Hart, T. 2008b. Heritage Impact Assessment for the proposed construction of transmission lines with respect to the relocation of the three Acacia Park Gas Turbines and one Port Rex Gas Turbine to Ankerlig Power Station, Atlantis Industria, Western Cape. Unpublished report by the Archaeology Contracts Office for Savannah Environmental (Pty) Ltd.

Kaplan, J. 1996. Archaeological and Cultural Impact Assessment: Omega substation. Unpublished report for Ninham Shand Consulting Engineers by Agency for Cultural Resource Management, Riebeek West.

Morris, A. 1992. A Master Catalogued: Holocene Human skeletons from South Africa. Johannesburg: Witwatersrand University Press.

Webley, L. 2008. A Phase 1 Archaeological Impact Assessment: Atlantis Village Development, Western Cape. Unpublished report by Archaeology Contracts Office for Pieter Badenhorst Professional Services.

Yours Sincerely

Dr Lita Webley PhD Archaeology (University of Cape Town) Member of Association of Southern African Professional Archaeologists (ASAPA) and accredited as a Principal Investigator for: Stone Age, Shell Middens, Colonial Period Archaeology and as Field Director for: Burials.

ACO Associates cc. Company Reg: CK 2008/234490/23 VAT Reg: 4160257996 Members: D Halkett & T Hart Associates: J. Orton, L. Webley

VERSION 2 OF MAY 2017

City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Y Moodley, S Perumal, A Raghunandan CSIR 3/8/2016

i City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Report details:

Client: CSIR Report title: City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility Report number: uMN161-15 Project number: uMN092-15 Project: GreenCape Atlantis Gas to Power Facility Version: Final Draft Version 2

Author details:

Author: Yegeshni Moodley, Sarisha Perumal, Atham Raghunandan

Approved: Mark Zunckel

This report has been produced for CSIR by uMoya-NILU Consulting (Pty) Ltd. The intellectual property contained in this report remains vested in uMoya-NILU Consulting (Pty) Ltd. No part of the report may be reproduced in any manner without written permission from uMoya-NILU Consulting (Pty) Ltd and CSIR.

When used in a reference this document should be cited as follows: uMoya-NILU (2016): City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility, Report No. uMN161-15, March 2016.

i City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

EXECUTIVE SUMMARY

GreenCape Atlantis Gas to Power Facility is located in the Atlantis Industrial Area, City of Cape Town in the Western Cape Province. It will be operated by the City of Cape Town. Limited sensitive receptors are located within a 5 km radius of the GreenCape Atlantis Gas to Power Facility.A combined cycle gas turbine (CCGT) plant uses a cycle configuration of combustion turbines, heat recovery steam generators (HRSG), and steam turbines, to generate electricity. The Atlantis Facility consists of 4 Combustion turbine and generator sets producing a combined power output of approximately 1500 MW; Heat recovery steam generators; and Dry cooling radiator systems. Pollutants emitted from LNG combustion include oxides of nitrogen (NOX = NO + NO2) and carbon monoxide (CO). Pollutants emitted from diesel combustion include sulphur dioxide (SO2), NOX, CO, benzene and particulates, including respirable PM10 and PM2.5. The combustion of both fuel types also results in CO2 emissions, which is a Greenhouse Gas. CO2 emissions for the facility were estimated at 246592.5 tons per annum for the LNG scenario, and 351954.7 tons per annum for the diesel scenario.

Table A: Average proposed emission concentrations (mg/Nm3) and rates (tons/year) at GreenCape Atlantis Gas to Power Facility

LNG Emission rate (tons/annum) Emission concentration (mg/Nm3) SO2 NOX PM10 CO Benzene SO2 NOX PM10 Stack 1 1.9 55 3.7 8.4 0.007 0.1 2.9 0.19 Stack 2 1.9 55 3.7 8.4 0.007 0.1 2.9 0.19 Stack 3 1.9 55 3.7 8.4 0.007 0.1 2.9 0.19 Stack 4 1.9 55 3.7 8.4 0.007 0.1 2.9 0.19

Diesel Emission rate (tons/annum) Emission concentration (mg/Nm3) SO2 NOX PM10 CO Benzene SO2 NOX PM10 Stack 1 18 493 6.7 1.8 0.031 1.0 25.7 0.35 Stack 2 18 493 6.7 1.8 0.031 1.0 25.7 0.35 Stack 3 18 493 6.7 1.8 0.031 1.0 25.7 0.35 Stack 4 18 493 6.7 1.8 0.031 1.0 25.7 0.35

Predicted maximum ambient concentrations of all pollutants are very low, with NO2 in the diesel scenario being the only elevated value observed. This maximum concentration is predicted to occur north of the facility, due to the stack and plume parameters used for modelling. No exceedances of the NAAQS are predicted from the facility.

Table B: Predicted concentrations for all pollutants

Pollutant Averaging period LNG Diesel SO2 1-hour 0.040 0.375 NO2 1-hour 0.916 8.211 PM10 24-hour 0.039 0.070 CO 1-hour 0.175 0.037 Benzene Annual average 0.000005 0.000024

An AEL application is required to be prepared and submitted upon finalisation of the project design. The licensing authority is the Department of Environmental Affairs, National Air Quality Officer, Dr Thulie Mdluli.

ii

Impacts from construction and decommissioning are of low significance. They are estimated with a medium confidence as the level of construction activities are not detailed. No mitigation is necessary, however, measures are suggested to minimise the nuisance impacts arising from the activities.

Impacts from operations are estimated to be of low significance for all pollutants considered, viz. SO2, NO2, PM10, benzene and CO. The estimation is stated with medium confidence as details relating to emission parameters were not specified and were assumed. This may affect ambient concentrations, if the facility does not meet the design parameters. No mitigation is needed for operational activities.

Table C: Impact assessment summary

Significance Impact Revers- Irreplace- Confidence Status Extent Duration Intensity Probability description ibility ability without with mitigation mitigation CONSTRUCTION/ DECOMMISSIONING Dust and other Replace- Negative Local Immediate Reversible Low Probable Low Low Med pollutants able IMPACTS FROM OPERATIONS Replace- Highly Low SO Negative Local Long Reversible Low Low Med 2 able probable Replace- Highly Low NO Negative Local Long Reversible Low Low Med 2 able probable Replace- Highly Low PM Negative Local Long Reversible Low Low Med 10 able probable Replace- Highly Low Benzene Negative Local Long Reversible Low Low Med able probable Replace- Highly Low CO Negative Local Long Reversible Low Low Med able probable

iii

GLOSSARY

AIR Atmospheric Impact Report AEL Atmospheric Emission Licence APPA Atmospheric Pollution Prevention Act (Act No. 45 of 1965) AQMP Air Quality Management Plan CO Carbon monoxide CO2 Carbon dioxide CoCT City of Cape Town DEA Department of Environmental Affairs K Kelvin kPa Kilopascal MES Minimum emission standard mg/Nm3 Milligram per normal cubic metre NAAQS National ambient air quality standards NEM:AQA National Environment Management, Air Quality Act (Act No. 39 of 2004) NEMA National Environmental Management Act (Act No. 107 of 1998) NO Nitrogen oxide NO2 Nitrogen dioxide NOX Oxides of nitrogen (NOX = NO + NO2) PM Particulate matter PM10 Particulate matter with a diameter of less than 10 µm PM2.5 Particulate matter with a diameter of less than 2.5 µm SO2 Sulphur dioxide µm 1 µm = 10-6 m WHO World Health Organisation

iv City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... ii GLOSSARY ...... iv TABLE OF CONTENTS ...... v FIGURES ...... vi TABLES ...... vi 1 INTRODUCTION ...... 1 1.1 Scope and objectives ...... 1 1.2 Terms of reference ...... 1 1.3 Approach and methodology ...... 1 1.3.1 Dispersion modelling methodology ...... 2 1.4 Assumptions ...... 3 1.5 Scoping input ...... 3 2 AIR QUALITY IMPACTS ...... 5 2.1 Nature of the Process ...... 5 2.2 Process details and mass balance ...... 5 2.3 Raw materials and products...... 7 2.4 Air pollutants resulting from power generation ...... 7 2.5 Atmospheric emissions ...... 8 2.5.1 Pollutants ...... 8 2.5.2 Point source emissions ...... 10 2.6 Emission Control Officer ...... 11 2.7 Authorisation Details ...... 11 2.8 Modelling contractor ...... 11 3 Description of affected environment ...... 11 3.1 Enterprise Details ...... 11 3.2 Location and extent ...... 12 3.3 Climatic conditions ...... 13 3.3.1 Temperature and rainfall ...... 13 3.3.2 Wind ...... 14 3.4 Current status of ambient air quality ...... 15 3.4.1 Air pollutant dispersion ...... 15 3.4.2 Ambient air quality monitoring ...... 15 3.4.3 Source apportionment ...... 16 4 IDENTIFICATION OF ISSUES ...... 16 4.1 Construction and decommissioning ...... 16 4.2 Operations ...... 16 4.2.1 Modelled ambient concentrations ...... 16 5 LEGAL REQUIREMENTS ...... 19 5.1 National Environmental Management Act ...... 19 5.2 The Air Quality Act ...... 20 5.2.1 Listed activities and Minimum Emission Standards ...... 20 5.2.2 Atmospheric Emission Licence (AEL) ...... 20 5.2.3 Ambient air quality standards ...... 20 6 IMPACT ASSESSMENT ...... 21 6.1 Status ...... 21 6.2 Extent ...... 22 6.3 Duration ...... 22 6.4 Intensity ...... 22

v City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

6.5 Probability ...... 23 6.6 Reversibility and irreplaceability ...... 23 6.7 Significance ...... 24 6.8 Summary of impacts with mitigation ...... 25 7 REFERENCES ...... 27 8 APPENDIX 1: SPECIALIST DECLARATION AND CV ...... 28 9 APPENDIX 2: MODEL PLAN OF STUDY...... 30

FIGURES

Figure 2-1: Relative location of the different process units at GreenCape Atlantis Gas to Power Facility ...... 6 Figure 2-2: A basic block flow diagram for the operation at GreenCape Atlantis Gas to Power Facility ...... 7 Figure 3-1: Relative location of the GreenCape Atlantis Gas to Power Facility ...... 12 Figure 3-2: Land use and sensitive receptors surrounding the site, shown by a green block ...... 13 Figure 3-3: Monthly average temperature and rainfall at Atlantis (SAWS, 1990) ...... 14 Figure 3-4: Annual windrose for Atlantis ...... 14 Figure 3-5: Hourly SO2 concentrations at Atlantis (www.saaqis.org.za) ...... 15 Figure 4-1: Predicted maximum 1-hour SO2 concentrations for a) LNG and b) diesel ...... 17 Figure 4-2: Predicted maximum 1-hour NO2 concentrations for a) LNG and b) diesel ...... 17 Figure 4-3: Predicted maximum 24-hour PM10 concentrations for a) LNG and b) diesel ...... 18 Figure 4-4: Predicted maximum 1-hour CO concentrations for a) LNG and b) diesel ...... 18 Figure 4-5: Predicted annual average benzene concentrations for a) LNG and b) diesel ...... 19

TABLES

Table 2-1: Unit processes ...... 5 Table 2-2: Raw material used at GreenCape Atlantis Gas to Power Facility ...... 7 Table 2-3: Production rates at GreenCape Atlantis Gas to Power Facility ...... 7 Table 2-4: Point sources at GreenCape Atlantis Gas to Power Facility ...... 10 Table 2-5: Average proposed emission concentrations (mg/Nm3) and rates (tons/year) at GreenCape Atlantis Gas to Power Facility ...... 10 Table 3-1: Entity details...... 11 Table 3-2: Site information ...... 12 Table 4-1: Predicted concentrations for all pollutants ...... 19 Table 5-1: Applicable minimum emission standards ...... 20 Table 5-2: National ambient air quality standards (DEA, 2009; DEA, 2012a) ...... 21 Table 6-1: Impact assessment summary ...... 25 Table 6-2: Mitigation summary ...... 26

vi City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

1 INTRODUCTION

1.1 Scope and objectives

GreenCape is a sector development agency established by the City of Cape Town and Western Cape Provincial government. GreenCape is the project management office for the proposed special economic zone (SEZ) in Atlantis. GreenCape is seeking environmental authorisation to develop and operate a 1500 MW Combined Cycle Gas Turbine (CCGT) power plant at Atlantis. Power Generation is a Listed Activity in terms of the National Environmental Management: Air Quality Act (Act No. 39 of 2004). The environmental authorisation for the project must therefore be supported by a specialist air quality assessment. This assessment report must meet all the requirements of an Atmospheric Impact Report (AIR), specified in DEA (2013).

The scope of specialist air quality study for the GreenCape Atlantis Gas to Power facility includes: i. Input in Draft Scoping Report ii. Description of the affected environment; iii. Identification of key issues; iv. Identification of key legislation and permit requirements; v. Impact assessment as per CSIR Impact assessment methodology, including cumulative impact assessment of proposed projects in the area (including this project); vi. Mitigation measures and monitoring requirements/recommendations; vii. Environmental Management Programme (EMPr) as per CSIR’s template.

1.2 Terms of reference

i. Provide inputs to the Scoping Report by providing a description of the affected environment and identifying the potential key issues associated with the proposed project during the scoping phase. ii. Use available data and information to description of current state of the receiving atmospheric environment in Atlantis and surrounds. Sources of data will include the City of Cape Town, the South Africa Weather Service and previous specialist studies in the area; iii. Provide an overview of the regulatory requirements under the NEM:AQA and the Air Quality Management Plans (AQMP) for City of Cape Town and the Western Cape; iv. Develop of an atmospheric emission inventory for the 1500 MW CCGT power plant; v. Predict ambient concentrations of pollutants resulting from emissions from the CCGT power plant using the DEA recommended CALPUFF dispersion model and according to the DEA guideline for dispersion modelling (DEA, 2012). vi. Assess of air quality impacts of the proposed operations and the implications for human health by evaluating predicted ambient concentrations of air pollutants with the National Ambient Air Quality Standard (NAAQS) and using EIA criteria prescribed by CSIR; vii. Prepare and submitted a draft AIR to CSIR for review and finalise the AIR.

1.3 Approach and methodology

The methodology employed for the air quality impact assessment includes a description of the receiving environment in the project area, a review of applicable legislation and standards to the activity, the compilation of a detailed emission inventory, prediction of ambient pollutant concentrations, assessment of air quality impacts, and the recommendation of suitable mitigation actions, where needed.

The emission inventory for the gas turbines and heat recovery uses US-EPA emission factors (US- EPA, 2009). The impact assessment is based on the CSIR methodology provided.

1 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

1.3.1 Dispersion modelling methodology

The approach to the dispersion modelling in this assessment is based on the requirements of the DEA guideline for dispersion modelling (DEA, 2012b) and is described in detail in the Plan of Study report (see Appendix. An overview of the dispersion modelling approach for GreenCape Atlantis Gas to Power Facility is provided here.

1.3.1.1 Models used

A number of models with different features are available for air dispersion studies. The selection of the most appropriate model for an air quality assessment needs to consider the complexity of the problem and factors such as the nature of the development and its sources, the physical and chemical characteristics of the emitted pollutants and the location of the sources.

This assessment is considered to be a level 3 assessment, according to the definition on the dispersion modelling guideline (DEA, 2012b). The CALPUFF suite of models (http://www.src.com/calpuff/calpuff1.htm) were therefore used. The U.S. EPA Guideline of Air Quality Models also provides for the use of CALPUFF on a case-by-case basis for air quality estimates involving complex meteorological flow conditions, where steady-state straight-line transport assumptions are inappropriate.

CALPUFF is a multi-layer, multi-species non-steady-state puff dispersion model that simulates the effects of time- and space-varying meteorological conditions on pollution transport, transformation and removal. CALPUFF can be applied on scales of tens to hundreds of kilometres. It includes algorithms for sub-grid scale effects (such as terrain impingement), as well as, longer range effects (such as pollutant removal due to wet scavenging and dry deposition, chemical transformation, and visibility effects of particulate matter concentrations).

The Air Pollution Model (TAPM) (Hurley, 2000; Hurley et al., 2001; Hurley et al., 2002) is used to model surface and upper air metrological data for the study domain. TAPM uses global gridded synoptic-scale meteorological data with observed surface data to simulate surface and upper air meteorology at given locations in the domain, taking the underlying topography and land cover into account. The global gridded data sets that are used are developed from surface and upper air data that are submitted routinely by all meteorological observing stations to the Global Telecommunication System of the World Meteorological Organisation. TAPM has been used successfully in Australia where it was developed (Hurley, 2000; Hurley et al., 2001; Hurley et al., 2002), and in South Africa (Raghunandan et al., 2007). It is considered to be an ideal tool for modelling applications where meteorological data does not adequately meet requirements for dispersion modelling. TAPM modelled output data is therefore used to augment the site specific surface meteorological data for upper air data for input to CALPUFF.

1.3.1.2 Model accuracy

Air quality models attempt to predict ambient concentrations based on “known” or measured parameters, such as wind speed, temperature profiles, solar radiation and emissions. There are however, variations in the parameters that are not measured, the so-called “unknown” parameters as well as unresolved details of atmospheric turbulent flow. Variations in these “unknown” parameters can result in deviations of the predicted concentrations of the same event, even though the “known” parameters are fixed.

There are also “reducible” uncertainties that result from inaccuracies in the model, errors in input values and errors in the measured concentrations. These might include poor quality or unrepresentative meteorological, geophysical and source emission data, errors in the measured concentrations that are used to compare with model predictions and inadequate model physics and formulation used to predict the concentrations. “Reducible” uncertainties can be controlled or minimised. This is achieved by making use of the most appropriate input data, preparing the input

2 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

files correctly, checking and re-checking for errors, correcting for odd model behaviour, ensuring that the errors in the measured data are minimised and applying appropriate model physics.

Models recommended in the DEA dispersion modelling guideline (DEA, 2012b) have been evaluated using a range of modelling test kits (http://www.epa.gov./scram001). It is therefore not mandatory to perform any modelling evaluations. Rather the accuracy of the modelling in this assessment is enhanced by every effort to minimise the “reducible” uncertainties in input data and model parameterisation.

For GreenCape Atlantis Gas to Power Facility the reducible uncertainty in CALMET and CALPUFF is minimised by:

 Using representative quality controlled observed hourly meteorological data to nudge the meteorological processor to the actual values;  Using 3-years of spatially and temporally continuous surface and upper air meteorological data field for the modelling domain;  Appropriate parameterisation of both models (Tables 8 and 9);  Using representative emission data; and  Using a competent modelling team with considerable experience using CALPUFF.

1.4 Assumptions

 No ambient air quality monitoring is proposed; rather available data from SAAQIS is used;  A human health risk assessment is not proposed, rather the air quality impact assessment is based on predicted pollutant concentrations relative to the NAAQS.  The facility assessment is based on a ‘project envelope’ approach, where a range of options are considered, as such certain design parameters were assumed using reasonable expert judgement.  The diesel storage tanks are not described and are not considered in the assessment.

1.5 Scoping input

Combustion facilities using liquid fuels or gas primarily for steam raising for electricity generation are classified as Listed Activity in terms of Section 21 the NEM: AQA and GN 893, if the design capacity of the individual generating units is equal to or greater than 50 MW heat input (Category 1, sub-category 1.2 (liquid), sub-category 1.4 (gas). The following Minimum Emission Standards apply:

Substance Minimum emission standard 3 (mg/Nm at 3% O2, 273 K and 101.3 kPa) 1 1 Particulate matter 50 or 10 1 2 Sulphur dioxide (SO2) 500 or 400 1 2 3 Oxides of nitrogen (NOX) 250 or 50 mg/Nm expressed as NO2 1: Applies to liquid fuels 2: Applies to gas combustion

3 The storage and handling of petroleum products with a storage capacity of more than 10 000 m is also classified as a Listed Activity (Category 2, sub-category 2.4). Fixed roof tanks vented to the atmosphere or pressure vacuum vents are required for products with a vapor pressure up to 14 kPa, such as diesel.

The National Ambient Air Quality Standards (NAAQS) (GN 1210 of 24 Dec 2009 and GN 486 of 29 June 2012) aim to protect human health from inhalation exposure. They consist of a limit value and a tolerance or permitted frequency of exceedance. The limit value is the fixed concentration level aimed at reducing the harmful effects of a pollutant. The permitted frequency of exceedance is the 99th percentile and represents the tolerated exceedance of the limit value.

3 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Liquid Natural Gas (LNG) will be the primary fuel used for electricity generation in the GreenCape Power Project, but diesel will be used in emergency situations. Emissions of pollutants from the power plant will depend on the fuel used. Pollutants emitted from LNG combustion include oxides of nitrogen (NOX = NO + NO2) and carbon dioxide (CO). Pollutants emitted from diesel combustion include sulphur dioxide (SO2), NOX, CO, benzene and particulates, including respirable PM10 and PM2.5. The combustion of both fuel types also results in CO2 emissions which is a Greenhouse Gas.

The NAAQS related to the pollutants emitted from gas and diesel combustion, and diesel storage and handling are listed in the table below:

Averaging Limit value Number of exceedances Pollutant Period (µg/m3) per annum 1 hour 350 88

SO2 24 hour 125 4 1 year 50 0 1 hour 200 88 NO 2 1 year 40 0 24 hour 75 4 PM 10 1 year 40 0 24 hour 65 0 401 0 252 0 PM 2.5 1 year 25 0 201 0 152 0 1 hour 30 88 CO 8 hours 10 11 Benzene 1 year 5 0 1: Effective date is 1 January 2016 2: Effective date is 1 January 2030

While there is some industrial activity in and around Atlantis, the only major source of air pollutants is the Ankerlig OCGT Power Station, emitting mainly NOX. Other air pollution sources are motor vehicles and windblown dust. Air quality at Atlantis may also be influenced by sources in the City of Cape Town under given meteorological conditions. However, being on the coast it is generally well ventilated by a high frequency of moderate and strong winds that effectively disperse pollutants.

The City of Cape Town’s operates an air quality monitoring station at Atlantis, measuring NO, NO2 and NOX. Ambient concentrations of these compounds are consistently low. The ambient NO2 concentrations are consistently well below the NAAQS.

(see http://web1.capetown.gov.za/web1/NewCityAirpol/default.asp).

An application for an Atmospheric Emission License (AEL) and a supporting Atmospheric Impact Report (AIR) is a requirement of the authorisation process for all Listed Activities. The AIR is also fundamental to the EIA process. For strategic projects the National Air Quality Officer (NAQO) is the AEL Authority, i.e. Dr Thuli Mdluli, Tel: +27 (0)12 310 3436, email: [email protected].

4 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

2 AIR QUALITY IMPACTS

2.1 Nature of the Process

A combined cycle gas turbine (CCGT) plant uses a cycle configuration of combustion turbines, heat recovery steam generators (HRSG), and steam turbines, to generate electricity. The GreenCape Atlantis Facility consists of 4 Combustion turbine and generator sets (Table 2-1) producing a combined power output of approximately 1500 MW; Heat recovery steam generators; and Dry cooling radiator systems (Figure 2-1).

2.2 Process details and mass balance

Gas turbines, also called “combustion turbines”, are used in a broad scope of applications including electric power generation. The primary fuels used in gas turbines are natural gas and diesel. A gas turbine is an internal combustion engine that operates with rotary rather than reciprocating motion. Gas turbines are essentially composed of three major components: compressor, combustor, and power turbine. In the compressor section, ambient air is drawn in and compressed up to 30 times ambient pressure and directed to the combustor section where fuel is introduced, ignited, and burned.

The combustion process in a gas turbine can be classified as diffusion flame combustion, or lean premix staged combustion. For lean-premix combustors, fuel and air are thoroughly mixed in an initial stage resulting in a uniform, lean, unburned fuel/air mixture which is delivered to a secondary stage where the combustion reaction takes place. Manufacturers use different types of fuel/air staging, including fuel staging, air staging, or both; however, the same staged, lean-premix principle is applied. Gas turbines using staged combustion are also referred to as Dry Low NOX combustors.

With reference to Figure 2.2, hot gases from the combustion section are diluted with additional air from the compressor section and directed to the power turbine section at temperatures up to 2600 ̊F (1427 ˚C). Energy from the hot exhaust gases, which expand in the power turbine section, are recovered in the form of shaft horsepower. More than 50 percent of the shaft horsepower is needed to drive the internal compressor and the balance of recovered shaft horsepower is available to drive an external load. Gas turbines may have one, two, or three shafts to transmit power between the inlet air compression turbine, the power turbine, and the exhaust turbine. The heat content of the exhaust gases exiting the turbine are recovered, with or without supplementary firing, to raise steam for a steam turbine Rankine cycle (combined cycle or repowering).

A combined cycle gas turbine is a gas turbine with a HRSG applied at electric utility sites. The gas turbine drives an electric generator, and the steam from the HRSG drives a steam turbine which also drives an electric generator. A supplementary-fired boiler can be used to increase the steam production. The thermal efficiency of a combined cycle gas turbine is between 38 percent and 60 percent.

The primary pollutants from gas turbine engines are nitrogen oxides (NOx), carbon monoxide (CO), and to a lesser extent, volatile organic compounds (VOC). Particulate matter (PM) is also a primary pollutant for gas turbines using liquid fuels. Nitrogen oxide formation is strongly dependent on the high temperatures developed in the combustor. Carbon monoxide, VOC, hazardous air pollutants (HAP), and PM are primarily the result of incomplete combustion. Trace to low amounts of HAP and sulphur dioxide (SO2) are emitted from gas turbines. Emissions of sulphur compounds, mainly SO2, are directly related to the sulphur content of the fuel.

Table 2-1: Unit processes

Unit Process Function of Unit Process Batch or Continuous Process Unit 1 Power generation process Continuous

5 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Unit 2 Power generation process Continuous Unit 3 Power generation process Continuous Unit 4 Power generation process Continuous

Figure 2-1: Relative location of the different process units at GreenCape Atlantis Gas to Power Facility

6 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Figure 2-2: A basic block flow diagram for the operation at GreenCape Atlantis Gas to Power Facility

2.3 Raw materials and products

The raw materials and the permitted annual consumption rates are presented in Table 2-2 for the proposed production capacity (Table 2-3).

Table 2-2: Raw material used at GreenCape Atlantis Gas to Power Facility

Raw material Maximum permitted consumption rate Units (Volume) (quantity / period) Liquid natural gas 6 600 000 m3/annum Diesel (Backup only) 2 437 277 m3/annum

Table 2-3: Production rates at GreenCape Atlantis Gas to Power Facility

Product/by-product Maximum Production capacity Units permitted (quantity / period) (Volume) Electricity 1 500 MW

2.4 Air pollutants resulting from power generation

Pollutants emitted from LNG combustion include oxides of nitrogen (NOX = NO + NO2) and carbon monoxide (CO). Pollutants emitted from diesel combustion include sulphur dioxide (SO2), NOX, CO, benzene and particulates, including respirable PM10 and PM2.5. The combustion of both fuel types also results in CO2 emissions, which is a Greenhouse Gas.

7 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

2.5 Atmospheric emissions

2.5.1 Pollutants

The major pollutants emitted from LNG combustion at GreenCape Atlantis Gas to Power Facility are NOX and CO. Diesel usage also produces SO2 and particulates.

2.5.1.1 Sulphur dioxide

Dominant sources of SO2 include fossil fuel combustion from industry and power plants. SO2 is emitted when coal is burnt for energy. The combustion of fuel oil also results in high SO2 emissions. Domestic coal or kerosene burning can thus also result in the release of SO2. Motor vehicles also emit SO2, in particular diesel vehicles due to the higher sulphur content of diesel fuel. Smelting of mineral ores can also result in the production of SO2, because metals usually exist as sulphides within the ore.

On inhalation, most SO2 only penetrates as far as the nose and throat, with minimal amounts reaching the lungs, unless the person is breathing heavily, breathing only through the mouth, or if the concentration of SO2 is high (CCINFO, 1998). The acute response to SO2 is rapid, within 10 minutes in people suffering from asthma (WHO, 2005). Effects such as a reduction in lung function, an increase in airway resistance, wheezing and shortness of breath, are enhanced by exercise that increases the volume of air inspired, as it allows SO2 to penetrate further into the respiratory tract (WHO, 1999). SO2 reacts with cell moisture in the respiratory system to form sulphuric acid. This can lead to impaired cell function and effects such as coughing, broncho- constriction, exacerbation of asthma and reduced lung function.

2.5.1.2 Nitrogen dioxide

Nitrogen dioxide (NO2) and nitric oxide (NO) are formed simultaneously in combustion processes and other high temperature operations such as metallurgical furnaces, blast furnaces, plasma furnaces, and kilns. NOX is a term commonly used to refer to the combination of NO and NO2. NOX can also be released from nitric acid plants and other types of industrial processes involving the generation and/or use of nitric acid. NOX also forms naturally through denitrification by anaerobic bacteria in soils and plants. Lightning is also a source of NOX.

The route of exposure to NO2 is inhalation and the seriousness of the effects depend more on the concentration than on the length of exposure. The site of deposition for NO2 is the distal lung where NO2 reacts with moisture in the fluids of the respiratory tract to form nitrous and nitric acids. About 80 to 90% of inhaled nitrogen dioxide is absorbed through the lungs (CCINFO, 1998). Nitrogen dioxide (present in the blood as the nitrite ion) oxidises unsaturated membrane lipids and proteins, which then results in the loss of control of cell permeability. Nitrogen dioxide caused decrements in lung function, particularly increased airway resistance. People with chronic respiratory problems and people who work or exercise outside will be more at risk to NO2 exposure (EAE, 2006).

2.5.1.3 Particulate matter

Particulate matter is a broad term used to describe the fine particles found in the atmosphere, including soil dust, dirt, soot, smoke, pollen, ash, aerosols and liquid droplets. The most distinguishing characteristic of PM is the particle size and the chemical composition. Particle size has the greatest influence on the behaviour of PM in the atmosphere with smaller particles tending to have longer residence times than larger ones. PM is categorised, according to particle size, into TSP, PM10 and PM2.5.

Total suspended particulates (TSP) consist of all sizes of particles suspended within the air smaller than 100 micrometres (µm). TSP is useful for understanding nuisance effects of PM, e.g. settling on houses, deposition on and discolouration of buildings, and reduction in visibility.

8 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

PM10 describes all particulate matter in the atmosphere with a diameter equal to or less than 10 µm. Sometimes referred to simply as coarse particles, they are generally emitted from motor vehicles (primarily those using diesel engines), factory and utility smokestacks, construction sites, tilled fields, unpaved roads, stone crushing, and burning of wood. Natural sources include sea spray, windblown dust and volcanoes. Coarse particles tend to have relatively short residence times as they settle out rapidly and PM10 is generally found relatively close to the source except in strong winds.

PM2.5 describes all particulate matter in the atmosphere with a diameter equal to or less than 2.5 µm. They are often called fine particles, and are mostly related to combustion (motor vehicles, smelting, incinerators), rather than mechanical processes as is the case with PM10. PM2.5 may be suspended in the atmosphere for long periods and can be transported over large distances. Fine particles can form in the atmosphere in three ways: when particles form from the gas phase, when gas molecules aggregate or cluster together without the aid of an existing surface to form a new particle, or from reactions of gases to form vapours that nucleate to form particles.

Particulate matter may contain both organic and inorganic pollutants. The extent to which particulates are considered harmful depends on their chemical composition and size, e.g. particulates emitted from diesel vehicle exhausts mainly contain unburned fuel oil and hydrocarbons that are known to be carcinogenic. Very fine particulates pose the greatest health risk as they can penetrate deep into the lung, as opposed to larger particles that may be filtered out through the airways’ natural mechanisms.

In normal nasal breathing, particles larger than 10 μm are typically removed from the air stream as it passes through the nose and upper respiratory airways, and particles between 3 μm and 10 μm are be deposited on the mucociliary escalator in the upper airways. Only particles in the range of 1 μm to 2 μm penetrate deeper where deposition in the alveoli of the lung can occur (WHO, 2003). Coarse particles (PM10 to PM2.5) can accumulate in the respiratory system and aggravate health problems such as asthma. PM2.5, which can penetrate deeply into the lungs, are more likely to contribute to the health effects (e.g. premature mortality and hospital admissions) than coarse particles (WHO, 2003).

2.5.1.4 Benzene (C6H6)

Benzene (C6H6) is a natural component of crude oil, petrol, diesel and other liquid fuels and is emitted when these fuels are combusted. Diesel exhaust emissions therefore contain benzene. After exposure to benzene, several factors determine whether harmful health effects will occur, as well as the type and severity of such health effects. These factors include the amount of benzene to which an individual is exposed and the length of time of the exposure. For example, brief exposure (5–10 minutes) to very high levels of benzene (14000 – 28000 µg/m3) can result in death (ATSDR, 2007). Lower levels (980 – 4200 µg/m3) can cause drowsiness, dizziness, rapid heart rate, headaches, tremors, confusion and unconsciousness. In most cases, people will stop feeling these effects when they are no longer exposed and begin to breathe fresh air. Inhalation of benzene for long periods may result in harmful effects in the tissues that form blood cells, especially the bone marrow. These effects can disrupt normal blood production and cause a decrease in important blood components. Excessive exposure to benzene can be harmful to the immune system, increasing the chance for infection. Both the International Agency for Cancer Research and the US-EPA have determined that benzene is carcinogenic to humans as long-term exposure to benzene can cause leukaemia, a cancer of the blood-forming organs.

2.5.1.5 Carbon monoxide (CO)

Carbon monoxide (CO) is a product of incomplete combustion of fossil fuels. It is predominantly formed in internal combustion engines of motor vehicles, but the combustion of any carbon-based material can release CO. Chemical reactions in the atmosphere may also lead to the formation of CO by the oxidation of other carbon-based gases such as methane. Decomposition of organic material within soils can also result in the release of CO. When inhaled, CO enters the blood

9 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

stream by crossing the alveolar, capillary and placental membranes. In the bloodstream approximately 80-90% of absorbed CO binds with haemoglobin to form carboxyhaemoglobin. The haemoglobin affinity for CO is approximately 200-250 times higher than that of oxygen. Carboxyhaemoglobin reduces the oxygen carrying capacity of the blood and reduces the release of oxygen from haemoglobin, which leads to tissue hypoxia. This may lead to neurological effects and sometimes delayed severe neurological effects that may include impaired coordination, vision problems, reduced vigilance and cognitive ability, reduced manual dexterity, and difficulty in performing complex tasks (WHO, 1999).

2.5.2 Point source emissions

The physical data for the stacks at GreenCape Atlantis Gas to Power Facility are listed in Table 2-4. Emission concentrations and emission rates for proposed production levels are shown in

Table 2-5.

NB. Emission release temperature and Emission exit velocity were not provided and a reasonable assumption of design parameters was made.

Table 2-4: Point sources at GreenCape Atlantis Gas to Power Facility

Source Stack Stack Latitude Longitude Emission Emission Description height diameter of centre of centre release exit (m) (m) (UTM) (UTM) temperature velocity (K) (m/s) Stack 1 30 5 265227 6279395 800 25 Stack 2 30 5 265158.5 6279493 800 25 Stack 3 30 5 265180.3 6279462 800 25 Stack 4 30 5 265203.9 6279428 800 25

Emission concentrations for NO2, SO2, PM10, CO and benzene for this scenario are listed in

Table 2-5. Emission concentrations are only presented for pollutants to which minimum emission standards apply, viz. SO2, NOX, and PM10.

NB. Volumetric flow rate was not supplied and an assumed flow rate of 2 188 620 Nm3/hour was used to calculate emission concentrations.

Table 2-5: Average proposed emission concentrations (mg/Nm3) and rates (tons/year) at GreenCape Atlantis Gas to Power Facility

LNG Emission rate (tons/annum) Emission concentration (mg/Nm3)* SO2 NOX PM10 CO Benzene SO2 NOX PM10 Stack 1 1.9 55 3.7 8.4 0.007 0.1 2.9 0.19 Stack 2 1.9 55 3.7 8.4 0.007 0.1 2.9 0.19 Stack 3 1.9 55 3.7 8.4 0.007 0.1 2.9 0.19 Stack 4 1.9 55 3.7 8.4 0.007 0.1 2.9 0.19

Diesel Emission rate (tons/annum) Emission concentration (mg/Nm3)* SO2 NOX PM10 CO Benzene SO2 NOX PM10 Stack 1 18 493 6.7 1.8 0.031 1.0 25.7 0.35 Stack 2 18 493 6.7 1.8 0.031 1.0 25.7 0.35

10 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Stack 3 18 493 6.7 1.8 0.031 1.0 25.7 0.35 Stack 4 18 493 6.7 1.8 0.031 1.0 25.7 0.35

* Reference conditions are 15% O2, 273 K and 101.3 kPa

CO2 emissions for the facility were estimated at 246592.5 tons per annum for the LNG scenario, and 351954.7 tons per annum for the diesel scenario.

2.5.2.1 Fugitive emissions

No fugitive emissions are expected from the engines.

2.6 Emission Control Officer

The emission control officer/s for the relevant listed activities has not as yet been appointed. Upon appointment the relevant contact details will be sent to the relevant Department/s.

2.7 Authorisation Details

As this is a new facility, no existing authorisations are in place.

2.8 Modelling contractor

The dispersion modelling supporting the application for the GreenCape Atlantis Gas to Power Facility is conducted by:

Company: uMoya-NILU Consulting (Pty) Ltd Modellers: Atham Raghunandan and Sarisha Perumal Contact details: Tel: 031 262 3265

3 Description of affected environment

3.1 Enterprise Details

Entity details for City of Cape Town’s (CoCT) GreenCape Atlantis Gas to Power Facility are listed in

Table 3-1.

Table 3-1: Entity details

Entity Name: City of Cape Town Metropolitan Municipality Trading as: See above Type of Entity, e.g. Company/Close Government entity Corporation/Trust, etc.: Company/Close Corporation/Trust N/A Registration Number (Registration Numbers if Joint Venture): Registered Address: 13th Floor, Civic Centre, 12 Hertzog Boulevard, Cape Town Postal Address: Private Bag X9181 Cape Town 8001 Telephone Number (General): 021 400 2366 Fax Number (General): 021 4195303 Company Website: https://www.capetown.gov.za

11 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Industry Type/Nature of Trade: Municipality Name of the Landowner/s or Andre Alfred Human (CoCT) Landlord/s: Name of Mortgage Bondholder/s (if N/A any): Deeds Office Registration Number N/A of Mortgage Bond: Land Use Zoning as per Town Industrial Planning Scheme: Land Use Rights if outside Town n/a Planning Scheme:

3.2 Location and extent

GreenCape Atlantis Gas to Power Facility is located in the Atlantis Industrial Area, City of Cape Town in the Western Cape Province (Figure 3-1). Site information is provided and the relative location to key landmarks is shown (Table 3-2). Only Site 2 is considered for this AIR.

Figure 3-1: Relative location of the GreenCape Atlantis Gas to Power Facility

Table 3-2: Site information

Physical Address of the Licenced Premises: n/a Description of Site (Where No Street Address): Cape Farm 1183 Property Registration Number (Surveyor-General C 0 1 6 0 0 0 0 0 0 0 1 1 8 3 0 0 0 0 0 1

Code): Coordinates (latitude, longitude) of Approximate -33.600156° S, 18.469674° E Centre of Operations (Decimal Degrees):

12 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Coordinates (UTM) of Approximate Centre of 34 H, 265210.94 m E, 6279306.33 m S Operations: Extent (km²): 0.3865 Elevation Above Mean Sea Level (m) 131 m Province: Western Cape District/Metropolitan Municipality: City of Cape Town Local Municipality: n/a Designated Priority Area (if applicable): n/a

Sensitive receptors that are located within a 5 km radius of the GreenCape Atlantis Gas to Power Facility are shown in Figure 3-2. The Atlantis residential area lies to the north and east of the Industrial area, with schools and a hospital within the area. Various areas fall within the larger residential area, these are Avondale, Protea Park, Robinvale, Saxonsea and Witsand. Wesfleur is an unpopulated area to the north as well. To the south and east are farming areas, which are sparsely populated. Open, uncultivated land lies to the west.

Figure 3-2: Land use and sensitive receptors surrounding the site, shown by a green block

3.3 Climatic conditions

3.3.1 Temperature and rainfall

Average temperature at Atlantis varies seasonally, with moderately warm summers from December to February, and cool winters from June to August. Average temperatures in summer peak at 20 ̊C and winter temperatures lower to 11 ̊C (Figure 3-3). Average rainfall is relatively low in the area, with 466 mm recorded for the year. The area is part of a winter rainfall region, with peak average rainfall recorded in July. Summers are significantly drier, with lowest mean rainfall of 10 mm recorded in February.

13 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Figure 3-3: Monthly average temperature and rainfall at Atlantis (SAWS, 1990)

3.3.2 Wind

Generally, four synoptic weather systems control Cape Town’s meteorology. In summer, the ridging Atlantic Ocean Anticyclone results in a high frequency of strong southeasterly winds and partly cloudy skies. Frontal weather systems in winter result in northwesterly winds in advance of the front with low temperatures and cloudy conditions, followed by southwesterly winds with the passage of the front, cold temperatures, cloudy skies and rainfall. In late winter and spring, the frontal systems are weaker and pressure gradients are generally slack. Clear skies result is the development of light berg winds and strong surface temperature inversions at night. In summer, the Atlantic Ocean Anticyclone is situated over the southern parts of the subcontinent resulting in light winds, clear skies and an elevated temperature inversion.

Winds at Atlantis are illustrated in the annual windrose in Figure 3-4. The windrose illustrates the frequency of hourly wind from the 16 cardinal wind directions, with wind indicated from the direction it blows, i.e. easterly winds blow from the east. It also illustrates the frequency of average hourly wind speed in six wind speed classes. The windrose shows no distinct dominant wind direction, with winds being recorded in all directions. A high frequency of strong winds are observed from the southwest. Westerly winds also occur, though less frequently. Light to gentle winds prevail in the area.

Figure 3-4: Annual windrose for Atlantis

14 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

3.4 Current status of ambient air quality

3.4.1 Air pollutant dispersion

The air pollution dispersion of an area refers to the ability of atmospheric processes, or meteorological mechanisms, to disperse and remove pollutants from the atmosphere. Dispersion comprises both vertical and horizontal components of motion. The vertical component is defined by the stability of the atmosphere and the depth of the surface mixing layer. The horizontal dispersion of pollution in the boundary layer is primarily a function of the wind field and atmospheric stability. The wind speed determines the rate of downwind transport and wind direction and the variability in wind direction determines the general path of pollutant. Atmospheric stability, or instability, determines the ability of the atmosphere to mix and dilute pollutants. Stability is a function of solar radiation (thermal turbulence) and wind speed and surface roughness which induce mechanical turbulence. The dispersion potential of an area therefore experiences diurnal and seasonal changes.

By day with strong insolation (in coming solar radiation) and stronger winds the dispersion potential is generally efficient through vertical dilution and horizontal dispersion. The dispersion potential is generally better on summer days than winter days. At night as the surface temperature inversion develops the lowest layer of the atmosphere becomes more and more stable, reaching a maximum at sunrise. As a result, the dispersion potential typically becomes less efficient during the night and the poorest conditions generally occur at sunrise. Thermal turbulence disappears when the sun sets, and mechanical turbulence decreases as the wind speeds drops at night. Pollutants tend to accumulate near the point of release under these conditions, particularly if these are released close to ground level. The dispersion potential is generally poorer on winter nights than summer nights.

3.4.2 Ambient air quality monitoring

SO2 concentrations at Atlantis are currently being monitored by the City of Cape Town. Low concentrations are recorded and they are compliant with the NAAQS (Figure 3-5)

Figure 3-5: Hourly SO2 concentrations at Atlantis (www.saaqis.org.za)

15 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

3.4.3 Source apportionment

No source apportionment can be done as the facility is not constructed. Existing sources in the area include the Eskom Ankerlig power station, manufacturing facilities in the Atlantis Industrial Area, the R27 and N7 roads, residential areas, and open veld areas. The Ankerlig power station also utilises gas as a fuel source, therefore similar pollutant emissions can be expected. This can contribute to cumulative impacts.

4 IDENTIFICATION OF ISSUES

4.1 Construction and decommissioning

Construction work will entail building of new infrastructure and heavy construction work with concrete, steel, piping, etc. Dust emissions during construction result mainly from earth moving activities (scraping, compacting, excavation, grading), movement of construction vehicles and back-fill operations. Dust emissions during decommissioning result from the demolition of structures, earth moving activities (scraping, compacting, excavation, grading), movement of construction vehicles and back-fill operations. All aspects of the construction inherently generate dust, but the movement of construction vehicles on paved and unpaved surfaces at the construction site are generally the largest source of dust. Construction vehicles will be in operation for the duration of the construction and decommissioning. Dust is also easily entrained from exposed areas by the wind.

The impact of dust is more of a nuisance nature and does not typically pose a health risk due to its typically coarse size. The impact of dust from the construction and decommissioning activities on air quality is expected to be relatively short lived, i.e. limited to the duration of the construction or decommissioning. The impacts are also expected to be localised and limited to the area adjacent to the activity.

4.2 Operations

The impacts associated with the operational phases are assessed by the comparison of predicted ambient concentrations with the National Ambient Air Quality Standards. These are health based standards, i.e. ambient concentrations below the standards imply that air quality is acceptable while exposure to ambient concentrations above the standard imply that there is a risk to human health, particularly for sensitive individuals. The ambient standards for a given pollutant consist of a limit value and a permitted frequency of exceedance.

The limit value is the fixed concentration level aimed at reducing the harmful effects of a pollutant. The permitted frequency of exceedance represents the tolerated exceedance of the limit value. Compliance with the standard therefore implies that ambient concentrations are below the limit value and the frequency of exceedance does not exceed the permitted tolerance.

4.2.1 Modelled ambient concentrations

Two scenario’s were assessed, viz. the CCGT process running on LNG or on diesel fuel. Predicted ambient concentrations of pollutants emitted for each scenario are presented in Figures 4-1 to 4-5 as isopleths in μg/m3

The effect of the prevailing southeasterly and northwesterly winds at Atlantis is evident in the annual dispersion pattern of SO2 (Figures 4-1 and 4-2), extending along these axes. Evidence of southwesterly winds extending the dispersion pattern northeastwards is also seen. Ambient concentrations for hourly SO2 are predicted to be very low for both scenario’s (Figure 4.-1). The predicted SO2 concentrations are an order of magnitude greater when diesel is used. For both scenario’s, the predicted concentrations are well below the NAAQS of 350 μg/m3 throughout the modelling domain.

16 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

a) b)

Figure 4-1: Predicted maximum 1-hour SO2 concentrations for a) LNG and b) diesel

Predicted hourly ambient concentrations of NO2 are low for both fuel type scenario’s, with diesel scenario values being an order of magnitude higher (Figure 4-2). A similar dispersion pattern is observed, with maximum ambient concentrations to the north of the site. The predicted concentrations are compliant with the NAAQS of 200 μg/m3.

Figure 4-2: Predicted maximum 1-hour NO2 concentrations for a) LNG and b) diesel

Predicted daily ambient concentrations of PM10 are very low (Figure 4-3), and are compliant with the NAAQS of 75 μg/m3. Dispersion of pollutants extends in a northerly direction from the plant.

17 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Figure 4-3: Predicted maximum 24-hour PM10 concentrations for a) LNG and b) diesel

Predicted hourly ambient CO concentrations are very low (Figure 4-4) and compliant with the NAAQS of 30 μg/m3. Predicted CO concentrations are slightly higher with LNG use than diesel. Dispersion extends to the north from the site.

Figure 4-4: Predicted maximum 1-hour CO concentrations for a) LNG and b) diesel

Predicted benzene concentrations are very low and can be considered of very low significance from this facility (Figure 4-5). Ambient concentrations are predicted to comply with the NAAQS of 5 μg/m3.

18 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Figure 4-5: Predicted annual average benzene concentrations for a) LNG and b) diesel

Predicted maximum concentrations of all pollutants are very low, with NO2 in the diesel scenario being the only elevated value observed. This maximum concentration is predicted to occur north of the facility, due to the stack and plume parameters used for modelling. No exceedances of the NAAQS are predicted from the facility.

Table 4-1: Predicted concentrations for all pollutants

Pollutant Averaging period LNG Diesel

SO2 1-hour 0.040 0.375

NO2 1-hour 0.916 8.211

PM10 24-hour 0.039 0.070 CO 1-hour 0.175 0.037 Benzene Annual average 0.000005 0.000024

5 LEGAL REQUIREMENTS

5.1 National Environmental Management Act

Section 28 of the National Environmental Management Act (NEMA) (Act No. 107 of 1998) addresses the duty of care and remediation of environmental damage. Sub-section 1 and 3 apply to CoCT’s GreenCape Atlantis Gas to Power Facility and air quality management. These are:

Sub-section 1: Every person who causes, has caused or may cause significant pollution or degradation of the environment must take reasonable measures to prevent such pollution or degradation from occurring, continuing or recurring, or, in so far as such harm to the environment is authorised by law or cannot reasonably be avoided or stopped, to minimise and rectify such pollution or degradation of the environment.

Sub-section 3: The measures required in terms of the above may include the following: i) Investigate, assess and evaluate the impact on the environment; ii) Inform and educate employees about the environmental risks of their work and the manner in which their tasks must be performed in order to avoid causing significant pollution or degradation of the environment; iii) Cease, modify or control any act, activity or process causing the pollution or degradation;

19 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

iv) Contain or prevent the movement of pollutants or the cause of degradation; v) Eliminate any source of the pollution or degradation; vi) Remedy the effects of the pollution or degradation.

Considering the requirements of Section 28 of the NEMA, CoCT is proactive in investigating, assessing and evaluating the impact of their emissions on ambient air quality through ambient monitoring and assessment studies.

5.2 The Air Quality Act

5.2.1 Listed activities and Minimum Emission Standards

Combustion facilities using liquid fuels or gas primarily for steam raising for electricity generation are classified as Listed Activity in terms of Section 21 of the NEM: AQA and GN 893, if the design capacity of the individual generating units is equal to or greater than 50 MW heat input (Category 1, sub-category 1.2 (liquid), sub-category 1.4 (gas). Listed Activities require an Atmospheric Emission Licence (AEL) in order to operate. Minimum emission standards are defined for existing and new plants (Table 5-1).

Table 5-1: Applicable minimum emission standards

Substance Plant status MES mg/Nm3 under normal conditions of 15%* O2, 273 K and 101.3 kPa Gas turbines Particulate matter New 10 Existing 10 Sulphur dioxide New 400 Existing 500 Oxides of nitrogen New 50 Existing 300 Liquid fuels Particulate matter New 50 Existing 75 Sulphur dioxide New 500 Existing 3 500 Oxides of nitrogen New 250 Existing 1 100 * diesel combustion is evaluated with reference oxygen concentration of 3%

5.2.2 Atmospheric Emission Licence (AEL)

An AEL application is required to be prepared and submitted upon finalisation of the project design. The licensing authority is the Department of Environmental Affairs, National Air Quality Officer, Dr Thulie Mdluli.

5.2.3 Ambient air quality standards

The effects of air pollutants on human health occur in a number of ways with short-term, or acute effects, and chronic, or long-term, effects. Different groups of people are affected differently, depending on their level of sensitivity, with the elderly and young children being more susceptible. Factors that link the concentration of an air pollutant to an observed health effect are the level and the duration of the exposure to that particular air pollutant.

Criteria pollutants occur ubiquitously in urban and industrial environments. Their effects on human health and the environment are well documented (e.g. WHO, 1999; 2003; 2005). South Africa has established national ambient air quality standards for the criteria pollutants, i.e. SO2, nitrogen

20 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

dioxide (NO2), carbon monoxide (CO), respirable particulate matter (PM10), ozone (O3), lead (Pb) and benzene (C6H6) (DEA, 2009) and PM2.5 (DEA, 2012a). The National Ambient Air Quality Standards for SO2, NO2, PM10 and PM2.5, CO and benzene are listed in Table 5-2.

The national ambient air quality standard consists of a limit value and a permitted frequency of exceedance. The limit value is the fixed concentration level aimed at reducing the harmful effects of a pollutant. The permitted frequency of exceedance represents the tolerated exceedance of the limit value and is equivalent to the 99th percentile, accounting for outliers in the data. Compliance with the ambient standard implies that the frequency of exceedance of the limit value does not exceed the permitted tolerance. Being a health-based standard, ambient concentrations below the standard imply that air quality is acceptable and poses little or no risk to human health; while exposure to ambient concentrations above the standard implies that there is a risk to human health.

Table 5-2: National ambient air quality standards (DEA, 2009; DEA, 2012a)

Pollutants Averaging period Limit value Number of permissible (µg/m3) exceedances per annum 1 hour 350 88 SO2 24 hour 125 4 1 year 50 0 NO2 1 hour 200 88 1 year 40 0

PM10 24-hour 75 4 Calendar year 40 0 1 2 PM2.5 24-hour 65 (40) (25) 0 Calendar year 25 (20)1 (15)2 0 Benzene Calendar year 5 0 CO 1 hour 30 88 8 hours 10 11 1: Implementation date 1 January 2016 2: Implementation date 1 January 2030

6 IMPACT ASSESSMENT

Impacts can generally be categorised as direct, indirect or cumulative. Direct impacts are impacts that are caused directly by the project or activity in isolation of other sources and generally occur at the same time and place as the activity. Indirect impacts are indirect or induced changes that may occur as a result of the activity. These types of impacts include all the potential impacts that do not manifest immediately when the activity is undertaken or which occur at a different place as a result of the activity. Cumulative impacts are impacts that result from the incremental impact of the proposed activity on a common resource when added to the impacts of other past, present or reasonably foreseeable future activities.

For this study, direct impacts will result from the inhalation of pollutants emitted during the operational life of the activity. Direct impacts from dust will also result from the construction and decommissioning activities. Indirect impacts are observed in the acid deposition caused by atmospheric emissions generated by the activity’s operations.

6.1 Status

The status of an impact is assessed according to the following criteria:

Positive – environment overall will benefit from impact Negative - environment overall will be adversely affected by impact Neutral - environment overall will not be affected

21 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

All impacts generated by the activity are negative.

6.2 Extent

The extent of impacts are assessed in accordance with the following criteria: 0 – No effect 1 - Limited to the site and its immediate surroundings 2 - Local/municipal extending only as far as the local community or urban area 3 - Provincial/regional 4 - National i.e. South Africa 5 - Across international borders

ACTIVITY EXTENT OF IMPACTS DIRECT INDIRECT CUMULATIVE Construction/ decommissioning Local n/a Local Operations SO2 Local Local Local NO2 Local Local Local PM10 Local n/a Local Benzene Local n/a Local CO Local n/a Local

6.3 Duration

The duration of impacts are assessed in accordance with the following criteria: 0 – None (impact will not occur) 1 - Immediate (less than 1 year) 2 - Short term (1-5 years) 3 - Medium term (6-15 years) 4 - Long term (the impact will cease after the operational life span of the project) 5 - Permanent (no mitigation measures of natural process will reduce the impact after construction)

ACTIVITY DURATION OF IMPACTS DIRECT INDIRECT CUMULATIVE Construction/ decommissioning Immediate n/a Immediate Operations SO2 Long-term Long-term Long-term NO2 Long-term Long-term Long-term PM10 Long-term n/a Long-term Benzene Long-term n/a Long-term CO Long-term n/a Long-term

6.4 Intensity

The intensity of impacts may be assessed in accordance with the following criteria: 0 - None (where the aspect will have no impact on the environment) 4 - Low (where the impact affects the environment in such a way that natural, cultural and social functions and processes are slightly affected), 6 - Medium (where the affected environment is altered but natural, cultural and social functions and processes continue albeit in a modified way), 8 - High (where natural, cultural or social functions or processes are altered to the extent that it will temporarily or permanently cease)

ACTIVITY INTENSITY OF IMPACTS

22 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

DIRECT INDIRECT CUMULATIVE Construction/ decommissioning Low n/a Low Operations SO2 Low Low Low NO2 Low Low Low PM10 Low n/a Low Benzene Low n/a Low CO Low n/a Low

6.5 Probability

The probability of impacts are assessed in accordance with the following scoring criteria: 0 - None (impact will not occur) 1 - Improbable (the possibility of the impact materialising is very low as a result of design, historic experience or implementation of adequate mitigation measures) 2 - Probable (there is a possibility that the impact will occur) 4 - Highly probable (it is most likely that the impact will occur) 5 - Definite (the impact will occur regardless of the implementation of any prevention or corrective actions)

ACTIVITY PROBABILITY OF IMPACTS DIRECT INDIRECT CUMULATIVE Construction/ decommissioning Highly probable n/a Probable Operation SO2 Highly probable Probable Probable NO2 Highly probable Probable Probable PM10 Highly probable n/a Probable Benzene Highly probable n/a Probable CO Highly probable n/a Probable

6.6 Reversibility and irreplaceability

Impacts can be classified as Non-reversible, Low, Moderate, or High. Non-reversible impacts are least desirable as original environmental conditions cannot be realised. Highly reversible impacts are most desirable as original environmental conditions can be easily realised following closure of the activity.

ACTIVITY REVERSIBILITY OF IMPACTS DIRECT INDIRECT CUMULATIVE Construction/ decommissioning High n/a High Operation SO2 High High High NO2 High High High PM10 High n/a High Benzene High n/a High CO High n/a High

Irreplaceability can be classified as replaceable, low, moderate, or high. Replaceable resources are most desirable, with high irreplaceability indicating the least favourable outcome, with significant deterioration of the resource.

ACTIVITY IRREPLACEABILITY OF IMPACTS DIRECT INDIRECT CUMULATIVE Construction/ decommissioning Replaceable n/a Replaceable Operation SO2 Replaceable Replaceable Replaceable

23 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

NO2 Replaceable Replaceable Replaceable PM10 Replaceable n/a Replaceable Benzene Replaceable n/a Replaceable CO Replaceable n/a Replaceable

6.7 Significance

Significance can be assessed with the following criteria:

Low – where the impact will not have an influence on the decision or require to be significantly accommodated in the project design Medium – where the impact could have influence on the environment which will require modification of the project design or alternative mitigation High – where it could have a ‘no-go’ implication for the project unless mitigation or re-design is practically achieved

ACTIVITY SIGNIFICANCE OF IMPACTS DIRECT INDIRECT CUMULATIVE Construction/ decommissioning Low n/a Low Operation SO2 Low Low Low NO2 Low Low Low PM10 Low n/a Low Benzene Low n/a Low CO Low n/a Low

24 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

6.8 Summary of impacts with mitigation

Impacts from construction and decommissioning are of low significance. They are estimated with a medium confidence as the level of construction activities are not detailed. No mitigation is necessary, however, measures are suggested to minimise the nuisance impacts arising from the activities.

Impacts from operations are estimated to be of low significance for all pollutants considered, viz. SO2, NO2, PM10, benzene and CO. the estimation is stated with medium confidence as details relating to emission parameters were not specified and were assumed. This may affect ambient concentrations, if the facility does not meet the design parameters. No mitigation is needed for operational activities.

In summarising the impacts, the highest score in each category described above is selected (Table 6-1).

Table 6-1: Impact assessment summary

Significance Impact Revers- Irreplace- Confidence Status Extent Duration Intensity Probability description ibility ability without with mitigation mitigation CONSTRUCTION/ DECOMMISSIONING Dust and other Replace- Negative Local Immediate Reversible Low Probable Low Low Med pollutants able IMPACTS FROM OPERATIONS Replace- Highly Low SO Negative Local Long Reversible Low Low Med 2 able probable Replace- Highly Low NO Negative Local Long Reversible Low Low Med 2 able probable Replace- Highly Low PM Negative Local Long Reversible Low Low Med 10 able probable Replace- Highly Low Benzene Negative Local Long Reversible Low Low Med able probable Replace- Highly Low CO Negative Local Long Reversible Low Low Med able probable

25 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Mitigation measures are suggested with respect to construction and decommissioning activities to limit nuisance emissions (Table 6-2). These should be incorporated into the EMPr. Due to the low predicted impacts, no mitigation measures are suggested for operational activities.

Table 6-2: Mitigation summary for EMPr

Impact Recommended Mitigation/Management action Monitoring Methodology Frequency Responsibility Dust and other pollutants  Loads on vehicles carrying dusty construction Include dust management On-going during Contractor from construction and materials should be covered in contractors contract construction decommissioning  Loading and unloading bulk construction should be conditions in areas protected from the wind on in calm conditions  Vehicles carrying dusty materials should be cleaned before leaving the site  Limit access to construction site to construction vehicles only  Impose vehicle speed restrictions on the construction site  Maintain high moisture content on exposed surface and roads by spraying with water  Maintenance programme for construction vehicles to ensure optimum performance reduced emissions

Employing the generic design parameters provided for the project, it is predicted that the site operations will low generate emissions, low ambient concentrations, and low environmental impacts overall. Mitigation measures are recommended for construction and decommissioning activities only. It is a reasonable opinion that the project should be authorised considering the outcomes of this impact assessment.

26 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

7 REFERENCES

Agency for Toxic Substances and Disease Registry (ATSDR) 2007. Online [Available]: http://www.atsdr.cdc.gov/phshome-c.html 19 May 2008.

CCINFO, 2000. The Canadian Centre for Occupational Health and Safety database. http://ccinfoweb.ccohs.ca. Visited on 21 July 2003. DEA, 2009. National Ambient Air Quality Standards, Government Gazette, 32861, Vol. 1210, 24 December 2009.

DEA, 2012a. National Ambient Air Quality Standard for Particulate Matter of Aerodynamic Diameter less than 2.5 micrometers, Notice 486, 29 June 2012, Government Gazette, 35463.

DEA, 2012b. Guideline to Air Dispersion Modelling for Air Quality Management in South Africa, draft regulation.

DEA, 2013: Regulations prescribing the format of the Atmospheric Impact Report, Government Gazette, 36904, Notice No. 747, 11 October 2013.

EAE, 2006. Encyclopaedia of the Atmospheric Environment, 2006, Nitrogen [Online], http://www.ace.mmu.ac.uk/eae/Air_Quality/Older/Nitrogen_Dioxide.html

Hurley, P., 2000. Verification of TAPM meteorological predictions in the Melbourne region for a winter and summer month. Australian Meteorological Magazine, 49, 97-107.

Hurley, P.J., Blockley, A. and Rayner, K., 2001. Verification of a prognostic meteorological and air pollution model for year-long predictions in the Kwinana industrial region of Western Australia. Atmospheric Environment, 35(10), 1871-1880.

Hurley, P.J., Physick, W.L. and Ashok, K.L., 2002. The Air Pollution Model (TAPM) Version 2, Part 21: summary of some verification studies, CSIRO Atmospheric Research Technical Paper No. 57, 46 p.

Raghunandan, A., Scott, G., Zunckel, M. and Carter, W., 2007. TAPM verification in South Africa: modelling surface meteorology at Alexander Bay and Richards Bay. South African Journal of Science, in prep.

South African Weather Service, 1990. Climate of South Africa, WB 42, Climate Statistics 1961 – 1990.

US-EPA, 2009. Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume I: Stationery Point and Area Sources.

WHO, 1999. Guidelines for Air Quality, World Health Organisation, http://www.who.int/peh/air/Airqualitygd.htm

WHO, 2000. Air Quality Guidelines for Europe, 2nd Edition, World Health Organisation, ISBN 92 890 1358 3.

WHO, 2003. Health aspects of air pollution with particulate matter, ozone and nitrogen dioxide. Report on a WHO Working Group Bonn, Germany 13-15 January 2003, WHO Geneva.

27 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

8 APPENDIX 1: SPECIALIST DECLARATION AND CV

I, YEGESHNI MOODLEY, declare that I am an independent consultant and have no business, financial, personal or other interest in the proposed project, application or appeal in respect of which I was appointed, other than fair remuneration for work performed in connection with the activity, application or appeal. There are no circumstances that compromise the objectivity of my performing such work.

Signature:

Name: YEGESHNI MOODLEY

Firm : uMoya-NILU (Pty) Ltd Profession : Air Quality Consultant Specialisation : Air quality management planning, air quality impact assessment, air dispersion modelling Position in Firm : Senior Consultant Years with Firm : 2 Nationality : South African Year of Birth : 1982 Language Proficiency : English

EDUCATION AND PROFESSIONAL STATUS

Qualification Institution Year BSc (Environmental Science, Univ. of Natal 2003 Geography) BSc Hons (Environmental Univ. of KwaZulu-Natal 2004 Science) MSc (Environmental Science) Univ. of KwaZulu-Natal 2007

Member: National Association for Clean Air, past Branch Vice-chairperson

EMPLOYMENT AND EXPERIENCE RECORD

Period Organisation details and responsibilities/roles January 2014 - uMoya-NILU Consulting (Pty) Ltd, current Senior air quality consultant June 2012 – NPC-Cimpor December 2013 Environmental Officer June 2008 – May uMoya-NILU Consulting (Pty) Ltd, 2012 Air quality consultant February 2004 – University of KwaZulu-Natal May 2008 Demonstrator, tutor, research assistant, support administrator, lecturer, research intern (air quality)

Current and Recent Project Experience: Year Description, client, role 2007 Member of a multi-national team to develop the National Framework for Air Quality Management for the Department of Environment Affairs and Tourism

28 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

Development of a proposed strategy to address illegal tyre burning for the 2007/8 Ethekwini Municipality Air quality assessment for Mputa Early Production System in Uganda for ERM 2008 Southern Africa on behalf of Tullow Oil Ugu district air quality screening study for the Ugu District Municipality 2008 Air quality assessment for proposed infrastructure upgrade at Bayhead Road, 2008 Ethekwini Air quality assessment for the New Multi-Products Pipeline for the NMPP 2008 Alliance Development of an Odour Management Strategy for Ethekwini 2008 Development of the Air Quality Management Plan for the Department of 2008-2010 Environmental Affairs and Development Planning, Western Cape Development of the Air Quality Management Plan for the Highveld Priority Area 2008-11 Development of an Environmental Management Framework for the Umhlatuze 2009-10 Local Municipality, air quality component Review of the City of Joburg’s Air Quality Management Plan 2010 2010-2011 Air quality management system for Total SA 2011 Air quality management plan for the Alternative Fuel and Resources Project at NPC-Cimpor Simuma Plant, Port Shepstone 2011 Baseline air quality assessment for Zambeze Coal Mine, Tete, Mozambique 2011 Development of SAAQIS Phase 2 for DEA and South African Weather Service 2011 Development of Vehicle Emission Reduction Strategy for DEA 2012 Air quality management system for Total South Africa 2012 Development of Air quality management plan for Mafube Colliery 2014-2015 Development of greenhouse gas emission reduction strategy for the Department of Transport 2014-2015 Air quality management plan development for the Waterberg-Bojanala Priority Area 2014-2015 Air quality management plan development for the eThekwini Metropolitan Municipality 2015- Development of air quality management system for the Transnet National Ports Authority

Publications: Introduction of local air quality management in South Africa: overview and challenges (Author) Environmental Science and Policy 17: pp 62-71; Journal; Elsevier Publishing. (Mar 2012)

Presentation at scientific meetings: Poster presentation at NACA Annual Conference 2006: ‘An Assessment of Local Government Capacity to Implement the Air Quality Act’ Presentation at NACA Annual Conference 2009: ‘Ambient air quality in the Highveld Priority Area’

Teaching and Training experience: Lecturing Climatology and Atmospheric Science material to undergraduate students, including lectures, practical exercises, tests and examinations Supervision of Honours research project in area of air pollution science Presentation of Training material on Air Pollution Control for CSIR training workshop Presentation of Training material to government officials in the Highveld Priority Area

29 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

9 APPENDIX 2: MODEL PLAN OF STUDY

30 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

31 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

32 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

33 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

34 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

35 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

36 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

37 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

38 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

39 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

40 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

APPENDIX 3

GREENHOUSES GASES AND POTENTIAL IMPACTS ON CLIMATE CHANGE

This section describes an assessment of the greenhouse gas emissions (GHG) associated with the proposed 1 500 MW Combined Cycle Gas Turbine (CCGT) power plant at Atlantis in the City of Cape Town. The impact of these GHG emissions and the contribution of the project to climate change is assessed and the degree to which the project is consistent with South Africa’s climate change policy is also considered.

The GHG emissions produced directly from the operations of the CCGT were calculated using the Intergovernmental Panel on Climate Change (IPCC) Guidelines for GHG inventories. The following formula applies:

Carbon emissions = Activity Data x Emission Factor x Global Warming Potential

Where:

 Activity data refers the emission source e.g. combustion of natural gas

 Global warming potentials are applied to non-CO2 gases to convert the result to carbon dioxide equivalent

Activity data for the calculation of operational emissions was sourced from the Air Quality Study (uMoya-NILU, 2016), with the assumption that the majority of GHG emissions would be attributed to the operational phase and more specifically to the 1 500 MW CCGT Turbines.

Emission factors were sources from the 2006 IPCC Guidelines for National Greenhouse Gas Inventories and GWPs were taken from the IPCC’s Fourth Assessment Report in alignment with South Africa’s National GHG Inventory.

The carbon footprint comprises all direct emissions under the operational control of the project (Scope 1) in line with guidance from international standards including the IFCs Performance Standard 3 on Resource Efficiency and Pollution Prevention (IFC, 2012).

Scope 2 emissions are only relevant for the construction and decommissioning phase, which typically contribute a very small amount to total emissions in a fossil fuelled power plant. As such these emissions were not included in this analysis.

The sources of emissions included in this assessment arise from activities under the operation control of the project, i.e. Scope 1 - stationary combustion emissions from natural gas turbines

Exclusions are Scope 1 emissions from stationary combustion emissions from diesel generators, and Scope 2 emissions from construction and decommissioning

Operational emissions were calculated using information and data from the AIR study for the GreenCape Atlantis Power Station (uMoya-NILU, 2016). This study addresses the GHG impacts associated with the 1 500 MW Power plant and assumes that the technology and gas specifications described in uMoya-NILU (2016) remain the same.

41 City of Cape Town: Atmospheric Impact Report for the GreenCape Atlantis Gas to Power Facility

The point of departure for the estimation of potential greenhouse gas emissions for the proposed power plant was the expected annual power generation, i.e. a top-down modelling approach. Combined Cycle Gas Turbines are relatively efficient, usually ranging from 38% to about 54% in state of the art facilities. Another factor affecting emissions is the capacity factor which is the operating hours per year expressed as a percentage. Typically gas turbines are either operated as ‘peaker’, ‘mid-merit’ or ‘baseload’ generators, with increasing capacity factors, however since CCGT are better suited to ‘mid-merit’ and ‘baseload’ power generation, only these with assumed capacity factors of 60% and 90% were used. Dividing the plant capacity (1500 MW) by the efficiency (as a percentage) and multiplying by the capacity factor (as a percentage) therefore provides an estimate of fuel consumption. In this case three scenarios were modelled:

 Low: assumes a high efficiency plant operating at 54% efficiency being used for ‘mid-merit’ generation (60% capacity factor). This plant will consume 52,560,000 GJ of natural gas per annum.  Moderate: assumes a medium efficiency plant operating at 45% efficiency being used for ‘mid-merit’ and ‘baseload’ generation at different times (average 75% capacity factor). This plant will consume 78,840,000 GJ of natural gas per annum.  High: assumes a low efficiency plant operating at 38% efficiency being used for ‘baseload’ generation (90% capacity factor). This plant will consume 112,035,789 GJ of natural gas per annum.

The greenhouse gases emitted in these scenarios were then calculated by multiplying the natural gas consumed by emission factors for natural gas (CO2: 56 100 kg; CH4: 92 kg; N20:3 kg /TJ natural gas). These different greenhouse gases were then converted to carbon dioxide equivalents using IPCCC global warming potential figures:

 Low: 3 116 493 Tonnes CO2e per annum

 Moderate: 4 674 739 Tonnes CO2e per annum

 High 6 643 050 Tonnes CO2e per annum

South Africa’s total projected greenhouse gas emissions according to its INDC to the UNFCCC is 1 between 398,000,000 and 583,000,000 Tonnes CO2e per annum in 2020 . Using this figure as the baseline, the GreenCape Atlantis Gas to Power Facility project will comprise between 0.53 and 1.67% of South Africa’s total projected greenhouse gas emissions in 2020.

1 Department of Environmental Affairs (DEA) (2015). South Africa’s Intended Nationally Determined Contribution (INDC). www.environment.gov.za

42