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BASIC ASSESSMENT REPORT

(For official use only)

File Reference Number:

Application Number:

Date Received:

Basic assessment report in terms of the Environmental Impact Assessment Regulations, 2010, promulgated in terms of the National Environmental Management Act, 1998(Act No. 107 of 1998), as amended.

DEDEAT REFERENCE NUMBER: EC05/C/LN1&3/M/18-2015

Kindly note that:

1. This basic assessment report is a standard report that may be required by a competent authority in terms of the EIA Regulations, 2014 and is meant to streamline applications. Please make sure that it is the report used by the particular competent authority for the activity that is being applied for.

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2. The report must be typed within the spaces provided in the form. The size of the spaces provided is not necessarily indicative of the amount of information to be provided. The report is in the form of a table that can extend itself as each space is filled with typing.

3. Where applicable tick the boxes that are applicable or black out the boxes that are not applicable in the report.

4. An incomplete report may be returned to the applicant for revision.

5. The use of “not applicable” in the report must be done with circumspection because if it is used in respect of material information that is required by the competent authority for assessing the application, it may result in the rejection of the application as provided for in the regulations.

6. This report must be handed in at offices of the relevant competent authority as determined by each authority.

7. No faxed or e-mailed reports will be accepted.

8. The report must be compiled by an independent environmental assessment practitioner (EAP).

9. Unless protected by law, all information in the report will become public information on receipt by the competent authority. Any interested and affected party should be provided with the information contained in this report on request, during any stage of the application process.

10. A competent authority may require that for specified types of activities in defined situations only parts of this report need to be completed.

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SECTION A: ACTIVITY INFORMATION

Has a specialist been consulted to assist with the completion of this YES NO section? X

If YES, please complete form XX for each specialist thus appointed:

Any specialist reports must be contained in Appendix D.

1. ACTIVITY DESCRIPTION

Describe the activity, which is being applied for, in detail The District Roads Engineer (DRE) proposes to reconstruct the Kariega River Low-Level Bridge on the gravel road that runs west-east just north of Kenton-on-Sea between the R343 and the P{ort Alfred to Southwell District Road (District Road, DR1950) (refer to Figure 1 included below). This was necessitated by extensive damage to the right bank approach embankment of the existing bridge in 2011 due to a high rainfall and subsequent flooding event in the river. The event showed that the hydraulic capacity of the existing bridge is insufficient to accommodate high flows in the river. As a result traffic has been forced to cross through the river. This poses a safety risk to all road users. The continuous traversing through the river is also causing damage to the river banks and the river bed. The proposed bridge will be approximately 35 metres in length and 5 metres wide. The scope of the engineering works includes the reconstruction of the low- level bridge with larger culverts to increase flow under the bridge but the crossing will, however, be designed to be overtopped during extreme events.

The proposed crossing will comprise seven portal box culverts, each 2.4 metres wide by 1.8 metres high, laid parallel to the direction of flow in the river as it approaches the site of the crossing (see Appendix C). Each culvert will comprise six 1.2 metres-long precast concrete units, Class 75S to SANS 986 (Rectangular Box Culverts). The culverts will be founded on a cast-in situ reinforced concrete slab 200mm thick. The slab will be laid on the river bed after suitable levelling and grading and, where necessary, filling soft spots with dental concrete. The base slab will be extended about 3.5m upstream of the entrance to the culverts to provide smooth flow conditions at the culvert entrances, and about the same distance at the downstream ends to prevent erosion by exiting flow. Four transverse cut-off walls approximately 600mm deep will be constructed beneath the slab at the upstream and downstream ends of the slab and at two places between to prevent water flowing under the

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slab and eroding the river bed beneath the structure.

Figure 1: Location of the proposed crossing, the insert shows the extent of the damage on the existing bridge.

The culverts will be laid about 2m apart, and the space between them filled with cement stabilised backfill material, with the upstream and downstream ends being sealed with a reinforced concrete wall. Reinforced concrete wing walls will be constructed at each side of the crossing to protect the river banks from erosion. The road slab will be a reinforced concrete slab approximately 200mm thick. The bed and banks of the river upstream and downstream of the crossing will be reinforced with Reno mattresses and stone-filled gabions respectively up to a certain level, above which the river banks and the side slopes of the road embankment will be reinforced with grouted stone pitching. The crossing will have to be constructed in two cofferdams, since the river flows continuously except in drought conditions.

A water use authorisation in terms of Section 21 (c) and (i) of the National Water Act (Act 36 of 1998) was initially anticipated, however it has been determined that the exact location of the low-level crossing is within the upper reaches of the estuary and is thus the mandate of the Department of Oceans and Coasts. Discussions with the Department of Water and Sanitation

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and Oceans and Coasts have confirmed this. A formal letter indicating such has been requested and will be included in the Final Basic Assessment Report.

2. FEASIBLE AND REASONABLE ALTERNATIVES

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

Describe alternatives that are considered in this application. Alternatives should include a consideration of all possible means by which the purpose and need of the proposed activity could be accomplished in the specific instance taking account of the interest of the applicant in the activity. The no-go alternative must in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. The determination of whether site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment. After receipt of this report the competent authority may also request the applicant to assess additional alternatives that could possibly accomplish the purpose and need of the proposed activity if it is clear that realistic alternatives have not been considered to a reasonable extent.

Paragraphs 3 – 13 below should be completed for each alternative.

(a) The property on which or location where it is proposed to undertake the activity: This application is for the reconstruction of an existing bridge to increase its hydraulic capacity to accommodate high flows in the river. A new low-level bridge will be constructed in the same footprint as the previous bridge, to reduce the overall impacts associated with the construction and operation phases. It should be noted that larger culverts will be installed in order to increase the hydraulic capacity of the bridge to accommodate high flows during heavy rainfall and flooding events, thereby reducing the potential risk for damage. For these reasons no location alternatives have been considered for this application. (b) The type of activity to be undertaken: Due to the fact that the application is for the reconstruction of an existing bridge that has been damaged, no activity alternatives have been considered for this application. (c) The design or layout of the activity: The proposed low-level bridge has been designed with larger culverts in order to increase the hydraulic capacity of the bridge to accommodate high flows during heavy rainfall and flooding

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events, thereby reducing the potential risk for damage. No other design or layout alternatives will thus be considered. (d) The technology to be used in the activity: N/A. The proposed activity is for the reconstruction of a damaged bridge. (e) The operational aspects of the activity: There are no alternative to the operation of the proposed low-level bridge. In all instances the bridge will be used for the safe crossing of vehicles and pedestrians under normal flow conditions. The facility is designed to be overtopped during extreme flood events. (f) The option of not implementing the activity: If the proposed low-level causeway is not reconstructed, it is anticipated that vehicles will continue to drive through the river as is currently the case. This poses a safety risk to all road users as the bridge is within the tidal reach. In addition to this, the continuous traversing through the river is causing damage to the river banks and the river bed. There are currently signs of increased erosion in this area (refer to Figure 2 below), which is likely to be exacerbated over time.

Figure 2: Current route through the river bed.

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3. ACTIVITY POSITION

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

List alternative sites if applicable.

There are no site alternatives proposed for the reconstruction of the existing bridge.

Latitude (S): Longitude (E): Alternative: Alternative S1 1 (preferred or only site o ‘ o ‘ alternative) Alternative S2 (if any) o ‘ o ‘ Alternative S3 (if any) o ‘ o ‘

In the case of linear activities: Alternative: Latitude (S): Longitude (E): Alternative S1 (preferred or only route alternative)  Starting point of the activity 33o 36’31.95” 25o 20’45.26”  Middle point of the activity 33o 36’32.04” 25o 20’44.48”  End point of the activity 33o 36’32.14” 25o 20’43.66”

Alternative S2 (if any)  Starting point of the activity o ‘ o ‘  Middle point of the activity o ‘ o ‘  End point of the activity o ‘ o ‘

Alternative S3 (if any)  Starting point of the activity o ‘ o ‘  Middle point of the activity o ‘ o ‘  End point of the activity o ‘ o ‘

For route alternatives that are longer than 500m, please provide an addendum with co-ordinates taken every 250 meters along the route for each alternative alignment.

1 “Alternative S..” refer to site alternatives.

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4. PHYSICAL SIZE OF THE ACTIVITY

Indicate the physical size of the preferred activity/technology as well as alternative activities/technologies (footprints): Alternative: Size of the activity: Alternative A12 (preferred activity alternative) m2 Alternative A2 (if any) m2 Alternative A3 (if any) m2 or, for linear activities: Alternative: Length of the activity: Alternative A1 (preferred activity alternative) Approximately 35 m Alternative A2 (if any) m Alternative A3 (if any) m

Indicate the size of the alternative sites or servitudes (within which the above footprints will occur): Alternative: Size of the site/servitude: Alternative A1 (preferred activity alternative) Approximately 175 m2 Alternative A2 (if any) m2 Alternative A3 (if any) m2

5. SITE ACCESS

Does ready access to the site exist? YES NO X If NO, what is the distance over which a new access road will be built m

Describe the type of access road planned:

Access to the eastern side of the proposed low-level bridge is via an existing gravel road from the R72. Access to the western side is from an existing gravel road off the R343.

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

2 “Alternative A..” refer to activity, process, technology or other alternatives.

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Existing gravel road off the R343

Existing gravel road off the R72

6. SITE OR ROUTE PLAN

A detailed site or route plan(s) must be prepared for each alternative site or alternative activity. It must be attached as Appendix A to this document.

The site or route plans must indicate the following:

6.1 The scale of the plan which must be at least a scale of 1:500; 6.2 The property boundaries and numbers of all the properties within 50 metres of the site; 6.3 The current land use as well as the land use zoning of each of the properties adjoining the site or sites; 6.4 The exact position of each element of the application as well as any other structures on the site; 6.5 The position of services, including electricity supply cables (indicate above or underground), water supply pipelines, boreholes, street lights, sewage pipelines, storm water infrastructure and telecommunication infrastructure; 6.6 All trees and shrubs taller than 1.8 metres; 6.7 Walls and fencing including details of the height and construction material;

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6.8 Servitudes indicating the purpose of the servitude; 6.9 Sensitive environmental elements within 100 metres of the site or sites including (but not limited thereto): . rivers; . the 1:100 year flood line (where available or where it is required by DWA); . ridges; . cultural and historical features; . areas with indigenous vegetation (even if it is degraded or invested with alien species); 6.9 For gentle slopes the 1 metre contour intervals must be indicated on the plan and whenever the slope of the site exceeds 1:10, the 500mm contours must be indicated on the plan; and 6.10 The positions from where photographs of the site were taken.

7. SITE PHOTOGRAPHS

Colour photographs from the centre of the site must be taken in at least the eight major compass directions with a description of each photograph. Photographs must be attached under Appendix B to this form. It must be supplemented with additional photographs of relevant features on the site, if applicable.

8. FACILITY ILLUSTRATION

A detailed illustration of the activity must be provided at a scale of 1:200 as Appendix C for activities that include structures. The illustrations must be to scale and must represent a realistic image of the planned activity. The illustration must give a representative view of the activity.

9. ACTIVITY MOTIVATION

9(a) Socio-economic value of the activity

What is the expected capital value of the activity on completion? R 2.5 million

What is the expected yearly income that will be generated by or as a result of R 0 the activity?

Will the activity contribute to service infrastructure? YES NO X Is the activity a public amenity? YES NO X

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How many new employment opportunities will be created in the development 10 phase of the activity?

What is the expected value of the employment opportunities during the R 150 000 development phase?

What percentage of this will accrue to previously disadvantaged individuals? 80 %

How many permanent new employment opportunities will be created during the 0 operational phase of the activity?

What is the expected current value of the employment opportunities during the N/A first 10 years?

What percentage of this will accrue to previously disadvantaged individuals? N/A

9(b) Need and desirability of the activity

Motivate and explain the need and desirability of the activity (including demand for the activity): According to the Ndlambe Municipality SDF (2006) the transportation network within the municipal area plays an important role in sustaining nodal points within the area. For this reason a transportation policy has been developed to ensure that the municipality provides a safe and efficient road network system, built to appropriate standards in order to optimise the accessibility of services and facilities for local communities, improve transport efficiency for economic activities and allow tourist access to the region’s assets. A more recent update of the SDF (Second Draft Ndlambe SDF -Dec 2012, _Rev3, 12 Feb 2013) does not mention the transportation policy, but notes that “Most of the roads in the area are in a poor condition and need upgrading especially those within the urban centres and those leading to surrounding farms. The roads to and from farms are in a poor state of repair and tis impacts the transportation of goods and services between the farming area and urban area/ it affects the quality of agricultural produce.” According to the Ndlambe Municipality IDP (Ndlambe LM IDP 2012-2017 Second Draft Review 2015 2016, undated), a Roads Management Programme was compiled in May 2005 to guide the Municipality in terms of investments in roads. At the time, discussions with DBSA ensued regarding feasible options of dealing with the required investments. Unfortunately the discussions never delivered a meaningful solution. As the Municipality anticipated a result from the DBSA process, its own budget for road maintenance was suspended with the result that roads deteriorated in the past years without any municipal budget to rectify the damages. This scenario compounded the problem and has generated a tremendous public outcry to the Municipality to develop a strategy. Considering the role of roads in the economic activities of the area (tourism/transport of agricultural products), as well as the numerous rural settlements that rely on economic activities at centres like Port Alfred and Alexandria, the matter requires

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urgent attention. In addition, Ndlambe is the Municipality that has been most affected by floods in the District, resulting in damages to roads (as is the case in this instance). The upgrading of the road network is development priority number 4 of the Integrated Development Plan. The proposed project is thus in line with both the SDF and the IDP for the Ndlambe Municipality. If the proposed low-level causeway is not reconstructed, it is anticipated that vehicles will continue to drive through the river as is currently the case. This poses a safety risk to all road users as the bridge is within the tidal reach. In addition to this, the continuous traversing through the river is causing damage to the river banks and the river bed. There are currently signs of increased erosion in this area, which is likely to be exacerbated over time.

Indicate any benefits that the activity will have for society in general:  Provide a safe crossing for all road users in the area.  Provide approximately 10 temporary employment opportunities during construction.  Result in a decrease in erosion along the river banks due to the fact that vehicles will no longer need to cross through the Kariega River.  Provide the community with a more direct route from the R343 instead of travelling through Kenton on Sea.

Indicate any benefits that the activity will have for the local communities where the activity will be located:  Provide a safe crossing for all road users in the area.  Provide approximately 10 temporary employment opportunities.  Result in a decrease in erosion along the river banks due to the fact that vehicles will no longer need to cross through the Kariega River.  Provide the community with a more direct route from the R343 instead of travelling through Kenton on Sea.

10. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES

List all legislation, policies and/or guidelines of any sphere of government that are applicable to the application as contemplated in the EIA regulations, if applicable:

Title of legislation, policy or guideline: Administering authority: Date: National Environmental Management Act DEA 1998 National Environmental Management: Biodiversity DEA 2004 Act National Environmental Management: Protected DEA 2003 Areas Act National Heritage Resources Act SAHRA 1999 National Water Act DWS 1998 National Environmental Management: Waste Act DEA 2008 Conservation of Agricultural Resources Act DAFF 1983 Hazardous Substances Act DoH 1973

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Occupational Health and Safety Act DoL 1993 Municipal By-Laws Ndlambe Municipality

11. WASTE, EFFLUENT, EMISSION AND NOISE MANAGEMENT

11(a) Solid waste management

Will the activity produce solid construction waste during the YES NO construction/initiation phase? X

If yes, what estimated quantity will be produced per month? Limited

How will the construction solid waste be disposed of (describe)?

Solid waste produced during the construction phase of the proposed development will primarily consist of building rubble. The contractor will remove and discard any waste resulting from construction to the closest registered waste disposal site. Where possible, construction waste must be re-used and/or recycled.

Where will the construction solid waste be disposed of (describe)?

The nearest registered waste disposal site (Port Alfred). YES NO X Will the activity produce solid waste during its operational phase?

If yes, what estimated quantity will be produced per month? N/A

How will the solid waste be disposed of (describe)?

N/A

Where will the solid waste be disposed if it does not feed into a municipal waste stream (describe)?

N/A

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If the solid waste (construction or operational phases) will not be disposed of in a registered landfill site or be taken up in a municipal waste stream, then the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

Can any part of the solid waste be classified as hazardous in terms of the YES NO relevant legislation? X

If yes, inform the competent authority and request a change to an application for scoping and EIA. Is the activity that is being applied for a solid waste handling or treatment YES NO facility? X

If yes, then the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

11(b) Liquid effluent

Will the activity produce effluent, other than normal sewage, that will be YES NO disposed of in a municipal sewage system? X

If yes, what estimated quantity will be produced per month? N/A

Will the activity produce any effluent that will be treated and/or disposed of on Yes NO site? X

If yes, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

Will the activity produce effluent that will be treated and/or disposed of at YES NO another facility? X

If yes, provide the particulars of the facility:

Facility name: N/A

Contact person:

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Postal address:

Postal code:

Telephone: Cell:

E-mail: Fax:

Describe the measures that will be taken to ensure the optimal reuse or recycling of waste water, if any:

N/A

11(c) Emissions into the atmosphere

Will the activity release emissions into the atmosphere? YES NO X If yes, is it controlled by any legislation of any sphere of government? YES NO X If yes, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

If no, describe the emissions in terms of type and concentration:

There is a possibility that dust will be generated during the construction phase, particularly during high wind conditions. In addition there will be exhaust emissions from vehicles nad the construction plant. The following mitigation measures will ensure that dust generated by the proposed development will remain insignificant:  Prompt rehabilitation and wetting down of recently cleared areas should minimize dust creation.  Construction vehicles must adhere to speed limits.  If fine building materials/sands are to be transported at the back of trucks, they must be adequately covered.

11(d) Generation of noise

Will the activity generate noise? YES NO X

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If yes, is it controlled by any legislation of any sphere of government? YES NO X If yes, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

If no, describe the noise in terms of type and level:

Noise generated will be from construction activities. The following mitigation measures will ensure that noise created during construction is negligible:  All construction vehicles must be in sound working order and meet the necessary noise level requirements.  Restrict construction times to working and light hours only to minimize noise pollution.  The normal municipal by-laws with regards to noise control must apply.  Construction staff should not be housed on site.

12. WATER USE

Please indicate the source(s) of water that will be used for the activity by ticking the appropriate box(es)

Municipal Water Groundwater River, Stream, Other The activity will not X Board Dam or Lake use water

Please note that water will be carted to site from closest municipal source (most probably Kenton-on-Sea) during the construction phase. No water will be required during the operational phase of the project.

If water is to be extracted from groundwater, river, stream, dam, lake or any other natural feature, please indicate the volume that will be extracted per month: N/A

Does the activity require a water use permit from the Department of Water YES NO Affairs? X

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If yes, please submit the necessary application to the Department of Water Affairs and attach proof thereof to this application if it has been submitted.

A water use authorisation in terms of Section 21 (c) and (i) of the National Water Act (Act 36 of 1998) was initially anticipated, however it has been determined that the exact location of the low-level crossing is within the upper reaches of the estuary and is thus the mandate of the Department of Oceans and Coasts. Discussions with the Department of Water and Sanitation and Oceans and Coasts have confirmed this. A formal letter indicating such has been requested and will be included in the Final Basic Assessment Report.

13. ENERGY EFFICIENCY

Describe the design measures, if any, that have been taken to ensure that the activity is energy efficient:

N/A. The proposed project is for the reconstruction of a bridge across the Kariega River.

Describe how alternative energy sources have been taken into account or been built into the design of the activity, if any:

N/A. The proposed project is for the reconstruction of a bridge across the Kariega River.

SECTION B: SITE/AREA/PROPERTY DESCRIPTION

Important notes:

1. For linear activities (pipelines, etc) as well as activities that cover very large sites, it may be necessary to complete this section for each part of the site that has a significantly different environment. In such cases please complete copies of Section C and indicate the area, which is covered by each copy No. on the Site Plan.

Section C Copy No. (e.g. A):

2. Paragraphs 1 - 6 below must be completed for each alternative.

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3. Has a specialist been consulted to assist with the completion of YES NO this section? X

If YES, please complete form XX for each specialist thus appointed:

All specialist reports must be contained in Appendix D.

1. GRADIENT OF THE SITE

Indicate the general gradient of the site. Alternative S1: Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper than X X X 1:5

Please note that the gradient approaching the river from the west is estimated to be 1:50-1:20. The current causeway section is flat with very gradual slopes on each side of the river bank. Travelling East (away from the river transect) the slope increases to approximately 1:20- 1:15.

Alternative S2 (if any): N/A Flat 1:50 – 1:20 – 1:15 – 1:10 1:10 – 1:7,5 – 1:5 Steeper than 1:20 1:15 1:7,5 1:5 Alternative S3 (if any): N/A Flat 1:50 – 1:20 – 1:15 – 1:10 1:10 – 1:7,5 – 1:5 Steeper than 1:20 1:15 1:7,5 1:5

2. LOCATION IN LANDSCAPE

Indicate the landform(s) that best describes the site:

2.1 Ridgeline 2.2 Plateau 2.3 Side slope of hill/mountain 2.4 Closed valley 2.5 Open valley X 2.6 Plain 2.7 Undulating plain / low hills 2.8 Dune 2.9 Seafront

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3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE

Is the site(s) located on any of the following (tick the appropriate boxes)? Alternative S1: Alternative S2 Alternative S3 (if any): (if any): Shallow water table (less YES NO YES NO YES NO than 1.5m deep) X Dolomite, sinkhole or doline YES NO YES NO YES NO areas X

Seasonally wet soils (often YES NO YES NO YES NO close to water bodies) X Unstable rocky slopes or YES NO YES NO YES NO steep slopes with loose soil X Dispersive soils (soils that YES NO YES NO YES NO dissolve in water) X Soils with high clay content YES NO YES NO YES NO (clay fraction more than X 40%) Any other unstable soil or YES NO YES NO YES NO geological feature X An area sensitive to erosion YES NO YES NO YES NO X

If you are unsure about any of the above or if you are concerned that any of the above aspects may be an issue of concern in the application, an appropriate specialist should be appointed to assist in the completion of this section. (Information in respect of the above will often be available as part of the project information or at the planning sections of local authorities. Where it exists, the 1:50 000 scale Regional Geotechnical Maps prepared by the Council for Geo Science may also be consulted).

4. GROUNDCOVER

Indicate the types of groundcover present on the site:

4.1 Natural veld – good condition E 4.2 Natural veld – scattered aliens E 4.3 Natural veld with heavy alien infestation E 4.4 Veld dominated by alien species E 4.5 Gardens 4.6 Sport field 4.7 Cultivated land

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4.8 Paved surface 4.9 Building or other structure 4.10 Bare soil

The location of all identified rare or endangered species or other elements should be accurately indicated on the site plan(s).

Natural veld Natural veld with Veld Natural veld - good with scattered E E heavy alien dominated by Gardens condition aliens E E infestation alien species X Building or Bare soil Sport field Cultivated land Paved surface other structure X X

If any of the boxes marked with an “E “is ticked, please consult an appropriate specialist to assist in the completion of this section if the environmental assessment practitioner doesn’t have the necessary expertise.

5. LAND USE CHARACTER OF SURROUNDING AREA

Indicate land uses and/or prominent features that currently occur within a 500m radius of the site and give description of how this influences the application or may be impacted upon by the application:

5.1 Natural area X 5.2 Low density residential 5.3 Medium density residential 5.4 High density residential 5.5 Informal residential 5.6 Retail commercial & warehousing 5.7 Light industrial 5.8 Medium industrial AN 5.9 Heavy industrial AN 5.10 Power station 5.11 Office/consulting room 5.12 Military or police base/station/compound 5.13 Spoil heap or slimes damA 5.14 Quarry, sand or borrow pit 5.15 Dam or reservoir 5.16 Hospital/medical centre 5.17 School 5.18 Tertiary education facility

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5.19 Church 5.20 Old age home 5.21 Sewage treatment plantA 5.22 Train station or shunting yard N 5.23 Railway line N 5.24 Major road (4 lanes or more) N 5.25 Airport N 5.26 Harbour 5.27 Sport facilities 5.28 Golf course 5.29 Polo fields 5.30 Filling station H 5.31 Landfill or waste treatment site 5.32 Plantation 5.33 Agriculture 5.34 River, stream or wetland X 5.35 Nature conservation area X 5.36 Mountain, koppie or ridge 5.37 Museum 5.38 Historical building 5.39 Protected Area X 5.40 Graveyard 5.41 Archaeological site 5.42 Other land uses (describe)

If any of the boxes marked with an “N “are ticked, how will this impact / be impacted upon by the proposed activity.

N/A, none of the boxes marked with “N” are ticked

If any of the boxes marked with an "An" are ticked, how will this impact / be impacted upon by the proposed activity.

If YES, specify and explain:

N/A, none of the boxes marked with “AN” are ticked

If YES, specify:

N/A, none of the boxes marked with “AN” are ticked

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If any of the boxes marked with an "H" are ticked, how will this impact / be impacted upon by the proposed activity.

If YES, specify and explain:

N/A, none of the boxes marked with “H” are ticked

If YES, specify:

N/A, none of the boxes marked with “H” are ticked

6. CULTURAL/HISTORICAL FEATURES

Are there any signs of culturally or historically significant elements, as YES NO defined in section 2 of the National Heritage Resources Act, 1999, (Act X No. 25 of 1999), including Archaeological or palaeontological sites, on or close (within 20m) to the NO site? X If YES, N/A explain: If uncertain, conduct a specialist investigation by a recognised specialist in the field to establish whether there is such a feature(s) present on or close to the site. Briefly N/A explain the findings of the specialist: Will any building or structure older than 60 years be affected in any YES NO way? X Is it necessary to apply for a permit in terms of the National Heritage YES NO Resources Act, 1999 (Act 25 of 1999)? X If yes, please submit or, make sure that the applicant or a specialist submits the necessary application to SAHRA or the relevant provincial heritage agency and attach proof thereof to this application if such application has been made.

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SECTION C: PUBLIC PARTICIPATION

1. ADVERTISEMENT

The person conducting a public participation process must take into account any guidelines applicable to public participation as contemplated in section 24J of the Act and must give notice to all potential interested and affected parties of the application which is subjected to public participation by—

(a) Fixing a notice board (of a size at least 60cm by 42cm; and must display the required information in lettering and in a format as may be determined by the competent authority) at a place conspicuous to the public at the boundary or on the fence of— (i) The site where the activity to which the application relates is or is to be undertaken; and (ii) Any alternative site mentioned in the application;

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(b) Giving written notice to— (i) The owner or person in control of that land if the applicant is not the owner or person in control of the land; (ii) The occupiers of the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken; (iii) Owners and occupiers of land adjacent to the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken; (iv) The municipal councillor of the ward in which the site or alternative site is situated and any organisation of ratepayers that represent the community in the area; (v) The municipality which has jurisdiction in the area; (vi) Any organ of state having jurisdiction in respect of any aspect of the activity; and

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(vii) Any other party as required by the competent authority;

The following I&APs where identified for the proposed project:

Title, Name and Affiliation/ key stakeholder Contact details Surname status Mr Nick Fox Land owner at Sibuya Game [email protected] Reserve, Vintony Farm Pty Ltd Tel: 046 648 2020 Fax: 046 648 2114 Cell: 083 648 2020 Mr Graeme Rushmere Land owner: Gorah Gorah Lodge [email protected] (Pty) Limited Tel: 041 581 2606 041 581 2601 Cell: 083 601 8503 Mr Andries Struwig Department of Economic [email protected] Development Environmental Tel: 0415085800 Affairs and Tourism (DEDEAT) Mr Joseph Jacobs Department of Water Affairs and [email protected] Sanitation Tel: 0415864884 Ms Skumsa Mancotywa DEA [email protected] Acting Deputy Director-General Biodiversity and Conservation Mr Ishaam Abader DEA [email protected] Deputy Director-General Legal Authorisations and Compliance Inspectorate Mr T Nokoyo DAFF [email protected] Mr Rolly Dumezweni Ndlambe Municipality [email protected] Municipal Manager Tel: 046 604 2774 Mr L E Khoathani Ndlambe Municipality [email protected] Ward Councillor – Ward 3 Tel: 082 403 1000

Ms Marilyn Tarentaal Ndlambe Municipality [email protected]

Ward Councillor – Ward 6 Tel: 079 028 9236 Mr Xolani Masiza Ndlambe Municipality [email protected] Director: Infrastructure Tel: 046 624 1140 Development Department of Roads and Public [email protected] Works [email protected] [email protected] [email protected] Mr S Mokhanya ECPHRA [email protected]

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Mrs Colette Scheermeyer SAHRA [email protected] Tel: 021 462 4502 Mr Morgan Griffiths WESSA [email protected] Ms Megan Hope Conservancies [email protected]

Emlanjeni Private Game Reserve [email protected] Tel: 046 648 2911 Ms Anneliza Collett Department of Agriculture [email protected]

Ms Ane Oosthuizen SANParks [email protected] Dr Stephen Holness [email protected] [email protected] [email protected] [email protected]

(c) Placing an advertisement in— (i) One local newspaper; or (ii) Any official Gazette that is published specifically for the purpose of providing public notice of applications or other submissions made in terms of these Regulations;

(d) Placing an advertisement in at least one provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the boundaries of the metropolitan or local municipality in which it is or will be undertaken: Provided that this paragraph need not be complied with if an advertisement has been placed in an official Gazette referred to in subregulation 54(c)(ii); and

(e) Using reasonable alternative methods, as agreed to by the competent authority, in those instances where a person is desiring of but unable to participate in the process due to— (i) Illiteracy; (ii) Disability; or (iii) Any other disadvantage.

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The Herald on 15th July 2014

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2. CONTENT OF ADVERTISEMENTS AND NOTICES

A notice board, advertisement or notices must:

(a) Indicate the details of the application which is subjected to public participation; and (b) State— (i) That the application has been submitted to the competent authority in terms of these Regulations, as the case may be; (ii) Whether basic assessment or scoping procedures are being applied to the application, in the case of an application for environmental authorisation; (iii) The nature and location of the activity to which the application relates; (iv) Where further information on the application or activity can be obtained; and (iv) The manner in which and the person to whom representations in respect of the application may be made.

3. PLACEMENT OF ADVERTISEMENTS AND NOTICES

Where the proposed activity may have impacts that extend beyond the municipal area where it is located, a notice must be placed in at least one provincial newspaper or national newspaper, indicating that an application will be submitted to the competent authority in terms of these regulations, the nature and location of the activity, where further information on the proposed activity can be obtained and the manner in which representations in respect of the application can be made, unless a notice has been placed in any Gazette that is published specifically for the purpose of providing notice to the public of applications made in terms of the EIA regulations.

Advertisements and notices must make provision for all alternatives.

4. DETERMINATION OF APPROPRIATE MEASURES

The practitioner must ensure that the public participation is adequate and must determine whether a public meeting or any other additional measure is appropriate or not based on the particular nature of each case. Special attention should be given to the involvement of local community structures such as Ward Committees, ratepayers associations and traditional authorities where appropriate. Please note that public concerns that emerge at a later stage that should have been addressed may cause the competent authority to withdraw any authorisation it may have issued if it becomes apparent that the public participation process was inadequate.

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5. COMMENTS AND RESPONSE REPORT

The practitioner must record all comments and respond to each comment of the public before the application is submitted. The comments and responses must be captured in a comments and response report as prescribed in the EIA regulations and be attached to this application. The comments and response report must be attached under Appendix E.

6. AUTHORITY PARTICIPATION

Authorities are key interested and affected parties in each application and no decision on any application will be made before the relevant local authority is provided with the opportunity to give input. The planning and the environmental sections of the local authority must be informed of the application at least 30 (thirty) calendar days before the submission of the application.

List of authorities informed:  Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT);  Ndlambe Municipality, Municipal Manager and Director of Infrastructure Development;  Department of Water and Sanitation (DWS);  EC Department of Forestry and Fisheries;  WESSA;  Eastern Cape Provincial Heritage Authority;  SAHRA;  EC Department of Agriculture;  EC Department of Roads and Public Works;  Ward 3 and 6 Ward Councillors  SANParks  DEA: Biodiversity and Conservation  Eastern Cape Conservancies

List of authorities from whom comments have been received:

No comments received to date.

7. CONSULTATION WITH OTHER STAKEHOLDERS

Note that, for linear activities, or where deviation from the public participation requirements may be appropriate, the person conducting the public participation process may deviate from the requirements of that subregulation to the extent and in the manner as may be agreed to by the competent authority.

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Any stakeholder that has a direct interest in the site or property, such as servitude holders and service providers, should be informed of the application at least 30 (thirty) calendar days before the submission of the application and be provided with the opportunity to comment.

Has any comment been received from stakeholders? YES NO X If “YES”, briefly describe the feedback below (also attach copies of any correspondence to and from the stakeholders to this application): The following is a summary of the major comments received during the public participation process. A full comments and response trail is available in Appendix E of this document.  Ensure that the new low level bridge is designed to allow for increased flow;  There are other roads within the Ndlambe Municipal area that require attention and due to limited funds it is suggested that these are fixed and/or maintained prior to the reconstruction of the Kariega low-level bridge as the DR1950 is not utilized by the local communities.

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SECTION D: IMPACT ASSESSMENT

The assessment of impacts must adhere to the minimum requirements in the EIA Regulations, 2010, and should take applicable official guidelines into account. The issues raised by interested and affected parties should also be addressed in the assessment of impacts.

1. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES

List the main issues raised by interested and affected parties.

The following is a summary of the major comments received during the public participation process. A full comments and response trail is available in Appendix E of this document.  Ensure that the new low level bridge is designed to allow for increased flow;  There are other roads within the Ndlambe Municipal area that require attention and due to limited funds it is suggested that these are fixed and/or maintained prior to the reconstruction of the Kariega low-level bridge as the DR1950 is not utilized by the local communities.

Response from the practitioner to the issues raised by the interested and affected parties (A full response must be given in the Comments and Response Report that must be attached to this report):

 How do we maximise the flow e.g. size, position and number of culverts? The proposed culverts are aligned (orientated) in-line with the natural flow path of the river, whereas the current (old) culverts are orientated at an angle to the natural flow path. This resulted in deposition of sediment, a restricted discharge capacity, and ultimately failure because the approach embankment was overtopped and washed away. The proposed culverts are 2400mm wide x 1800mm high, and allow for continuous flow over the entire width of the river. The concrete apron on the upstream side of the culverts creates optimum approach conditions and flow through the culverts.  The current design allows for 6 culverts. Can more be included? Yes, if necessary, but the structure is designed as a low level bridge and allows for overtopping for design floods bigger than 1:2 years. The six culverts currently included are calculated to adequately handle the 2-year flood, which has an estimated peak flow rate of 52m³/s, and therefore it is not necessary to include more culverts. Overtopping conditions are estimated to occur at 90m3/s. The banks of the river and the approach embankments will be protected against erosion during overtopping by Reno mattresses, stone-filled gabions and grouted stone pitching.  They need to ensure that what they think the bed level is, is indeed the real bed level or a perched level resulting from previous reclamation. Design is based on a surveyed area of the section. This was completed at the beginning of 2014.  The design must ensure that the culverts are not perched above the spring low level i.e. they allow water passage at all tidal levels. Noted, levels proposed by the engineer must be verified on site by contractor prior to the

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commencement of work.  The area is used by fishermen and bird watchers is there any chance of creating a small paved area for parking and a picnic bench and table area. The Game parks may not like this but they do not own the road. This proposal will be presented to client.  Obviously there must be a good construction and rehabilitation plan with on-site ECO inspection. The Kenton community are very vigilant and put a stop to a recent project on the Bushmans which was not complying with the authorised activities. Noted. Provision has been made for an on-site ECO in the recommendations.  As an added benefit you may wish to chat with Dr Tommy Bornman of SAEON [email protected] to see if he would like a small instrument housing included in the design. This would be a very very marginal cost and would involve concreting a small stainless steel structure to one of the culverts which will allow the deployment of scientific instrumentation. This can be allowed for in BOQ if the cost is marginal.  There are other roads within the Ndlambe Municipal area that require attention and due to limited funds it is suggested that these are fixed and/or maintained prior to the reconstruction of the Kariega low-level bridge, as the DR1950 is not utilized by the local communities. Noted. This issue will be presented to the client.

2.IMPACTS THAT MAY RESULT FROM THE PLANNING AND DESIGN, CONSTRUCTION, OPERATIONAL, DECOMMISSIONING AND CLOSURE PHASES AS WELL AS PROPOSED MANAGEMENT OF IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES

List the potential direct, indirect and cumulative property/activity/design/technology/operational alternative related impacts (as appropriate) that are likely to occur as a result of the planning and design phase, construction phase, operational phase, decommissioning and closure phase, including impacts relating to the choice of site/activity/technology alternatives as well as the mitigation measures that may eliminate or reduce the potential impacts listed.

Planning and Design Phase Alternative 1 (Preferred Alternative) Direct impacts: This phase consists of planning and design around the proposed development, and is done at a desktop level. In some cases site visits need to take place but the impact of these visits is negligible, if any, e.g. photographs, GPS points etc.

Indirect impacts: As above Cumulative impacts: As above

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Alternative 2 Direct impacts: N/A. There are no feasible or reasonable alternatives for the proposed project that will meet the purpose of the project, which is to restore the damaged crossing at the same point, all as described in Section A point 2. Indirect impacts: As above Cumulative impacts: As above Alternative 3 Direct impacts: N/A. There are no feasible or reasonable alternatives for the proposed project that will meet the purpose of the project, which is to restore the damaged crossing at the same point, all as described in Section A point 2. Indirect impacts: As above Cumulative impacts: As above

Construction Phase Alternative 1 (Preferred Alternative) Direct impacts:

Impact 1: Terrestrial Biodiversity Impacts

Cause and Comment: The eastern bank of the project area contains intact thicket. An existing ‘disturbance zone’ (car park) provides sufficient space to prevent disturbance to the intact thicket during construction. The current bridge and western bank of the project area are dominated by weedy species, successional species (e.g. Acacia karroo), and disturbed riparian plant communities. The western side of the river is far less sensitive than the eastern bank. The proposed site camp is located outside the riparian area, in a highly transformed landscape (old lands). The proposed site camp has an existing access road to the construction area.

Mitigation Measures:  Prevent construction taking place further east of the existing bridge to avoid impacting on intact thicket;  Avoid the widening of the access roads to prevent the loss of riparian vegetation, where possible;  Where feasible vegetation clearing and trampling should be avoided in this area;  Infrastructure should be located on the western bank if possible;  Alien species found in this area should be removed as part of the Alien management plan;

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Significance Statement:

Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Permanent Localised Moderate Definite MODERATE Mitigation With Mitigation Permanent Study Area Slight Definite LOW

Impact 2: Solid waste generation Cause and Comment: It is anticipated that the proposed development will produce solid waste in the form of building rubble such as excavated soil and vegetation and excess concrete, etc. and general waste during the construction phase.

Mitigation Measures:  Rubble and other construction waste produced should be re-used if possible and where it is not possible must be disposed of at the nearest registered waste disposal facility.  Litter must be controlled during construction – adequate bins must be made available on site at all times. These must be made scavenger proof and must be emptied on a regular basis. Construction materials stored on site must be secured – i.e. plastics must be covered to prevent being blown off site. Skips must be regularly emptied and must be covered.  Any hazardous materials that need to be stored on site must be done so under lock and key

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Short-term Study Area Moderate Probable LOW Mitigation With Short-term Localised Slight May Occur LOW Mitigation

Impact 3: Soil compaction and erosion Cause and Comment: There is a possibility that soil may be compacted by the operation and parking of large construction vehicles. Compacted soil results in the reduced ability for plant growth and water absorption. The clearing of vegetation will result in the exposure of soils. Exposed soils are easily susceptible to erosion by wind and water (i.e. run-off) during high wind or rainfall conditions. Soil erosion may result in an increase in sediment laden water in the Kariega River.

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Mitigation Measures:

 Disturbance and clearing of natural vegetation, should the disturbed area mentioned above not be adequate or provide sufficient space for construction purposes, should be kept to the minimum required for construction.  Newly cleared and exposed areas must be promptly rehabilitated with indigenous vegetation to avoid soil erosion. Where necessary, temporary stabilization measures must be used until vegetation establishes.  Plan for the worst case, that is, for heavy rainfall and runoff events, or high winds.  Appropriate erosion control measures must be implemented and a monitoring programme established to ensure that no erosion is taking place. At the first sign of erosion the necessary remedial action must be taken.  Care must be taken to ensure that runoff is well dispersed so as to limit erosion.  Reasonable measures to limit erosion and sedimentation due to construction activities must be implemented and must comply with such detailed measures as may be required by the EMP.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Short-term Regional Moderate Probable MODERATE Mitigation With Short-term Localised Slight May Occur LOW Mitigation

Impact 4: Surface and groundwater contamination Cause and Comment: The proposed project is for the construction of a road across the Kariega River. Various activities such as poor vehicle maintenance (e.g. oil leaks), improper storage of hazardous materials (i.e. paint and fuel) and washing down practices may result in the pollution of surface and groundwater sources.

Mitigation Measures:  Establish a dedicated area for construction vehicles to refuel and where cement can be mixed. Vehicle re-fuelling and cement mixing must only take place on impervious surfaces and/or drip trays.  Ensure all construction machinery is in sound working order to prevent oil leaks.  Temporary chemical toilets must be provided for the duration of the construction period. These toilets must be made available for all site staff during the construction phase and should be at least 50m from the Kariega River. The developers should also appoint and enter into a contract with qualified third party service provider for the maintenance of the sanitation system.

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 Adequate waste disposal (litter) bins must be available on site. These must be properly secured and covered to prevent scavengers from tipping them.  Any hazardous materials that need to be stored on site must be done so under lock and key.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Short-term Regional Severe Probable MODERATE Mitigation With Short-term Localised Slight May Occur LOW Mitigation

Impact 5: Noise Cause and Comment: It can be expected that there will be an increase in noise levels during the site preparation and construction phase of the development. The increase in noise will be associated with the operation of construction vehicles and equipment.

Mitigation Measures:  All construction vehicles must be in sound working order and meet the necessary noise level requirements.  Restrict construction times to working and light hours only to minimize noise pollution.  The normal municipal by-laws with regards to noise control must apply.  Construction staff should not be housed on site.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Short-term Study Area Moderate Probable LOW Mitigation With Short-term Localised Slight May Occur LOW Mitigation

Impact 6: Dust Creation Cause and Comment: There is a possibility that dust will be generated during the construction phase, particularly during high wind conditions.

Mitigation Measures:

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 Prompt rehabilitation and wetting down of recently cleared areas should minimize dust creation.  Construction vehicles must adhere to speed limits.  If fine building materials/sands are to be transported at the back of trucks, they must be adequately covered.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Short-term Study Area Moderate Probable LOW Mitigation With Short-term Localised Slight May Occur LOW Mitigation

Impact 7: Visual Impacts Cause and Comment: Construction vehicles and equipment will be evident in the landscape.

Mitigation Measures:  Generation of dust will increase the visibility of the project, and it is therefore important to employ techniques to suppress dust generation during construction.  The contractor should maintain good housekeeping on site to prevent litter and minimise waste.  Erosion risks should be assessed and minimised as erosion scarring can create areas of strong visual contrast with the surrounding vegetation.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Short-term Study Area Moderate Probable LOW Mitigation With Short-term Localised Slight May Occur LOW Mitigation

Impact 8: Traffic Impacts Cause and Comment: During the construction phase of the proposed development large construction vehicles will be utilizing the existing road network, this may result in the impeding of traffic and damage to existing roads.

Mitigation Measures:

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 Large construction vehicles must not be permitted to utilize public roads during peak hours.  Damaged to public roads caused by large construction vehicles must be repaired immediately.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Short-term Regional Moderate Probable MODERATE Mitigation With Short-term Localised Slight May Occur LOW Mitigation

Impact 9: Employment creation Cause and Comment: The construction phase of the proposed development will create a number of temporary jobs for locals within the area.

Mitigation Measures:  As far as reasonability possible local labour should be used.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Short-term Study Area Moderate Definite MODERATE + Mitigation With Short-term Study Area Moderate Definite MODERATE + Mitigation

Impact 10: Increased flow velocities and erosion due to the construction of coffer dams

Cause and Comment: In order to construct the Kariega low-level bridge two coffer dams will need to be constructed, one for each half of the bridge. The cofferdams are constructed successively, construction of the second one being commenced only when the first is completely removed. Because the flow in the river is confined to half of the channel it is possible that increased flow velocities may result in erosion of the banks and / or scour of the bed, especially during high flow events from storms on the upper catchment. If the cofferdam is insufficiently robust to withstand elevated flow rates it may be overtopped and / or washed away, and the material of construction carried downstream.

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Mitigation Measures: If necessary provide temporary protection to the river bed and banks if high flows are anticipated during the construction period. Ensure cofferdams are designed and constructed to withstand elevated flow rates that can reasonably be expected to occur during the construction period. If any material is washed downstream it must be removed as soon as flow conditions permit.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Short-term Study Area Moderate Possible MODERATE Mitigation With Short-term Study Area Slight Unlikely LOW Mitigation

Impact 11: Diversion and increased velocity of surface water flows – Changes to the hydrological regime and increased potential for erosion

Cause and Comment: Due to the nature of the proposed project this will be construction phase impact. The structure could interfere with natural run-off patterns, diverting flows and increasing the velocity of surface water flows in the immediate vicinity of the crossing. This has the potential to increase the potential for erosion, while increasing sedimentation of downstream areas, once flows subside. The downstream sedimentation would result in unnatural sand bank areas that would be colonised by reeds. The reeds then later restrict flows within the system, resulting in flooding of upstream areas. However, this would have already occurred due to the presence of the existing structure.

Mitigation Measures: Stormwater and any runoff generated by the hard surfaces should be discharged into retention structures, rock rip-rap areas or similar structures. These energy dissipation structures should be placed such that flows are managed prior to being discharged back into the natural watercourses, thus not only preventing erosion, but would support the maintenance of natural base flows within these systems, i.e. hydrological regime (water quantity and quality) is maintained.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Permanent Localised Unlikely Moderate MODERATE

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Mitigation With Permanent Localised Unlikely Slight LOW Mitigation

Indirect impacts: Impact 1: The purchase of materials from local businesses where available Cause and Comment: Where possible materials will be sourced from local businesses this will result in a boost of the local economy of the immediate vicinity and surrounding areas.

Mitigation Measures:  None required

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Short-term Study Area Moderate Probable LOW + Mitigation With N/A N/A N/A N/A N/A Mitigation

Cumulative impacts: No cumulative impacts were identified. Alternative 2 Direct impacts: N/A. There are no feasible or reasonable alternatives for the proposed project that will meet the purpose of the project, which is to restore the damaged crossing at the same point, all as described in Section A point 2. Indirect impacts: As above Cumulative impacts: As above Alternative 3 Direct impacts: N/A. There are no feasible or reasonable alternatives for the proposed project that will meet the purpose of the project, which is to restore the damaged crossing at the same point, all as described in Section A point 2. Indirect impacts: As above Cumulative impacts:

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As above

Operational Phase Alternative 1 Direct impacts:

Impact 1: Reduction in erosion of the river banks

Cause and Comment: Currently vehicles are driving across the unprotected river bank on both sides of the river and passing through the river, which is resulting in an increase in erosion on the river banks. When construction of the new bridge is complete these banks will be rehabilitated and stabilised which will result in a reduction in sediment input to the river.

Mitigation Measures: Banks must be rehabilitated, including re-establishment of vegetal cover.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Permanent Localised Probable Slight LOW + Mitigation With N/A N/A N/A N/A N/A Mitigation

Impact 2: Increased safety to road users

Cause and Comment: Once the construction of the low level bridge is complete, traffic will not need to drive through the river which results in safety issues. Driving across the banks and through the river channel will only be necessary if the bridge approaches, or the bridge itself, are damaged by a high flood and becomes impassable

Mitigation Measures: Ongoing maintenance of both the low-level bridge and the approach embankments and immediate repair if damaged.

Significance Statement: Impact Effect Risk or Overall

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Temporal Severity of Likelihood Significance Spatial Scale Scale Impact Without Long-term Localised Probable Moderate MODERATE Mitigation With Permanent Localised Possible Moderate MODERATE + Mitigation

Indirect impacts: No indirect impacts were identified. Cumulative impacts: No cumulative impacts were identified. Alternative 2 (technological alternative) Direct impacts: N/A. There are no feasible or reasonable alternatives for the proposed project that will meet the purpose of the project, which is to restore the damaged crossing at the same point, all as described in Section A point 2. Indirect impacts: As above Cumulative impacts: As above

Alternative 3 (technological alternative) Direct impacts: N/A. There are no feasible or reasonable alternatives for the proposed project that will meet the purpose of the project, which is to restore the damaged crossing at the same point, all as described in Section A point 2. Indirect impacts: As above Cumulative impacts: As above

No-go Alternative Direct impacts:

Impact 1: Erosion of the river banks

Cause and Comment: Currently vehicles are passing through the river which is resulting in an increase in erosion along the Kariega river banks.

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Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Permanent Localised Probable Moderate MODERATE Mitigation

Impact 2: Safety to road users

Cause and Comment: Traffic currently needs to drive through the river which results in safety issues.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Long-term Localised Probable Moderate MODERATE Mitigation

Impact 3: Impact on the aquatic environment

Cause and comment: The present culverts are too small to allow sufficient water flow through the bridge when the river comes down in flood. These culverts also collect considerable amounts of debris during tidal fluctuations, therefore further exacerbating the water flow issue. The flow changes have resulted in the establishment of weedy and unnatural riparian plant species within the river basin. Many of these species are successional and may reproduce substantially under the current conditions.

Significance Statement: Effect Risk or Overall Impact Temporal Severity of Spatial Scale Likelihood Significance Scale Impact Without Permanent Study Area Moderate Definite MODERATE Mitigation

Indirect impacts: No indirect impacts were identified. Cumulative impacts: No cumulative impacts were identified.

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Decommissioning and Closure Phase Alternative 1 It is highly unlikely that the bridge would be decommissioned as it serves as a connecting route from the R343 to another secondary road to the east of the river. Potential impacts were therefore not assessed for the decommissioning or closure of the facilility.

3. ENVIRONMENTAL IMPACT STATEMENT

Taking the assessment of potential impacts into account, please provide an environmental impact statement that summarises the impact that the proposed activity and its alternatives may have on the environment after the management and mitigation of impacts have been taken into account, with specific reference to types of impact, duration of impacts, likelihood of potential impacts actually occurring and the significance of impacts.

The CES colour rating scheme for environmental impacts is presented in table 1 below. Table 1: Ranking matrix of environmental significance.

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For the construction phase of the project eleven potential impacts were identified. These were discussed and given an impact rating based on Table 1 above. Mitigation measures to lessen these impacts were then presented. Refer to Figure 1 below.

With mitigation measures in place, the majority of the negative impacts can be reduced to a low significance ranking.

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Figure 1: Impacts before (top) and after (bottom) mitigation for the construction phase.

For the operation phase, two impacts were identified and assessed. With mitigation measures in place both of these impacts are beneficial.

Additional positive impacts related to the proposed development will include job creation and the purchase of materials from local businesses.

In conclusion, the majority of the impacts associated with the proposed project can be reduced to that of low significance. As a result it is recommended that a positive environmental authorization is issued for the proposed project.

SECTION E. RECOMMENDATIONS OF PRACTITIONER

Is the information contained in this report and the documentation attached YES NO hereto sufficient to make a decision in respect of the activity applied for (in the X view of the environmental assessment practitioner)?

Is an EMPr attached? YES NO

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X

The EMPr must be attached as Appendix F.

If “NO”, indicate the aspects that should be assessed further as part of a Scoping and EIA process before a decision can be made (list the aspects that require further assessment):

N/A If “YES”, please list any recommended conditions, including mitigation measures that should be considered for inclusion in any authorisation that may be granted by the competent authority in respect of the application:  All mitigation measures contained in this report, as well as the EMPr must be adhered to.  An ECO must be appointed for the proposed project. Audits should be completed on a bimonthly basis.  Continued maintenance of low-level bridge, i.e. removing debris from the culverts and repair of the approach embankments after high flows.

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SECTION F: APPENDICES

The following appendixes must be attached as appropriate:

Appendix A: Site plan(s)

Appendix B: Photographs

Appendix C: Facility illustration(s)

Appendix D: Specialist reports

Appendix E: Comments and responses report

Appendix F: Environmental Management Programme (EMPr)

Appendix G: Other information

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APPENDIX A: SITE PLAN(S)

Figure A.1: Proposed site plan

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Figure A.2: Proposed site plan at 1:500 scale

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APPENDIX B: PHOTOGRAPHS

Below are photographs in the eight cardinal directions from the Kariega Bridge site on road DR1950.

Photograph 1: View to the North.

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Photograph 2: View to the North-East.

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Photograph 3: View to the East. Note that vehicle tracks across the river banks are visible.

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Photograph 4: View to the South-East.

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Photograph 5: View to the South.

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Photograph 6: View to the South-West. Note that this is the damaged approach embankment.

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Photograph 7: View to the West.

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Photograph 8: View to the North-West.

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Photograph 9: Extent of the damage to the existing bridge.

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Photograph 10: Vehicle abandoned on the western side of the existing bridge.

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Photograph 11: The area where vehicles are currently traversing the river during periods of low flow.

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APPENDIX C: FACILITY ILLUSTRATION(S)

PLEASE NOTE: AN A1 PLAN HAS BEEN SUBMITTED AS PART OF THE BAR DOCUMENTS

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APPENDIX D: SPECIALIST REPORTS

D.1 AQUATIC ASSESSMENT

Aquatic Assessment: Kariega River Bridge

Prepared by:

EOH Coastal & Environmental Services

November 2014

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ACRONYMS

DWS Department of Water and Sanitation (formerly the Department of Water Affairs) EIS Ecological Importance and Sensitivity GIS Geographic Information System PES Present Ecological State SABIF South African Biodiversity Information Facility, a SANBI database that contains both faunal and floral species records SANBI South African National Biodiversity Institute WUL Water Use Licence WULA Water Use Licence Application

INTRODUCTION

EOH Coastal & Environmental Services (EOH CES) was appointed to conduct an application for environmental authorisation, supported by an aquatic specialist assessment for the proposed re- construction of a low-level bridge on the Kariega River on District Road (DR) 1950, in the Ndlambe Municipality, Eastern Cape Province. The purpose of the study is to investigate the potential impacts on the section of the river that could be affected by the proposed construction activities and bridge structure. EOH CES conducted a Present Ecological State (PES) assessment of the aquatic systems within the alignment footprint of the crossing, as well as within a 500m radius of the site. This report will thus also form part of the Water Use Licence Application (WULA) required by the National Department of Water and Sanitation (DWS).

The following documents (amongst others) are required for the WULA by DWS:  Delineation of riparian and wetland areas, together with a desktop analysis and potential sensitivity identification due to the close proximity of the development to the river.  This report, detailing the current ecological condition of the river and riparian systems after a short site visit has been conducted for a Section 21 water use application.  Section 21 (c) and (i) use, i.e. river or wetland crossings, which includes any drainage lines by any infrastructure.

Figure 1: Locality map indicating the project site

Figure 2: The water bodies investigated in relation to the proposed development

RELEVANT LEGISLATION AND POLICY

The South African Constitution, seven (7) of South African Acts and one (1) international treaty allow for the protection of rivers and watercourses. These systems are thus protected from destruction or pollution by the following:  Section 24 of The Constitution of the Republic of South Africa;  Agenda 21 – Action plan for sustainable development of the Department of Environmental Affairs and Tourism (DEAT) 1998;  National Environmental Management Act (NEMA), 1998 (Act No. 107 of 1998) including all amendments, as well as the NEM: Biodiversity Act, 2004 (Act 10 of 2004);  National Water Act, 1998 (Act No. 36 of 1998);  Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983);  Minerals and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002);  Eastern Cape Nature and Environmental Conservation Ordinance (No. 19 of 1974);  National Forest Act (No. 84 of 1998); and  National Heritage Resources Act (No. 25 of 1999).

This report will be used as per the relevant submissions to the Department of Water and Sanitation (DWS) in terms the required licences.

Provincial legislation and policy

Various guidelines on buffer zones for aquatic systems have been issued in a number of the provinces, including the Eastern Cape Province, and those stated in this report are based on accepted provincial guidelines as stated in the Eastern Cape Biodiversity Conservation Plan (ECBCP). These are stated below so that the engineers and contractors are aware of the necessity to take these buffer zones into account during the planning phase. Although construction will have

to take place within the watercourse the associated concrete batching plants (if required), stockpiles, lay down areas and construction camps should avoid the buffer areas.

With regard to protected flora, which includes wetland / riparian flora, the Eastern Cape Provincial Nature Conservation Ordinance (PNCO) includes a list of protected flora. Any plants found within the sites will be described in this report. Should any species that are listed in the ordinance be found, the relevant permits must be obtained by the applicant before plants are either relocated or destroyed.

Table 1: Recommended buffers for rivers highlighted in blue from Berliner & Desmet (2007). Criterion used Buffer width Rationale (m) Mountain streams and upper 50 These longitudinal zones generally have more confined foothills of all 1:500 000 rivers riparian zones than lower foothills and lowland rivers and are generally less threatened by agricultural practices. Lower foothills and lowland 100 These longitudinal zones generally have less confined rivers of all 1:500 000 rivers riparian zones than mountain streams and upper foothills and are generally more threatened by development practices. All remaining 1:50 000 32 Generally smaller upland streams corresponding to streams mountain streams and upper foothills, smaller than those designated in the 1:500 000 rivers layer. They are assigned the riparian buffer required under South African legislation.

STUDY AREA DESCRIPTION

The proposed project is located along the Kariega River, on a gravel road (DR1950) en-route to Southwell just north of Kenton-on-Sea (Figure 1). The proposed development became necessary after heavy rains caused the Kariega River Bridge, which is a low level crossing, to collapse (refer to Plate 1). Traffic has been forced to cross through the river, which poses a safety risk to motorists as the bridge is still within the tidal influence. Repeated vehicle crossings through the river are also causing damage to the bed and banks of the river.

Plate 1: Collapse of the low level bridge.

The study area hydrology was characterised mostly perennial flows in the Kariega River and no measurable flows from any of the drainage lines (Figure 2). The steep river banks within the survey reach are formed through a combination of the softer sediments contained in the regional geology and localised flooding events. The rivers are thus scoured and become incised over time and thus limit the development of wide floodplain areas, with the associated broad riparian zones. Thus wide riparian zones are not a natural phenomenon of this system.

METHODS

Study terms of reference

EOH CES based this study on the following scope of work:  Identify and delineate all aquatic systems that may be impacted by the proposed bridge reconstruction;  Identify and rate potential environmental risks with regard to the aquatic zone;  Provide a significance rating of surface water impacts which includes a rating of the ecological sensitivity of the site;  Identify mitigations for negative impacts.

Based on these requirements, the following have been produced:  River and wetland area delineation,  In-stream Present Ecological State (PES) based on the in-stream aquatic habitats identified in the affected river reach,

 Riparian Present Ecological State (PES) assessment after a short site visit has been conducted; in line with the Department of Water Affairs requirements with regard to the necessary licences.

Study methods

The assessment was initiated with a survey of relevant literature and previous reports that exist for the study region. A site visit was then conducted to ground-truth the findings to see whether it is pertinent to the site. Information was also collected to determine the PES of the site. These analyses were based on the models developed by the Department of Water Affairs, with the results producing a ratings (A – F), summarised in Table 2. The importance of the study area was also assessed against local and provincial conservation plans such as the Conservation Plan.

Table 2: Description of A – F ecological categories based on Kleynhans et al., (2005) ECOLOGICAL MANAGEMENT ECOLOGICAL DESCRIPTION CATEGORY PERSPECTIVE Protected systems; relatively untouched by human hands; no A Unmodified, natural. discharges or impoundments allowed Largely natural with few modifications. A small Some human-related B change in natural habitats and biota may have disturbance, but mostly of low taken place but the ecosystem functions are impact potential essentially unchanged. Moderately modified. Loss and change of natural habitat and biota have occurred, but the basic Multiple disturbances C ecosystem functions are still predominantly associated with need for socio- unchanged. economic development, e.g. impoundment, habitat Largely modified. A large loss of natural habitat, modification and water quality D biota and basic ecosystem functions has occurred. degradation

Seriously modified. The loss of natural habitat, E Often characterized by high biota and basic ecosystem functions is extensive. human densities or extensive Critically / Extremely modified. Modifications have resource exploitation. reached a critical level and the system has been Management intervention is modified completely with an almost complete loss needed to improve health, e.g. F of natural habitat and biota. In the worst instances to restore flow patterns, river the basic ecosystem functions have been habitats or water quality destroyed and the changes are irreversible.

RESULTS

Vegetation

A site survey was conducted 100 m either side of the bridge. Broad aquatic and riparian zones were not evident, with little or no permanent riparian / obligate riparian species found within this reach. This was due to the steep nature of the river banks, which precludes the development of wide riparian floodplains. In addition the area was also degraded. Some narrow fringes of hygrophilous grasses and sedges were observed. Forb (herbaceous flowering plants that are not grasses, sedges or rushes) and woody species were thus limited to invasive or encroaching species such as Acacia spp and Euphorbias.

Plate 2: Steep river banks with narrow fringes of grasses and sedges

Debris was found to accumulate in the area around the bridge, especially after flood events. This debris then accumulates in the river and may form blockages (dams) when trapped by other alien vegetation or the bridge itself.

No protected plants or plants species of special concern were observed within or adjacent to the water courses due to the degree of past disturbance.

Fish and instream aquatic habitats

The fish survey did not reveal any fish in the river reach 100m upstream and downstream of the bridge although tadpoles, frogs and crabs were observed, and aquatic habitats appeared capable of supporting fish life.

The dominant species caught in the river according to Richards et al (2004) were Solea bleekeri, Glossogobius callidus and Heteromycteris capensis. Other species which occurred in moderate numbers were Gilchristella aestuaria, Psammogobius knysnaensis Rhabdosargus holubi, Caffrogobius gilchristi and Pomadasys commersonnii. In general, the mouth region and upper reaches tended to have lower numbers of fish species than the middle reaches (Richards et al, 2004).

The Fish Response Assessment Index (FRAI) assessment, largely based on the condition of the in stream aquatic habitats in the Study Area, gave the present ecological status (PES) in terms of fish as Category D, due to the large loss of aquatic biota and natural aquatic habitat. The main impacts are related to destruction of indigenous riparian and marginal vegetation, increased sediment input and water abstraction and damming in the catchment.

Present Ecological State

The overall condition or Present Ecological State (PES) of the system was assessed using accepted methodologies. A desktop analysis of the system revealed an overall PES for the river

reach within the study area and was rated as Category C (Moderately modified – Table 3). Due to the numerous impoundments along the system the current hydrological PES of the system is rated as D. The geomorphology PES is rated as C and the vegetation PES is rated as D due to the large amount of invasive species and transformed land upstream as well as due to the lack of riparian zone continuity due to the lack of natural vegetation cover.

Conservation importance

Of interest is the National Freshwater Ecosystems Priority Areas. Several important catchments (sub-quaternaries or SQ) have been earmarked, based either on the presence of important biota (e.g. rare or endemic fish) or the degree of riverine degradation, i.e. the greater the catchment degradation the lower the priority to conserve the catchment. The important catchments areas are then classified as Freshwater Ecosystems Priority Areas or FEPAs (Figure 2).

Recommended buffers

According to national policies and DWA accepted best practices, these rivers should receive a buffer of 50 m. Based on this assessment and the proposed designs, this project would have little physical impact on the conservation importance and functioning on the riparian systems, should the project proceed. It is recommended that no stockpiles or laydown areas, construction camps or other works associated with the upgrade are located within the 32 m buffer. The rationale being, that due to the channel form - steep river banks with no floodplain areas - buffering the river by 50 m would not contribute significantly more to the conservation of riverine habitat than will be protected by a 32 m buffer.

IMPACT ASSESSMENT

The impact assessment was derived from the methodology provided by EOH CES, the proposed project description and the conceptual design layout, which was measured against the current state of the observed water courses. Several impacts have been highlighted and have been rated based on the project actions / impacts, as well as any potential cumulative impacts during the construction and operational phases of the project. These were also assessed with and without mitigation. It should be noted that some of the impacts assessed will have a negative impact on the aquatic systems, which were assessed with a high degree of confidence based on our understanding of aquatic systems, its catchment and past experience from assessing similar types of proposals. This would be mostly associated with the construction phase. There are however a number of social and ecological impacts in the form of traffic safety and controlled river crossing that would have a positive impact on the environment.

The potential construction phase impacts will result from the physical changes to the catchment, i.e. removal of vegetation and the disturbance of soils. The operational phase will result in the diversion and or / alteration of flows (volume and velocity) due to the hard engineered structures such as the road and the bridge / culvert crossings. These changes in the hydrological regime then pose impacts such as erosion of the riverbed and then later sedimentation of downstream areas. However due to the nature of the Kariega River system, coupled to its current modified state, all the potential impacts would be similar for any of the proposed alternatives. This is also due to similarities in the structure and function of the previous structure in the study area.

Impact 1: Diversion and increased velocity of surface water flows – Changes to the hydrological regime and increased potential for erosion

Nature of the impact Due to the nature of the proposed project this will be a construction phase impact. The structure could interfere with natural run-off patterns, diverting flows and increasing the velocity of surface water flows in the immediate vicinity of the crossing. This has the potential to increase the potential for erosion, while increasing sedimentation of downstream areas, once flows subside. The downstream sedimentation would result in unnatural sand bank areas that would be colonised by

reeds. The reeds then later restrict flows within the system, resulting in flooding of upstream areas. However, this would have already occurred due to the presence of the existing structure.

Significance of impacts without mitigation The soils within the study area are susceptible to erosion when subjected to high-velocity flows. This creates bed and bank instability in the aquatic ecosystems and consequent sedimentation of downstream areas.

Due to the nature of the study area hydrology, its present state and the surrounding impacts the negative impact, although permanent would be localised and unlikely; resulting in a medium intensity impact if the crossings are constructed. Thus the overall significance of the impact would be rated as Medium.

Proposed mitigation Stormwater and any runoff generated by the hard surfaces should be discharged into retention structures, rock rip-rap areas or similar structures. These energy dissipation structures should be placed suchthat flows are managed prior to being discharged back into the natural watercourses, thus not only preventing erosion, but would support the maintenance of natural base flows within these systems, i.e. hydrological regime (water quantity and quality) is maintained.

Significance of impact with mitigation Although permanent changes to the local hydrological regime are probable, the intensity of negative impact in the operational phase would be low, thus the overall significance of this impact would be Low. This impact is also partially reversible should the roads and related infrastructure be decommissioned.

Impact 2: Impact of changes to water quality

Nature of the impact During the road construction the discharge of various materials, such as sediments, diesel, oils and cement, into the watercourse will pose a threat to the continued ecological functioning of the instream and adjacent areas, if by chance it is dispersed via surface run-off, or are allowed to permeate into the groundwater. The potential negative changes to water quality during the operational phase would be limited to sedimentation, erosion and hydrocarbon related issues. These negative impacts would persist into the medium term.

Significance of impacts without mitigation Changes to water quality (surface and groundwater) impact on the functioning of plants and other in stream biota. This impact without mitigation significance would be Very High, as excessive pollution will also impact on in stream conditions due the introduction of toxins. Potential toxins include the following:  Grout and concrete – these products contain cement which increases the pH (basic) of surface waters and impairs the metabolism and breathing physiology of aquatic organisms  Hydrocarbons (shutter oil, other lubricants, grease and fuels) – The persistent impact of these pollutants is varied, but can impact negatively on metabolic pathways, cellular structures (plant and animal), respiration and gene stability (heavy metals)

Proposed mitigation  Chemicals used for road surfacing and bridge building must be stored safely on site and surrounded by bunds. Chemical storage containers must be regularly inspected so that any leaks are detected early  Littering and contamination of water sources during construction must be prevented by effective construction camp management.  Emergency plans must be in place in case of spillages onto road surfaces and water courses.  All stockpiles must be protected from erosion, stored on flat areas where run-off will be minimised, and be surrounded by bunds.

 Stockpiles must be located away from river channels.  Under no circumstances should materials be stockpiled in watercourses, whether dry of flowing.  Erosion of and the deposition of sediment into river channels must be minimised through effective stabilisation materials such as gabions and Reno mattresses, and the re-vegetation of any disturbed riverbanks.  The construction camp and necessary ablution facilities meant for construction workers must beyond the 50m buffer described previously.  Works should be limited to dry periods within the river bed.  Any stormwater runoff should not be allowed to enter any water courses directly, to minimise the potential hydrocarbon related issues.

Significance of impact with mitigation Should the construction site and the works be managed properly, the negative impacts would remain localised and in the short-term. This would result in an overall significance of Low for the culverts.

Direct Impact Extent Duration Intensity Probability Significance Significance Status Confidence without with mitigation mitigation Diversion and increased Highly velocity of Local Permanent Medium MEDIUM LOW Negative High Probable surface water flows Impact of changes to Regional Permanent High Probable HIGH LOW Negative High water quality

CONCLUSION AND RECOMMENDATIONS

The negative impacts associated with the project are related to:  The potential for generating increased sediment loads in the river: Elevated turbidity due to mobilization of fine sediment, particularly during the construction phase, can have a significant and even lethal impact on aquatic biota, including fish. These impacts include reduced primary production, smothering of benthic organisms and fish eggs, clogging and abrading of fish gills (leading to disease and death) and reduced feeding efficiency of visual predators. The current sedimentation and increased turbidity after rains in the degraded Kariega River catchment is probably as one of the major negative impacts on native fish populations.  The possibility of chemical pollution during construction. During the construction of the infrastructure within the Kariega River channel and adjacent areas, a range of hazardous materials (such as hydrocarbons, bitumen, cement, paints, cleaning/shutter fluids) associated with the construction activities and machinery used, could pollute the river unless great care and adequate precautions are taken.

Current land use, the creation of barriers in the river, abstraction of water from the river, and the spread of alien vegetation have all had a significant impact on the functioning and importance of the aquatic systems within the study region.

The proposed bridge is to replace an existing crossing that wsa destroyed ina recent high flodd, and the project will therefore restore an existing public amenity.

Accordingly it is recommended that the proposed project is authorised, subject to strict adherence the conditions outlined in this report.

APPENDIX E: PUBLIC PARTICIPATION PROCESS AND COMMENTS AND RESPONSES REPORT

This Section of the report provides the details of the Public Participation Process followed for the proposed project. Public participation provides for the involvement of Interested and Affected Parties (I&APs), in forums that allow them to voice their opinions and concerns, at an early stage of the proposed project. Such engagement is critical in the BAR, as it contributes to a better understanding of the proposed project among I&APs, and raises important issues that need to be assessed in the EIA process.

PUBLIC PARTICIPATION TO DATE

There are four key steps within the overall public participation process. These include -  Notifying I&APs of the BAR process;  Holding public meetings;  Making provision for I&APs to review and comment on all reports before they are finalised and submitted to the competent authority; and  Making a record of responses to comments and concerns available to I&APs.

Notifying Interested and Affected Parties of the proposed project

Background information document

A Background Information Document (BID) was prepared that provided basic information on the proposed project, the BAR process and contact details for registration as an I&AP. The BID was sent to all persons and organisations identified as I&APs as well as landowners and surrounding land owners via e-mail. In the cases where no email addresses were available, BIDs were distributed in person. The list of identified I&APs and a copy of the BID are included below.

Title, Name and Affiliation/ key stakeholder Contact details Surname status Mr Nick Fox Land owner at Sibuya Game [email protected] Reserve, Vintony Farm Pty Ltd Tel: 046 648 2020 Fax: 046 648 2114 Cell: 083 648 2020 Mr Graeme Rushmere Land owner: Gorah Gorah Lodge [email protected] (Pty) Limited Tel: 041 581 2606 041 581 2601 Cell: 083 601 8503 Mr Andries Struwig Department of Economic [email protected] Development Environmental Tel: 0415085800 Affairs and Tourism (DEDEAT) Mr Joseph Jacobs Department of Water Affairs and [email protected] Sanitation Tel: 0415864884 Ms Skumsa Mancotywa DEA [email protected] Acting Deputy Director-General Biodiversity and Conservation Mr Ishaam Abader DEA [email protected] Deputy Director-General Legal Authorisations and Compliance Inspectorate

Mr T Nokoyo DAFF [email protected] Mr Rolly Dumezweni Ndlambe Municipality [email protected] Municipal Manager Tel: 046 604 2774 Mr L E Khoathani Ndlambe Municipality [email protected] Ward Councillor – Ward 3 Tel: 082 403 1000

Ms Marilyn Tarentaal Ndlambe Municipality [email protected]

Ward Councillor – Ward 6 Tel: 079 028 9236 Mr Xolani Masiza Ndlambe Municipality [email protected] Director: Infrastructure Tel: 046 624 1140 Development Department of Roads and Public [email protected] Works [email protected] [email protected] [email protected]

ECPHRA [email protected] Mrs Colette Scheermeyer SAHRA [email protected] Tel: 021 462 4502

Mr Morgan Griffiths WESSA [email protected]

Ms Megan Hope Eastern Cape Conservancies [email protected] Emlanjeni Private Game Reserve [email protected] Tel: 046 648 2911

Ms Anneliza Collett Department of Agriculture [email protected]

Alan Weyer Kariega Game Reserve [email protected] Ms Ane Oosthuizen SANParks [email protected] Dr Stephen Holness [email protected] [email protected] [email protected] [email protected]

Advertisements

An advertisement was placed in The Herald Newspaper on 15th of July 2014 in order to:

 Advise readers of the intention to undertake an EIA for the proposed development; and  Invite them to register as I&APs.

A copy of the advertisement(s) is included below. A second advertisement will be placed in the Herald to announce the release of the Draft Basic Assessment Report for public review. A copy of this advertisement will be included in the Final BAR Report.

Site notices

The NEMA regulations require the erection of “a notice board at a place conspicuous to the public at the boundary or on the fence of the site where the activity to which the application relates is or is to be undertaken; and any alternative site mentioned in the application”.

Therefore in accordance with this requirement, one 800 X 600mm single sided corex notice board was erected at the turnoff from the main road (R72) to the site.

The photographs of the fixed notices are provided below.

Public Meetings

A public meeting will be held during the period of public review of the Draft BAR. Details of this meeting will be included in the advertisement to be posted in the Herald. In addition the relevant details will be emailed to all registered interested and affected parties. The attendance register and minutes from the meeting will be included in the Final BAR.

Registration of Interested and Affected Parties and Comments Database

A register of I&APs has been compiled and included below, containing all available contact details of those who responded to the advertisement(s), or registered as I&APs.

I&AP that registered during the pre-assessment public participation process

STAKEHOLDER CONTACT PERSON CONTACT DETAILS WESSA Morgan Griffiths [email protected] SAIAB Angus Paterson [email protected] Tel: 046 603 5800 Fax: 046 622 2403 Cell: 083 275 4407 SIBUYA GAME RESERVE & Nick Fox [email protected] LODGE (PTY) LTD Tel: 046 648 2020 Fax: 046 648 2114 Cell: 083 648 2020

Issues and Response Trail

The table below contains all comments received to date, as well as the responses to these comments by the EAP. The table will be supplemented with any comments received from the release of the Draft BAR for public review as well as the public meeting. This will be included in the Final BAR.

Comments and response trail

I&AP ISSUE RESPONSE Angus Paterson How do we maximise the The proposed culverts are aligned (orientated) flow e.g. size, position and in-line with the natural flow path of the river, number of culverts? whereas the current (old) culverts are orientated at an angle to the natural flow path. This resulted in deposition of sediment, a restricted discharge capacity, and ultimately failure because the approach embankment was overtopped and washed away. The proposed culverts are 2400mm wide x 1800mm high, and allow for continuous flow over the entire width of the river. The concrete apron on the upstream side of the culverts creates optimum approach conditions and flow through the culverts. Angus Paterson The current design allows for Yes, if necessary, but the structure is designed 6 culverts. Can more be as a low level bridge and allows for overtopping included? for design floods bigger than 1:2 years. The six culverts currently included are calculated to adequately handle the 2-year flood, which has an estimated peak flow rate of 52m³/s, and therefore it is not necessary to include more culverts. Overtopping conditions are estimated to occur at 90m3/s. The banks of the river and the approach embankments will be protected against erosion during overtopping by Reno

mattresses, stone-filled gabions and grouted stone pitching. Angus Paterson They need to ensure that Design is based on a surveyed area of the what they think the bed level section. This was completed at the beginning of is, is indeed the real bed 2014. level or a perched level resulting from previous reclamation. Angus Paterson The design must ensure that Noted, levels proposed by the engineer must be the culverts are not perched verified on site by contractor prior to the above the spring low level commencement of work. i.e. they allow water passage at all tidal levels. Angus Paterson The area is used by This proposal will be presented to client. fishermen and bird watchers is there any chance of creating a small paved area for parking and a picnic bench and table area. The Game parks may not like this but they do not own the road. Angus Paterson Obviously there must be a Noted. Provision has been made for an on-site good construction and ECO in the recommendations. rehabilitation plan with on- site ECO inspection. The Kenton community are very vigilant and put a stop to a recent project on the Bushmans which was not complying with the authorised activities. Angus Paterson As an added benefit you may This can be allowed for in BOQ if the cost is wish to chat with Dr Tommy marginal. Bornman of SAEON [email protected] to see if he would like a small instrument housing included in the design. This would be a very very marginal cost and would involve concreting a small stainless steel structure to one of the culverts which will allow the deployment of scientific instrumentation. Nick Fox There are other roads within Noted. This issue will be presented to the client. the Ndlambe Municipal area that require attention and due to limited funds it is suggested that these are fixed and/or maintained prior to the reconstruction of the Kariega low-level bridge, as the DR1950 is not utilized by the local communities.

Copies of comments/issues received from I&APs

1. Angus Paterson

From: Angus Paterson [mailto:[email protected]] Sent: 01 July 2015 12:48 PM

To: Kim Brent Cc: Alan Whitfield; Tommy Bornman Subject: Kariega causeway upgrade - initial comments

Hi Kim

The Kariega system becomes hyper-saline (saltier than the sea) in the upper reaches during drought years which is presently exacerbated by the poor causeway design which grossly restricts flow. Thus a new design which increases flow is of potential ecological benefit to the system. So the key design questions should be:

1) How do we maximise the flow e.g. size, position and number of culverts? 2) The current design allows for 6 culverts. Can more be included? 3) They need to ensure that what they think the bed level is indeed the real bed level or a perched level resulting from previous reclamation. 4) The design must ensure that the culverts are not perched above the spring low level i.e they allow water passage at all tidal levels. 5) The area is used by fishermen and bird watchers is there any chance of creating a small paved area for parking and a picnic bench and table area. The Game parks may not like this but they do not won the road! 6) Obviously there must be a good construction and rehab plan with on site ECO inspection. The Kenton community are very vigilant and put a stop to a recent project on the Bushmans which was not complying with the authorised activities. 7) As an added benefit you may wish to chat with Dr Tommy Bornman of SAEON [email protected] to see if he would like a small instrument housing included in the design. This would be a very very marginal cost and would involve concreting a small stainless steel structure to one of the culverts which will allow the deployment of scientific instrumentation.

Kind regards

Angus

2. Nick Fox

Reply CES 25th June 2015

Dear Chantel

I refer to our earlier discussions. You have asked me to detail my discussions with Jesse Jegels and add photographic evidence to back up any assertions. Accordingly I have driven the Southwell road (DR 1949) from the intersection with the R 72 to the intersection with the Ghio to Port Alfred road (DR 1950) and have taken pictures as I went Then I have driven on the road to the Causeway, back to the intersection and then down to the Kasouga bridge again taking relevant photos as I went. (see arrows on map below).

However I start with the premise that the Causeway needs repair because it is the alternate route should the Kariega bridge be washed away (as proposed by the Department of Roads). I copy the content of an email from Marius Keyser (Dept of Roads EC) in December 2012

“Hi Nick We are now progressing well with repairing the extensive damage on our provincial road network in Ndlambe caused by the floods late last year . Works on DR1950 are scheduled for February and will address the approaches to the Kariega River . As DR1950 remains strategically important as an emergency by-pass for the R72 the causeway structure over the Kariega River has been assigned priority status for in the departmental bridge rehabilitation program for upgrading . The local Roads Committee representative Francois Kruger is also kept informed of the progress and planning . We trust the matter of the gates will now be resolved. Marius”

However, I maintain, the Kenton bridge should never wash away if the proper repairs required are effected, and the bridge and its surrounds are properly maintained. There is only one possible exception - that being the failure of the Settlers Dam wall, causing a wall of water to flood the valley and reach the Kenton Bridge. And if the bridge were washed away (because of bad maintenance or failure of Settlers dam as detailed above) the alternate route, the DR 1950, would almost certainly be unusable as well. Any flooding of a magnitude required to damage the Kenton bridge would in all likelihood completely destroy any causeway across the Kariega (new or old) but would most certainly cause such enormous damage to this steep and hilly gravel road as to make it completely impassable to all vehicles.

To address these two points, firstly let me start with the Kariega Bridge on the R72 and why it is unlikely to wash away except in the instance of failure of the Settlers dam wall.

The floods of 2012, where approximately 650mms of rain fell in the immediate catchment area of the Kariega River within a 30 day period, were by all accounts the heaviest rainfall in a month recorded for the last at least fifty and probably the last hundred years. The river rose to an exceptional level and carried volumes of water at the causeway (on the DR 1950) apparently not seen in living memory - at least 50 years and again most likely in the last hundred years.(see comparative pictures below).

Therefore with certainty we can say these floods can be classified as at least 50 year and possibly 100 year floods. There was no damage to the Kenton Bridge structure itself but the entrance to the bridge from the East, sustained a certain amount of gouging of the fill on the eastern approach. Repairs were effected by the installation of a gabion buffer wall, which was subsequently damaged again in the floods of 2013. (Although this damage was pointed out to the roads engineers this has inexplicably still not been repaired).

The reason, I believe, that the Kenton bridge remained relatively unscathed, is that the Kariega river, at 138 kms in length, is a relatively short river with a small total catchment area of only 646 square kms. With the Settlers Dam acting as a reservoir, it requires at least two record amounts of rainfall to firstly fill Settlers Dam and then cause severe flooding thereafter as happened in 2012.The floods of that year bear out the point that if properly maintained the Kariega bridge can withstand this water surge without too much problem. However, my concern is that, two years later the necessary repairs have still not been adequately effected, placing the entrance to the bridge at risk in the event of another major flood.

See pics below of damage to gabions and scouring (pictures taken at relatively high tide)

Secondly, should the flooding be so severe as to cause the failure of the Kenton bridge, then without doubt the damage further upstream where the valley is narrower would be catastrophic, probably removing the causeway altogether. And even should the structure survive, the damage to the gravel approaches and indeed the entire gravel road would be so severe (as occurred in 2012) as to make the road completely impassable.

This road has not been resurfaced or maintained for years. It is not used by the local residents except those immediately adjacent, being Sibuya Game Reserve and Kariega Park. It is only used by the general public, primarily in December, for game viewing purposes and not for access or as a through road. It is for this reason, plus the extreme shortage of available funds for road maintenance that the DR 1950 has remained completely unmaintained for most of the last decade. For this road to serve as an alternate route to the R72, it would need to be completely rebuilt and unless tarred would still not be suitable for such a purpose.

The thought might be that repairs to the causeway and the entire DR 1950 might be able to be effected quicker than the rebuilding of the Kenton bridge and this may be true. However even once repaired, unless tarred, this road would have to be closed every time it rained as one or two vehicles getting stuck (as would undoubtedly happen) would block the entire route. The presence of big 5 animals in the vicinity and the lack of cell phone coverage in the valley would make it particularly unpleasant and unsafe for anyone stuck as walking out of the valley to call for help would be extremely dangerous.

Floods of 2006 – compare water level over Causeway with 50 -100 year flood of 2012 (below)

Floods of 2012 – compare water level over Causeway with 10-25 year flood of 2006 (above)

Hence my assertion that as far as the residents of Southwell are concerned; the hundreds of thousands of Rand proposed to be spent on this project, should rather be used to repair and properly maintain (on a consistent basis) the main access road, being the DR 1949, which is used by the local farmers to supply goods and services and deliver products to the various markets.

The shocking state of disrepair of this road is clearly evident in the series of photographs below that chronicle the various faults that have remained unrepaired since the floods of 2013. The work on this road is inconsistent at best and poorly considered and implemented at worst. A great deal of money was spent on completely resurfacing it about three years ago and because of shoddy and unprofessional maintenance, a road that should last 15- 20 years will need complete resurfacing in less than half that time.

Although I have not marked the positions of each photograph on a map this can easily be done should it be required.

The start of the DR1949 – the Southwell Road and access for the Southwell farming community

Inadequate maintenance of the storm water drainage causing flooding and damage

Repair work (filling of pot holes) carried out by the local farmers as this is never done by the Municipality

Completely blocked storm water drains causing water to flood over and damage the road surface

Completely blocked storm water gullies forcing water to run down the middle and next to the road, causing massive damage and erosion

Incorrect grading resulting in incorrect camber on the road – result storm water flowing down the middle of the road and scouring the gravel surface

Further evidence of scouring and rivers next to the road damaging the road edges

Condition of the DR 1949 at the Southwell road and DR 1950 intersection

The intersection of DR 1949 and DR 1950

DR 1950

This road has not been maintained for years mostly at the insistence of the local residents. With the current prevailing constraint of funds, that has apparently been the case for most of the last decade, we have consistently requested that all funds available be utilised on the DR 1949 and not the DR 1950. Letters in this regard have been addressed to the various authorities on behalf of the farmers (I refer to submissions by Justin Stirk in particular).

Accordingly this road has deteriorated to such an extent that any thought that it may be used as an alternative to the R72 is misguided and irrational. I repeat, for this to be a viable option, it would require tarring from the Ghio turn off on the R72 right through to the end of the Southwell to Grahamstown road at Port Alfred - a distance of, I would guess, about 35kms. Anything less would be pointless, as were the Kenton bridge to be destroyed, the likelihood of the Kasouga and the Bushmans River bridges being destroyed at the same time, is almost a certainty. In fact, after the floods of 2012 the Kasouga bridge, on the R72 had to be closed for a period to undergo repairs, whilst the Kenton bridge remained open.

The below series of photographs depict the state of the DR 1950 from the intersection to the Causeway bridge, which we have repaired to make it passable.

It is possible to see that this road largely has no gravel surfacing left at all.

I have also added a picture to depict the steepness (with a vehicle in it) although the 2D effect does not show this too well

Blocked or lack of storm water drains

Severe gouging to the side of the road

Severe damage to the road by water on the surface due to blocked drains

Blocked and broken drainage pipes

Road completely devoid of gravel surface

Steep inclines completely impassable to trucks and low profile cars especially in the wet

Causeway:

We have previously (2005) applied to privatise the DR 1950 and therefore to maintain it ourselves. This was refused on the basis that it is an alternate route to the R72. However as described above this is not a workable option. Even were the roads Department to insist on this option, such a massive repair job is completely out of proportion to the usage of this road and would be done in a void without at least the same work being done to the Kasouga bridge further down the DR 1950 and an entire upgrade of the entire road as a whole. I reiterate; as a community asset the local community would far prefer the funds spent on upgrading and maintaining the DR 1949 which is our main access road and which in its current condition, is the cause of astronomical vehicle maintenance bills for the community as a whole.

We have in the meanwhile repaired the Causeway, at our own cost, to facilitate access for our game drive vehicles to the portion of the Reserve that lies to the west of the Kariega River.

Existing Causeway repaired by ourselves to facilitate access to our Game Vehicles.

The Kasouga bridge, to the East of the DR 1949 intersection is a far more necessary bridge requiring repairs. This bridge is not only used by farmers accessing the Charlgrove Auction Yard with cattle trucks, but is the only access for us to reach our Bush Lodge, situated on the northern side of the Kasouga river. Since the recent floods we have used our machinery and staff to make this bridge accessible to vehicles but it requires a complete rebuild to render it safe.

The severely damaged Kasouga bridge - West side approach with temporary repairs effected by the local residents

The severely damaged Kasouga bridge - East side approach

In Conclusion

The concept of spending hundreds of thousands of Rands on rebuilding the Kariega causeway in isolation is a complete waste of public funds. This road in its present state can never serve as alternate route to the R72.

The bridge over the Kasouga River is a far more strategic asset, used substantially more by the local residents and if any bridge were to be rebuilt, it should rather be this one.

SANRAL should urgently attend to the existing damage to the Kenton bridge and should constantly be vigilant to the status of this structure and its surrounds. Should this happen there will be no necessity for an alternate route.

APPENDIX F: ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR)

PROPOSED RECONSTRUCTION OF THE KARIEGA LOW LEVEL BRIDGE IN THE EASTERN CAPE PROVINCE

Prepared for:

SMEC Engineers

On behalf of

Eastern Cape Department of Roads and Public Works Qhasana Building, Independence Avenue, Bhisho, 5605

Prepared by:

EOH Coastal & Environmental Services (CES) Port Elizabeth 13 Stanley Street Richmond Hill Also in Grahamstown, East London, Gauteng, Cape Town and Maputo

www.cesnet.co.za

June 2015

This Report should be cited as follows: Draft Environmental Management Plan: Proposed reconstruction of the Kariega Low Level Bridge, within the Ndlambe Municipality, Eastern Cape province, EOH Coastal & Environmental Services. June 2015. Port Elizabeth.

INTRODUCTION

An Environmental Management Programme (EMPr) must consist of a set of mitigation, monitoring and institutional measures to be taken during implementation and operation to eliminate adverse environmental and social impacts, offset them, or reduce them to acceptable levels. The plan also includes the actions needed to implement these measures.

ENVIRONMENTAL MANAGEMENT PROGRAMME

An Environmental Management Programme (EMPr) can be defined as, “an environmental management tool used to ensure that undue or reasonably avoidable adverse impacts of the construction, operation and decommissioning of a project are prevented; and that the positive benefits of the project are enhanced”.

EMPrs are very important tools in the sound environmental management of projects, provided the specifications are implemented and the user understands the contents of the report and the reasons for the implementation of certain specifications.

The EMPr has the following objectives:

 To state standards and guidelines which are required to be achieved in terms of environmental legislation.  To set out the mitigation measures and environmental specifications which are required to be implemented for all phases of the project in order to minimise the extent of environmental impacts, and to manage environmental impacts and where possible to improve the condition of the environment.  To provide guidance regarding method statements which are required to be implemented to achieve the environmental specifications.  To define corrective actions, this must be taken in the event of non-compliance with the specifications.  To prevent long-term or permanent environmental degradation.

The following principles have been used in the preparation of the EMP:

 Compliance with relevant legislation, standards, codes, and practices in the application of safe technologies;  Minimisation of impacts on the environment and human beings;  Performance of all activities in a safe and effective manner and maintenance of all equipment in good operating condition for the protection of the health and safety of all persons and to conserve the environment and property;  Focus on environment risk prevention;  Focus on occupational and public health, safety; and  The undertaking of all necessary precautions to control, remove, or otherwise correct any leaks and/or spills of hazardous materials, or other health and safety hazards.

There are essentially four broad categories of EMPs: Design EMP, Construction EMP, Operational EMP and Decommissioning EMP. The objectives of these EMPs are all the same and include; identifying the possible environmental impacts of the proposed activity, and developing measures to minimise, mitigate and manage the negative impacts while enhancing the positive ones. The difference between these EMPs is related to the different mitigation measures required for the different stages of the project life cycle.

The proposed low level bridge will not be decommissioned in the foreseeable future, and thus the decommissioning phase for this development is not further discussed. Each remaining category of EMP is discussed in more detail below.

Design EMP

The Design EMP is an integral component of the project life cycle and requires interaction between the design engineers and environmental consultants to ensure that the engineers are aware of the environmental constraints that must be considered and incorporated into the final design of the project.

The format of this design EMP is checklist in nature to ensure that all specifications are included in the design phase. The design EMP phase requires ongoing and in-depth discussions between the final design team and the environmental control officer. The engineer will have to cost for, and be available for, ongoing discussions with the environmental officer at all stages of final design.

The majority of the work is undertaken at a desktop level and thus impacts are negligible and will not be discussed in further detail.

Construction EMP

The Construction EMP details the environmental management system/framework within which construction activities will be governed for the Construction Phase. The Construction EMP consists of various actions, initiatives and systems that the contractor will have to ensure are in place and are undertaken. The Construction EMP consists of both a management system and environmental specifications which contain detailed specifications that will need to be undertaken or adhered to by the contractor.

The Construction EMP will need to be developed in parallel with the Final Design Stages, and constructive input should be invited from the selected contractor. Sound environmental management is orientated around a pragmatic, unambiguous but enforceable set of guidelines and specifications, and for this reason it is imperative that the contractor, while being bound by the EMP, fully understands it and has had input into its final development. For this reason the final construction EMP will need to be signed off after input from the selected contractor prior to the initiation of construction activities. It should, however, be noted that the contractor must tender on the existing document and that in areas of uncertainty, a precautionary approach to the environmental guidelines and specifications must be adopted

Operational and Maintenance EMP

The operational phase EMP provides specific guidance related to operational activities associated with a particular development. Operational EMPs are sometimes referred to as Environmental Management Systems (EMS).

Impacts during the operational phase of a development of this nature will be few in number and low in intensity. By taking pro-active measures during the construction phase, potential environmental impacts emanating during the operational phase will be minimised. Monitoring of certain issues such as the success of vegetation re-establishment and erosion control will be required to continue during operation.

The final Operational EMP should be developed in conjunction with any other relevant stakeholders prior to the adoption thereof.

CONTENTS OF THE ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR)

The contents of the Environmental Management Programme (EMPr), as it is defined the EIA Regulations published as Government Notice (GN) No R. 982 in Government Gazette No 38282 of 4 December 2014 in terms of Chapter 5 of the National Environmental Management Act No 107 of 1998 (NEMA), must be consistent with the below requirements and include –

(1) An EMPr must comply with section 24N of the Act and include-

(a) Details of (i) The EAP who prepared the EMPr; and (ii) The expertise of that EAP to prepare an EMPr, including a curriculum vitae;

(b) A detailed description of the aspects of the activity that are covered by the EMPr as identified by the project description;

(c) A map at an appropriate scale which superimposes the proposed activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that any areas that should be avoided, including buffers;

(d) A description of the impact management objectives, including management statements, identifying the impacts and risks that need to be avoided, managed and mitigated as identified through the environmental impact assessment process for all phases of the development including- (i) Planning and design; (ii) Pre-construction activities; (iii) Construction activities; (iv) Rehabilitation of the environment after construction and where applicable post closure; and (v) Where relevant, operation activities;

(e) A description and identification of impact management outcomes required for the aspects contemplated in paragraph (d);

(f) A description of proposed impact management actions, identifying the manner in which the impact management objectives and outcomes contemplated in paragraphs (d) and (e) will be achieved, and must, where applicable, include actions to - (i) Avoid, modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation; (ii) Comply with any prescribed environmental management standards or practices; (iii) Comply with any applicable provisions of the Act regarding closure, where applicable; and (iv) Comply with any provisions of the Act regarding financial provisions for rehabilitation, where applicable;

(g) The method of monitoring the implementation of the impact management actions contemplated in paragraph (f);

(h) The frequency of monitoring the implementation of the impact management actions contemplated in paragraph (f);

(i) An indication of the persons who will be responsible for the implementation of the impact management actions;

(j) The time periods within which the impact management actions contemplated in paragraph must be implemented;

(k) The mechanism for monitoring compliance with the impact management actions contemplated in paragraph (f);

(l) A program for reporting on compliance, taking into account the requirements as prescribed by the Regulations;

(m) An environmental awareness plan describing the manner in which- (i) The applicant intends to inform his or her employees of any environmental risk

which may result from their work; and (ii) Risks must be dealt with in order to avoid pollution or the degradation of the environment

(n) Any specific information that may be required by the competent authority.

Provided in the Sections that follow is the EMPr for the proposed development, based on the requirements of Regulation 33 of the EIA Regulations (GNR 982) as detailed above.

BASIC ASSESSMENT ISSUES AND MITIGATION MEASURES

The identification and significance of identified project related impacts (before and after mitigation is presented in the Basic Assessment Report (BAR). The BAR identified potential impacts and risks associated with the proposed development and these, contained in this EMPr, presents the preliminary actions, specifications and management commitments that need to be adhered to in order to mitigate or enhance the impacts of significance. These are detailed in the following sections.

DEFINITIONS

For the purposes of this EMP, the following definitions and abbreviations shall apply:

Alien Vegetation: Alien vegetation is defined as undesirable plant growth which shall include, but not be limited to all declared category 1 and 2 listed invader species as set out in the Conservation of Agricultural Resources Act (CARA) regulations. Other vegetation deemed to be alien shall be those plant species that show the potential to occupy in number, any area within the defined construction area and which are declared to be undesirable. This includes plant species identified as Alien and invasive species in the National Environmental Management Biodiversity Act of 2004, Alien and Invasive Species Regulations, 2014.

Cement laden water: Means water containing cement or concrete arising from the Contractor’s activities.

Contaminated water: Means water contaminated by the Contractor's activities such as with hazardous substances, hydrocarbons, paints, solvents and runoff from plant, workshop or personnel wash areas but excludes water containing cement/ concrete or silt.

Construction Camp: Construction camp (site camps) refers to all storage and stockpile sites, site offices, container sites, workshops and testing facilities and other areas required undertaking construction activities.

Environment: Environment means the surroundings within which humans exist and that could be made up of:-  The land, water and atmosphere of the earth;  Micro-organisms, plant and animal life;  Any part or combination of (i) and (ii) and the interrelationships among and between them; and  The physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and well-being.

Environmental Aspect: An environmental aspect is any component of a contractor’s construction activity that is likely to interact with the environment.

Environmental Authorisation (EA) (formerly known as, Record of Decision): A written statement from the relevant environmental authority, with or without conditions, that records its approval of a planned undertaking to construct the low level bridge and the mitigating measures required to prevent or reduce the effects of environmental impacts during the life of a contract.

Environmental Control Officer (ECO): A suitably qualified and experienced person or entity appointed for the construction works, to perform the obligations specified in the EA.

Environmental Site Officer (ESO): An ESO is the site-based designated person responsible for implementing the environmental provisions of the construction contract and is appointed by the service provider that carries-out construction activities.

Environmental Impact: An impact or environmental impact is the change to the environment, whether desirable or undesirable, that will result from the effect of a construction activity. An impact may be the direct or indirect consequence of a construction activity.

Environmental Management Plan/Programme: An environmental management tool used to ensure that undue or reasonably avoidable adverse impacts of the construction, operation and decommissioning of a project are prevented; and that the positive benefits of the projects are enhanced.

Environmental Management System: The internationally accepted and recognized environmental management system (EMS) which enables companies, organizations and operations to systematically manage, prevent and reduce environmental problems and associated costs. In terms of ISO 14001 and EMS is defined as, “that part of the overall management system includes organizational structure, planning activities, responsibilities, procedures, processes and resources for developing, implementing, reviewing and maintaining the environmental policy.”

Environmental Policy: A statement by the organisation of its intentions and principles in relation to its overall environmental performance which provides a framework for action and for the setting of its environmental objectives and targets.

External Auditor: A suitably qualified and experienced independent expert as per the required auditor qualifications (ISO 14012).

His: Means his or her, as applicable.

Independent Environmental Consultant: A suitably qualified and experienced independent environmental consultant (IEC) appointed by the Engineer to perform the obligations specified in the Contract. The IEC shall provide reports to the regulatory authority, the Engineer and any other parties as specified by the regulatory authority.

Interested and Affected Party (I&AP): Refers to an I&AP party contemplated in section 24(4)(d) of the NEMA (1998, Act No. 107) and which, in terms of that section, includes – a) Any person, groups of persons, organisation interested in or affected by an activity, and; b) Any organ of state that may have jurisdiction over any aspect of the activity.

ISO 14001 Environmental Management System (ISO 14001): The internationally accepted and recognised Environmental Management System as reflected in the document SABS ISO 14001: 1996.

Method Statement: Is a written submission by the Contractor to the ECO in response to the EMP or to a request by the ECO, setting out the plant (construction equipment), materials, labour and method the Contractor proposes using to carry out an activity, identified by the relevant specification or the ECO when requesting the Method Statement. The Method Statement shall be in such detail that the ECO is able to assess whether the Contractor's proposal is in accordance with the EMP and/or will produce results in accordance with the EMP.

Mitigate: The implementation of practical measures to reduce the adverse impacts, or to enhance beneficial impacts of a particular action.

No-Go Area: Areas where construction activities are prohibited.

Pollution: According to the NEMA (Act No. 107 of 1998), pollution can be defined as, “Any change in the environment caused by (i) substances; (ii) radioactive or other waves; or (iii) noise, odours, dust or heat emitted from any activity, including the storage or treatment of waste or substances, construction and the provision of services, whether engaged in by any person or an organ of state, where that change has an adverse effect on human health or well-being or on the composition, resilience and productivity of natural or managed ecosystems, or on materials useful to people, or will have such an effect in the future”.

Potentially hazardous substance: Is a substance, which, in the reasonable opinion of the ECO, can have a deleterious effect on the environment. Hazardous Chemical Substances are defined in the Regulations for Hazardous Chemical Substances published in terms of the Occupational Health and Safety Act.

Reasonable: Means, unless the context indicates otherwise, reasonable in the opinion of the ECO, after he has consulted with ESO.

Rehabilitation: To re-establish or restore to a healthy, sustainable capacity or state.

Silt laden water: Means water containing sand and silt arising from the Contractor’s activities and/or as a result of natural run-off.

Site: The area in which construction is taking place.

Solid waste: Means all solid waste, including construction debris, chemical waste, excess cement/concrete, wrapping materials, timber, tins, cans, drums, wire, nails, food and domestic waste (e.g. plastic packets and wrappers).

Species of Special Concern: Those species listed in the rare, indeterminate, or monitoring categories of the South African Red Data Books, and/or species listed in globally near threatened, nationally threatened or nationally near threatened categories (Barnes, 1998).

Threatened species: Threatened species are defined as: a) species listed in the endangered or vulnerable categories in the revised South African Red Data Books or listed in the globally threatened category; b) species of special conservation concern (i.e. taxa described since the relevant South African Red Data Books, or whose conservation status has been highlighted subsequent to 1984); c) species which are included in other international lists; or d) species included in Appendix 1 or 2 of the Convention of International Trade in Endangered Species (CITES).

Topsoil: The top 100 mm of soil and may include top material e.g. vegetation and leaf litter.

BACKGROUND INFORMATION

Provided below is a brief description of the proposed Kariega Low Level Bridge Project.

The District Roads Engineer (DRE) proposes to reconstruct the Kariega River Low-Level Bridge on the gravel road en-route to Southwell just north of Kenton-on-Sea (Divisional Road, DR1950) (refer to Figure 1 included below). This was necessitated by the collapse of the original bridge in 2011 due to a high rainfall and subsequent flooding event. As a result, traffic has been forced to cross through the river. This poses a safety risk to all road users. The continuous traversing through the river is also causing damage to the river banks and the river bed. The proposed bridge will be approximately 35 meters in length and 5 meters wide. The scope of the engineering works includes the reconstruction of the low- level bridge with larger culverts to increase flow under the bridge, but will however still be designed to be flooded during extreme events.

The proposed crossing will comprise seven portal box culverts, each 2.4 metres wide by 1.8 metres high, laid parallel to the direction of flow in the river as it approaches the site of the crossing (see Appendix C). Each culvert will comprise six 1.2 metres-long precast concrete units, Class 75S to SANS 986 (Rectangular Box Culverts). The culverts will be founded on a cast-in situ reinforced concrete slab 200mm thick. The slab will be laid on the river bed after suitable levelling and grading and, where necessary, filling soft spots with dental concrete. The base slab will be extended about 3.5m upstream of the entrance to the culverts to provide smooth flow conditions at the culvert entrances, and about the same distance at the downstream ends to prevent erosion by exiting flow. Four cut-off walls approximately 600mm deep will be constructed beneath the slab at the upstream and downstream ends of the slab and at two places between to prevent water flowing under the slab and eroding the river bed beneath the structure.

Figure 1: Location of the proposed crossing, the insert shows the extent of the damage on the existing bridge.

The culverts will be laid about 2m apart, and the space between them filled with cement stabilised backfill material, with the upstream and downstream ends being sealed with a reinforced concrete wall. Reinforced concrete wing walls will be constructed at each side of the crossing to protect the river banks from erosion. The road slab will be a reinforced concrete slab approximately 200mm thick. The bed and banks of the river upstream and downstream of the crossing will be reinforced with Reno mattresses and stone-filled gabions respectively up to a certain level, above which the river banks side and the slopes of the road embankment and will be reinforced with grouted stone pitching. The crossing will have to be constructed in two cofferdams, since the river flows continuously except in drought conditions.

A water use authorisation in terms of Section 21 (c) and (i) of the National Water Act (Act 36 of 1998) was initially anticipated, however it has been determined that the exact location of the low- level crossing is within the upper reaches of the estuary and is thus the mandate of the Department of Oceans and Coasts. Discussions with the Department of Water and Sanitation and Oceans and Coasts have confirmed this. A formal letter indicating such has been requested and will be included in the Final Basic Assessment Report.

Figure 2: Proposed site plan

THE ENVIRONMENTAL POLICY

The contractor is required to compile an Environmental Management Policy, which must consider the following:

 The contractor’s mission, vision and core values;  Guiding principles;  Requirements of, and communication with I&APs;  The environmental specifications and intentions of the specifications must be upheld;  The need to work towards continual improvement;  The obligation to prevent pollution and ecological degradation;  The importance of coordination with other organisational policies (e.g. quality, occupational health and safety, etc.);  Site activities will be conducted in a manner that does not create a nuisance, risk or hazard to the natural environment;  Reference to specific local and/or regional conditions;  Employee and public health and safety must be considered a priority;  A commitment to compliance with relevant environmental laws, regulations, by-laws and other criteria to which the contractor subscribes.

The contractor (contractor is defined as principal contractor, sub-contractors and any employees retained on this project) is required to be familiar with the environmental policy (to be developed by the applicant) and all that it implies, and to adopt and implement the policy throughout the course of construction. The policy must be communicated to all employees and contractors (and sub- contractors) of the contractor, and made available to the public, if requested.

ENVIRONMENTAL OBJECTIVES AND TARGETS

In order to meet the commitments detailed within the Environmental Management Policy, as well as those included within the environmental specifications of this EMPr, the contractor shall develop environmental objectives and targets. The objectives and targets must conform to, and comply with, the following criteria:

 The objectives and targets shall constitute the overall goals for environmental performance identified in the environmental policy and strategy;  When establishing objectives and targets, the contractor shall take into account the identified environmental aspects and associated environmental impacts, as well as the relevant findings from environmental reviews and/audits;  The targets must be set to achieve objectives within a specified timeframe;  Targets should be specific and measurable;  When the objectives and targets are set, the contractor must establish measurable Key Performance Indicators (KPIs). The latter will be used by the contractor as the basis for an Environmental Performance Evaluation System, and can provide information on both the environmental management and the operational systems. Objectives and targets need to apply broadly across the contractor’s operations, as well as to site-specific and individual activities; and  Objectives and targets must be reviewed from time to time in view of changed operational circumstances and/or changes in environmental legal requirements, and need to take into consideration the views of the I&APs.

All objectives and targets must be supplied to the IEC or ECO for review and used during audits, as prescribed in the conditions of the EA.

ENVIRONMENTAL LEGISLATION AND GUIDELINES

The Contractor must ensure that all South African legislation concerning the natural environment, pollution and the built environment is strictly enforced. Such legislation must include, but is not limited to the:

 The Constitution of the Republic of South Africa Act No. 108 of 1996.  National Environmental Management Act No. 107 of 1998 as amended.  National Heritage Resources Act, No 25 of 1999.  National Environmental Management: Biodiversity Act 10 of 2004  National Environmental Management: Waste Management Act 59 of 2008  National Water Act, No 36 of 1998  National Forest Act, No 84 of 1998  Health Act 63 of 1977  Occupational Health and Safety Act 85 of 1993  Hazardous Substances Act No. 15 of 1973.

DETAILS OF EAP

EAP: Kim Brent Company: Coastal and Environmental Services, trading as EOH Coastal & Environmental Services (CES) Port Elizabeth Branch Physical Address: 13 Stanley Street, Port Elizabeth 6000 Postal Address: 13 Stanley Street, Port Elizabeth 6000 Telephone: +27 41 585 1715 Fax: 086 604 8781 Website: www.cesnet.co.za Email: [email protected]

EOH Coastal & Environmental Services (CES), established in 1990, is a specialist environmental consulting company with one of their offices based in Port Elizabeth (Eastern Cape Province). We believe that a balance between development and environmental protection can be achieved by skilful, considerate and careful planning. CES has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, and state of environment reporting (SOER), Integrated Waste Management Plans (IWMP), Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) processes. CES has been active in all of the above fields, and in so doing have made a positive contribution to towards environmental management and sustainable development in the South Africa and many other African countries.

ADMINISTRATION AND REGULATION OF ENVIRONMENTAL OBLIGATIONS

MANAGEMENT STRUCTURE

In line with this EMPr, the contractor must prepare a document clearly outlining and demonstrating the environmental responsibilities, accountability and liability of the contractor’s employees. The contractor must assign responsibilities for the following:

 Reporting structures;  Actions to be taken to ensure compliance;  Overall design, development and implementation of the EMPr;  Documenting the environmental policy and strategy;  Implementing the EMPr in all stages/phases of the project; and

 All the aspects which require action under the other core elements and sub-elements of the EMPr.

All official communication and reporting lines including instructions, directives and information need to be channelled according to the organisation structure.

ROLES AND RESPONSIBILITIES

Applicant/Developer

The applicant is the responsible entity for monitoring the implementation of the EMPr and compliance with the authorisation. However, if the company appoints a contractor to implement the project and hence implement the proposed mitigation measures documented in this EMPr on their behalf, then the successful contractor’s responsibilities are outlined as per the section that follows.

Contractor

The successful contractor shall:

 Be responsible for the finalisation of the EMPr in terms of methodologies which are required to be implemented to achieve the environmental specifications contained herein and the relevant requirements contained in the EA;  Be responsible for the overall implementation of the EMPr in accordance with the requirements of the developer and the EA;  Ensure that all third parties who carry out all or part of the contractor’s obligations under the contract comply with the requirements of this EMPr;  Ensure that the appointments of the ECO are subject to the approval of the developer.

Environmental Control Officer

For the purposes of implementing the conditions contained herein, the contractor shall appoint an ECO for the contract. The ECO shall be the responsible person for ensuring that the provisions of the EMPr as well as the environmental authorisation are complied with during the construction period. The ECO will be responsible for issuing instructions to the contractor and where environmental considerations call for action to be taken. The ECO shall submit regular written reports to the applicant and the environmental authority (DEDEAT) as required.

The ECO will be responsible for the monitoring, reviewing and verifying of compliance with the EMPr and conditions of the environmental authorisation by the contractor. The ECO’s duties in this regard will include, inter alia, the following:

 Confirming that all the environmental authorisations and permits required in terms of the applicable legislation have been obtained prior to construction commencing;  Monitoring and verifying that the EMPr, EA and contract are adhered to at all times and taking action if specifications are not followed;  Monitoring and verifying that environmental impacts are kept to a minimum;  Reviewing and approving construction method statements with input from the ESO and engineer, where necessary, in order to ensure that the environmental specifications contained within this EMPr and EA are adhered to;  Inspecting the site and surrounding areas on a regular basis regarding compliance with the EMPr, EA and contract;  Monitoring the undertaking by the contractor of environmental awareness training for all new personnel on site;  Ensuring that activities on site comply with all relevant environmental legislation;  Ordering the removal of, or issuing spot fines for person/s and/or equipment not complying with the specifications of the EMPr and/or environmental authorisation;

 Undertaking a continual internal review of the EMPr and submitting any changes for applicant and authority review and approval as applicable;  Checking the register of complaints kept on site and maintained by the ESO and ensuring that the correct actions are/were taken in response to these complaints;  Checking that the required actions are/were undertaken to mitigate the impacts resulting from non-compliance;  Reporting all incidences of non-compliance;  Conducting annual environmental performance audits in respect of the activities undertaken relating to the project. The ECO shall also submit compliance audit reports to DEDEAT, in accordance with the requirements of the environmental authorisation. Such reports shall be reviewed by the applicant, prior to submission;  Keeping a photographic record of progress on site from an environmental perspective. This can be conducted in conjunction with the ESO as the ESO will be the person that will be onsite at all times and can therefore take photographic records weekly. The ECO would need to check and ensure that the ESO understands the task at hand;  Recommending additional environmental protection measures, should this be necessary; and  Providing report back on any environmental issues at site meetings.

The ECO must have:

 A good working knowledge of all relevant environmental policies, legislation, guidelines and standards;  The ability to conduct inspections and audits and to produce thorough, readable and informative reports;  The ability to manage public communication and complaints;  The ability to think holistically about the structure, functioning and performance of environmental systems; and  Proven competence in the application of the following integrated environmental management tools:  Environmental impact assessment;  Environmental management plans/programmes;  Environmental auditing;  Mitigation and optimisation of impacts;  Monitoring and evaluation of impacts; and  Environmental management systems.

The ECO must be fully conversant with the Basic Assessment process and BAR, this EMPr, EA and all relevant environmental legislation for the project. The applicant shall have the authority to replace the ECO if, in their opinion, the appointed officer is not fulfilling his/her duties in terms of the requirements of the EMPr or this specification. Such instruction will be in writing and shall clearly set out the reasons why a replacement is required and within what timeframe.

Environmental Site Officer

The contractor shall appoint a nominated representative of the contractor as the ESO for the contract. The ESO will be site-based and shall be the responsible person for implementing the environmental provisions of the construction contract. There shall be an approved ESO on the site at all times. It may be necessary to have more than one ESO. The ESO’s duties will include, inter alia, the following:

 Ensuring that all the EAs and permits required in terms of the applicable legislation have been obtained prior to construction commencing;  Reviewing and approving construction method statements with input from the ECO and engineer, where necessary, in order to ensure that the environmental specifications contained within the construction contract are adhered to;

 Assisting the contractor in finding environmentally responsible solutions to problems;  Keeping accurate and detailed records of all activities on site;  Keeping a register of complaints on site and recording community comments and issues, and the actions taken in response to these complaints;  Ensuring that the required actions are undertaken to mitigate the impacts resulting from non-compliance; and  Reporting all incidences of non-compliance to the ECO and contractor.

The ESO shall submit regular written reports to the ECO, but not less frequently than once a month. The ESO must have:

 The ability to manage public communication and complaints;  The ability to think holistically about the structure, functioning and performance of environmental systems; and  The ESO must be fully conversant with the BAR and EMPr for the proposed low level bridge construction and all relevant environmental legislation; and lastly  The ESO must have received professional training, including training in the skills necessary to be able to amicably and diplomatically deal with the public as outlined in bullet point one above.

The ECO shall be in the position to determine whether or not the ESO has adequately demonstrated his/her capabilities to carry-out the tasks at hand and in a professional manner. The ECO shall therefore have the authority to instruct the contractor to replace the ESO if, in the ECO’s opinion, the appointed officer is not fulfilling his/her duties in terms of the requirements of the construction contract. Such instruction will be in writing and shall clearly set out the reasons why a replacement is required and within what timeframe.

The ECO shall visit the development site and in addition to the responsibilities listed in this section, review the performance of the ESO and submit regular performance reviews to the applicant/developer.

COMPLIANCE MONITORING AND CORRECTIVE ACTION

Non-compliance with the conditions of the EMPr must be viewed as a breach of appointment contract for which the construction contractors will be held liable. The latter is deemed NOT to have complied with the EMPr if:

 There is evidence of contravention of the EMPr, its environmental specifications or the Method Statements developed by the contractor within the boundaries of the construction site or areas of contractor responsibility;  Construction related activities take place outside the defined boundaries of the site;  Environmental damage ensues due to negligence;  The contractor fails to comply with corrective or other instructions issued by the ECO within a specific time; or  The contractor fails to respond adequately to complaints from the public or authorities.

The proponent and the construction contractors are liable for any construction rehabilitation costs associated with their non-compliance with the EMPr. This rehabilitation will be undertaken to the satisfaction of the ECO.

The construction contractors shall have the right to appeal any punitive action undertaken by the ECO or applicant/developer.

REPORTING AND REVIEW

The EMPr reporting and documentation requirements must be based on best practice principles, e.g. ISO 14001 that must take the following requirements into account:

 Documents associated with the EMPr must be regularly reviewed and updated by all environmental management parties.  Audits of the environmental performance of the construction phase of the project will be undertaken on a quarterly basis by accredited auditors in fulfilment of likely conditions of environmental authorisation in this regard.  The findings of external, internal and informal environmental reviews will be recorded and items requiring action will be identified from the recommendations made.  The construction contractors will be contractually obliged to fulfil any reasonable recommendations, and implementation of these actions will be assessed in the above audit.

Weekly and monthly reporting meetings will take place on site. Internal auditing and reporting will be subject to external review by the ECO during the quarterly compliance audits.

MONITORING

Construction activities have the potential to impact on a range of biophysical habitats as well as neighbouring communities. The monitoring programme that requires development by the applicant, ECO and contractor should inter alia allow for analysis of:

1. Air Quality e.g. dust. 2. Hydrocarbon pollution. 3. Success of local labour employment. 4. Success of local procurement policies. 5. Ambient and workplace noise. 6. Health and safety incidents. 7. Success of traffic management measures. 8. Riverine habitat monitoring.

EMERGENCY PREPAREDNESS

The contractor shall develop environmental emergency response procedures to ensure that there will be an appropriate response to unexpected or accidental actions or incidents that will cause environmental impacts during the construction period. Such activities may include, inter alia:

 Accidental discharges to water and land.  Accidental exposure of employees to hazardous substances.  Accidental fires.  Accidental spillage of hazardous substances.  Specific environmental and ecosystem effects from accidental releases or incidents.

The contractor and sub-contractors shall comply with the emergency preparedness incident reporting requirements that must be developed prior to construction.

ENVIRONMENTAL INCIDENT MANAGEMENT

The construction contractors will adhere to the hazard and incident reporting protocols to be developed by the contractor. A report must be completed for all incidents, and appropriate action taken where necessary to minimise any potential impacts. DEDEAT must be informed of any environmental incident, in accordance with legislative requirements, should this be necessitated by a major environmental incident.

MANAGEMENT REVIEW

A formal management review needs to be conducted on a regular basis in which the internal audit reports written by the ESO based on frequent inspections and interactions with the ECO and review of the periodic reports, including audit reports by the independent external auditor - will be reviewed. The purpose of the review is to critically examine the effectiveness of the EMPr and its implementation and to decide on potential modifications to the EMPr as and when necessary. The process of management review is in keeping with the principle of continual improvement.

Management review will take place when the liaison committee consisting of representatives from the contractor, construction sub-contractors as appropriate, ECO and other parties or I&APs as deemed necessary on a monthly basis. The purpose of these monthly meetings will be to review the progress of the contractor in implementing and complying with its obligations in terms of this EMPr for the duration of the project. Where necessary, management review will take place more frequently than the required monthly meetings.

RECOMMENDATIONS FOR ENVIRONMENTAL MANAGEMENT

METHOD STATEMENTS

Annexure F.1 provides a pro forma method statement sheet that must be completed by the Contractor for each activity requiring a method statement as specified in the EMP or as requested by the ECO. A method statement is “a sequence of steps taken to complete a series of construction or project related activities in a safe manner that reduces the overall risk to people and the environment”.

This can be for a once off task, or a series of tasks that are often repeated. The method statement should be written by a person that is competent in the tasks to be undertaken and how these can be effectively communicated. An understanding of how relevant environmental specifications dictate the manner in which these tasks can be implemented is also required.

When a method statement is prepared, the risks are identified during the various work stages. Steps taken to reduce the potential risk associated with these stages are then determined. The sequential steps and actions to be followed by the persons carrying out the works are written down. This sequence of steps should include all environmental and safety aspects relevant to the task being executed. The contractor shall not commence an activity until all required method statements have been approved by the ECO and applicant. Such approval should not unreasonably be withheld.

All control measures detailed in the method statement must be the subject of "tool box" talks prior to the initiation of works. By introducing or reaffirming these measures during the "tool box" talk, everyone involved will have a clear understanding of the work to be carried out, as well as the safe work method sequences and equipment required. The method statement shall cover:

 Construction procedures.  Materials and equipment to be used.  Getting the equipment to and from site.  How the equipment/material will be moved while on site.  How and where material will be stored.  The containment (or action to be taken if containment is not possible) of leaks or spills of any liquid or material that may occur.  Timing and location of activities.  Compliance/non-compliance with the specifications or control measures.  Any other information deemed necessary by the ECO.

Approved method statements shall be readily available on the site and the location thereof communicated to all relevant personnel. The contractor shall carry out the works in accordance with the approved method statements as they apply to the work in progress. Approval of the method statement shall not absolve the contractor from any of his obligations or responsibilities in terms of general legal contracts entered into by any party.

Contractor Method Statements for Construction Activities

The contractor should produce the following method statements as a minimum:

1. Site Dust Management 2. Solid Waste Management 3. Hazardous Material Management 4. Hydrocarbon Management 5. Surface Water Management 6. Site Clearing and Topsoil Management 7. Fire Management 8. Noise and Vibration Management 9. Concrete Mixing 10. Pollution Control 11. Site Access and Traffic Management 12. Incident and Emergency Response Management

Additional method statements will be developed (or revised) if the need therefore is identified during the construction phase of the project.

CONSTRUCTION PHASE

Site access and demarcation

The location, layout and method of establishment of the construction camp including the following must be clearly indicated and demarcated prior to construction activity commencing:

 All Contractor’s buildings, and/or offices  Lay down areas  Vehicle wash areas (if any)  Workshops and drip trays  Fuel storage areas (including filling and dispensing from storage tanks)  Cement/concrete mixing areas (including the methods employed for the mixing of concrete and particularly the containment of runoff water from such areas and the method of transportation of concrete)  Other infrastructure required for the running of the project

Details, including a drawing, showing where and how the access points and routes will be located and managed must be submitted to the ECO and developer that are supported by the following management requirements:

 On the site and within such distance of the site as may be stated, the contractor shall control the movement of all vehicles and plant including that of his suppliers so that they remain on designated routes, are distributed so as not to cause an undue concentration of traffic and that all relevant laws are complied with. In addition, such vehicles and plant shall be so routed and operated as to minimise disruption to regular users of the routes not on the Site.  On gravel or earth roads on site and within 500m of the site, the vehicles of the contractor and his suppliers shall not exceed a speed of 45 km/h or as directed by the ECO.  The Contractor shall supply the ECO with a Method Statement detailing the location and management of all access points and roads.

The Contractor shall erect and maintain permanent and / or temporary fences of the type and in the locations directed by the ECO. Such fences shall, if so specified, be erected before undertaking designated activities.

Certain areas within or next to the Site shall be "no go" areas. The Contractor shall ensure that, insofar as he has the authority, no person, machinery, equipment or materials enter the “no go" areas at any time.

Materials handling, use and storage

 The Contractor shall ensure that any delivery drivers are informed of all procedures and restrictions (including identified "no go" areas) required to comply with the EMPr.  The Contractor shall ensure that these delivery drivers are supervised during off loading, by someone with an adequate understanding of the requirements of the EMPr.  Materials shall be appropriately secured to ensure safe passage between destinations. Loads including, but not limited to sand, stone chip, fine vegetation, refuse, paper and cement, shall have appropriate cover to prevent them spilling from the vehicle during transit.  The Contractor shall be responsible for any clean-up resulting from the failure by his employees or suppliers to properly secure transported materials.  All manufactured and/ or imported material shall be stored within the Contractor's camp, and, if so required by the EMPr, out of the rain.  All lay down areas outside of the construction camp shall be subject to the ECO's approval.  Imported gravel, fill, soil and sand materials shall be free of weeds, alien invasive seed matter, plant material, litter and contaminants and shall be obtained from sources approved by the ECO.

Stockpiling

 Any stockpiling of gravel, cut, fill or any other material including spoil shall be in areas approved by the ECO within the defined working area.  The Contractor shall ensure that the material does not blow or wash away. If the stockpiled material is in danger of being washed or blown away, the Contractor shall spray it with Dustex or cover it with a suitable material, such as hessian or plastic. Stockpiles of topsoil shall not be covered with plastic.  No stockpiling of any material shall be allowed within 20 m of any “no go” area.

Solid waste management

 No on-site burning, burying or dumping of any waste materials, litter or refuse shall occur.  The Contractor shall provide vermin and weatherproof bins with lids of sufficient number and capacity to store the solid waste produced on a daily basis. The lids shall be kept firmly on the bins at all times.  Bins shall not be allowed to become overfull and shall be emptied at least once a day.  The waste from bins may be temporarily stored on Site in a central waste area that is weatherproof and scavenger-proof, and which the ECO has approved.  Recyclable waste shall be disposed of into separate skips/bins and removed off-site for recycling.  All solid waste shall be disposed of off-site at approved registered landfill site. The Contractor shall supply the ECO with the appropriate disposal certificates.  The Contractor shall submit a solid waste management plan as part of the Pollution Control Method Statement to the ECO.

Water use

 All sources of water for construction purposes must be approved by the ECO in writing before any such sources can be used to obtain water.  Where possible all wash water will be recycled for use, as wash water again or for dust suppression where applicable.

Contaminated water

 Potential pollutants of any kind and in any form shall be kept, stored, and used in such a manner that any escape can be contained and that the water table and surface water is not endangered. Water containing such pollutants as chemicals, washing detergents, sewerage, fuels, paints and solvents and hydrocarbons shall be contained and discharged into an impermeable storage facility for removal from the site or for recycling. This particularly applies to runoff from fuel depots/workshops/truck washing areas.  Wash down areas shall be placed and constructed in such a manner so as to ensure that the surrounding areas are not polluted. The Contractor shall notify the ECO immediately of any pollution incidents on Site.  As part of the Pollution Control Method Statement, the Contractor shall submit a plan to the ECO detailing how the contaminated water will be managed on site.

Hazardous substances

 The transportation and handling of hazardous substances must comply with the provisions of the Hazardous Substances Act (Act No.187 of 1993) and associated regulations as well as SABS 0228 and SABS 0229.  The Contractor shall also comply with all other applicable regional and local legislation and regulations with regard to the transport, use and disposal of hazardous substances. Hazardous chemical substances (as defined in the Regulations for Hazardous Chemical Substances) used during construction shall be stored in secondary containers. The relevant Material Safety Data Sheets (MSDS) shall be available on site. Procedures detailed in the MSDSs shall be followed in the event of an emergency situation.  The Contractor shall be responsible for the training and education of all personnel on site who will be handling hazardous materials about their proper use, handling and disposal.  If potentially hazardous substances are to be stored or used on site, the Contractor shall submit a Method Statement to the ECO detailing the substances / materials to be used, together with the transport, storage, handling and disposal procedures for the substances.

Cement and mixing of concrete

 The proposed location of cement mixing areas (including the location of cement stores and sand and aggregate stockpiles) shall be indicated on the site layout plan and approved by the ECO. All mixing areas shall not be located within 50 m of the Kariega River or within 20 m of any “no go” areas, unless written approval has been granted by the ECO.  All wastewater generated from the operation and cleaning of concrete mixing equipment and other sources of concrete shall be passed through a concrete wastewater settlement system. The water from this system shall not be allowed to flow into any “no go” area or water course but must permeate through the ground before it reaches any such water course. The accumulated sludge in the settlement system must be regularly cleaned out and appropriately disposed of as solid waste.  The Contractor shall ensure that minimal water is used for washing of concrete and cement mixing equipment.  Used cement bags shall be disposed of in weatherproof bins on site to prevent the generation of wind-blown cement dust and the bags from blowing away.

 During construction, the contractor must ensure that concrete is mixed on mortar boards, all visible remains of concrete are removed and disposed of as waste and that all surplus aggregate is removed.  As part of the Pollution Control and Concrete Mixing Method Statement, a plan detailing all actions to be taken to comply with the requirements shall be submitted to the ECO.

Fuel (petrol and diesel) and oil

Fuel Storage

 All construction materials including fuels and oil should be stored in demarcated areas that are contained within berms / bunds to avoid spread of any contamination into nearby rivers or drainage lines. Washing and cleaning of equipment should also be done in berms or bunds, in order to trap any cement and prevent excessive soil erosion. These sites must be re-vegetated after construction has been completed. Mechanical plant and bowsers must not be refuelled or serviced within or directly adjacent to any drainage line or waterbody.  The location of the fuel storage area will be approved by the ECO and will be situated at least 50 m away from the Kariega River and/or 20 m away from any “no go” areas. All necessary approvals with respect to fuel storage and dispensing shall be obtained from the appropriate authorities. Symbolic safety signs depicting “No Smoking”, “No Naked Lights” and “Danger” conforming to the requirement of SABS 1186 shall be prominently displayed in and around the fuel storage area. There shall be adequate fire-fighting equipment at the fuel storage area.  The Contractor shall ensure that all liquid fuels and oils are stored in tanks with lids, which are kept firmly shut and under lock and key at all times. The capacity of the tank shall be clearly displayed and the product contained within the tank clearly identified using the emergency information system detailed in SABS 0232 part 1. Fuel storage tanks shall have a capacity not exceeding 9 000 litres and shall be kept on site only for as long as fuel is needed for construction activities, on completion of which they shall be removed.  Tanks on site shall not be linked or joined via any pipe work, but shall remain as separate entities. The tanks shall be situated on a smooth impermeable base with a bund. The volume inside the bund shall be 110% of the total capacity of the largest storage tank. The base may be constructed of concrete, or of plastic sheeting with impermeable joints with a layer of sand over to prevent perishing. The impermeable lining shall extend to the crest of the bund. The floor of the bund shall be sloped to enable any spilled fuel and/or fuel-contaminated water to be removed. Appropriate material, approved by the ECO that absorbs / breaks-down or encapsulates minor hydrocarbon spillage and which is effective in water shall be installed in the sump.  The tanks and bunded areas shall be covered by a roofed structure, taken off site to a disposal site approved by the ECO, and the material that absorbs / breaks-down or encapsulates minor hydrocarbon spillage shall be replenished.  Only empty and externally clean tanks may be stored on the bare ground. Empty and externally dirty tanks shall be sealed and stored on an area where the ground has been protected.  Adequate precautions shall be provided to prevent spillage during the filling of any tank and during the dispensing of the contents. The dispensing mechanism for the fuel storage tanks shall be stored in a waterproof container when not in use.  As part of the required site layout for the construction camp, a plan shall be submitted to the ECO detailing the design, location and construction of the fuel storage area as well as for the filling and dispensing from storage tanks and for the type of absorbing / breaking-down or encapsulating material to be used.

Refuelling

 Where reasonably practical, the plant shall be refuelled at a designated re-fuelling area/depot or at a workshop as applicable. If this is not reasonably practical then the surface under the refuelling area shall be protected and appropriately bunded against pollution to the reasonable satisfaction of the ECO prior to any refuelling activities.

 If fuel is dispensed from 200 litre drums, the proper dispensing equipment shall be used, and the drum shall not be tipped in order to dispense fuel. The Contractor shall ensure that the appropriate fire-fighting equipment is present during refuelling operations.  The Contractor shall ensure that there is always a supply of absorbent material readily available to absorb/breakdown or where possible, be designed to encapsulate minor hydrocarbon spillages. The quantities of such materials shall be able to handle a minimum of 200 ℓ of hydrocarbon liquid spill. Prior to any refuelling or maintenance activities, the ECO must approve this material.

Used oil and hydrocarbon contaminated materials

 Used oil shall be stored at a central location on site prior to removal off site for disposal at an approved disposal or recycling site.  Old oil filters and oil, petrol and diesel-soaked material shall be treated as hazardous waste. The Contractor shall remove all oil, petrol, and diesel-soaked sand immediately and shall dispose of it as hazardous waste or treat it on site with material that breaks-down or encapsulates such spillages as approved by the ECO.

Workshop, equipment maintenance and storage

 Where practical, all maintenance of equipment and vehicles on site shall be performed in a workshop. If it is necessary to do maintenance outside of the workshop area, the Contractor shall obtain the approval of the ECO prior to commencing such activities. No maintenance, including emergency maintenance, of plant can take place within 20 m of any “no go” area or 50 m from the Kariega River.  The Contractor shall ensure that in his workshop and other plant maintenance facilities, including those areas where, after obtaining the ECO's approval, the Contractor carries out emergency plant maintenance, there is no contamination of the soil or vegetation. The workshop shall have a smooth impermeable (concrete or thick plastic covered with sand) floor.  The floor shall be bunded and sloped towards an oil trap or sump to contain any spillages. When servicing equipment, drip trays shall be used to collect the waste oil and other lubricants. Drip trays shall also be provided in construction areas for stationary plant (such as compressors) and for "parked" plant (such as scrapers, loaders, vehicles).  All vehicles and equipment shall be kept in good working order and serviced regularly. Leaking equipment shall be repaired immediately or removed from the site.  The washing of equipment shall be restricted to urgent or preventative maintenance requirements only. All washing shall be undertaken in the workshop or maintenance areas, and these areas must be equipped with a suitable impermeable floor and sump/oil trap. The use of detergents for washing shall be restricted to low phosphate and nitrate containing and low sudsing-type detergents.  As part of the site layouts, a plan must be submitted to the ECO detailing the design of the bunding of the workshop and how run-off from the workshop will be managed as well as how drip trays used under plant will be managed.

Ablution facilities

 Washing, whether of the person or of personal effects, and acts of excretion and urination are strictly prohibited other than at the facilities provided. The Contractor shall provide the necessary ablution facilities for all his personnel prior to the commencement of work and shall ensure that his personnel make use of the facilities.  Toilet facilities shall be supplied by the Contractor for the workers at a ratio of at least 1 toilet per 20 workers in areas approved by the ECO. Every 1-man urinal will be taken as supplying the equivalent of 5 men in addition to the 20 men per toilet on site. No toilets will be erected within within 20 m of any “no go” areas or 50 m of the Kariega River. Toilets shall be situated within 200m of any area where work is taking place in numbers sufficient to meet the ratio

depicted above for the workers in the area. Mobile toilets (e.g. trailer mounted) should be considered for sites, where workers may be expected to cover large distances every day.  The facilities shall be maintained in a hygienic state and serviced regularly. Toilet paper shall be provided. Temporary / portable toilets shall be secured to the ground to prevent them toppling due to wind or any other cause, to the satisfaction of the ECO.  Discharge into the environment and burial of waste is strictly prohibited. The Contractor shall ensure that no spillage occurs when the toilets are cleaned or emptied and that the contents are removed from the site. Toilets shall be emptied before the Contractors’ holidays or any other temporary site closure.

Eating areas

 The Contractor shall designate eating area(s), subject to the approval of the ECO. No cooking is allowed outside of the Contractor’s camp area on site.  At meal times all workers must eat in designated eating areas. These areas shall have shade for the workers. The eating areas may be in existing structures or in temporary / transportable structures that shall be well constructed using wood or metal for the frame and screened on the top and sides with shade cloth/canvas or other material to the satisfaction of the ECO. These areas shall be well demarcated and in locations approved by the ECO and shall not be within 20 m of any “no go” areas or 50 m of the Kariega River, on or adjacent to the site.  Sufficient bins shall be present in these areas. All disposable food packaging must be disposed of in the bins after every meal.  The area must be cleaned after every meal.  The feeding or leaving of food for animals is strictly prohibited.

Site structures

 All site establishment components (as well as equipment) shall be positioned to limit visual intrusion on neighbours and the size of the land area disturbed. The type and colour of roofing and cladding materials to the Contractor's temporary structures shall be selected to reduce reflection.  The Contractor shall supply and maintain adequate and suitable sheds for the storage of materials. Sheds for the storage of materials that may deteriorate or corrode if exposed to the weather shall be weatherproof, adequately ventilated and provided with raised floors.

Lights

 The Contractor shall ensure that any lighting installed on the site for his activities does not cause a reasonably avoidable disturbance to the naturally-occurring fauna.

Noise

 The Contractor shall take precautions to minimise noise generated on site (e.g. install and maintain silencers on machinery).  The Contractor shall comply with the Noise Induced Hearing Loss Regulations published under the Occupational Health and Safety Act.  Appropriate directional and intensity settings are to be maintained on all hooters and sirens.  No amplified music shall be allowed on site. The Contractor shall not use sound amplification equipment on Site unless in emergency situations.

Dust Control

 The Contractor shall be responsible for the continued control of dust arising from his operations. The Contractor shall take all reasonable measures to minimize the generation of dust as a result of construction activities to the satisfaction of the ECO. Appropriate dust suppression measures include: spraying or dampening with water, using a commercial dust

binder (such as Hydropam or Dustex), rotovating straw bales, planting of open cleared space and the scheduling of dust-generating activities. If the conditions are such that the Contractor cannot satisfactorily dampen the dust, then the ECO may halt operations until such time as the conditions are more suitable for lower dust generating construction.  Damping of all gravel haul and access roads (if constructed) with water must be ongoing and special attention must be given to roads close to residential areas. Should dust still be a problem on any specific road, the allowable speed will be reduced to 20km/h. If dust is still a problem the road should be treated with a commercial dust binder, as required, to form a cohesive layer that will control the dust on the road.  Areas that are to have the topsoil stripped for construction purposes must be limited and only stripped when work is about to take place.  Other activities and situations that may result in a dust nuisance include: site clearance and other earth moving operations, open cleared space, stockpiles of topsoil or sand and activities associated with concrete mixing.

Environmental awareness training

 Environmental awareness training courses shall be run for all personnel on site (See Annexure F.2 for a proposed Basic Environmental Education Course). Two types of courses shall be run, one for the Contractor's and Subcontractor's management and one for all site staff and labourers. Courses shall be run in the morning during normal working hours at a suitable venue provided by the Contractor. All attendees shall remain for the duration of the course and sign an attendance register on completion that clearly indicates participant’s names, a copy of which shall be handed to the ECO.  The size of each session shall be limited to 30 people. The Contractor shall allow for sufficient sessions to train all personnel. Subsequent sessions shall be run for any new personnel coming onto site. A Method Statement with respect to the organisation of these courses shall be submitted.  Notwithstanding the specific provisions of this clause it is incumbent upon the Contractor to convey the sentiments of the EMPr to all personnel and Subcontractors involved with the Works.

Training course for management and foremen

 The environmental awareness training course for management shall include all management staff and foremen. The course, which will be presented by the ECO, will be of approximately one-hour duration.  The initial course shall be undertaken not less than 7 days prior to commencement of work on site. Subsequent courses shall be held as and when required.

Training course for site staff and labour

 The environmental awareness training course for site staff and labour shall be presented by the Contractor’s SHE Officer from material provided by the ECO unless otherwise required by the Project Specification. The course will be approximately one-hour long.  The course shall be run not more than 7 days after commencement of work on site with sufficient sessions to accommodate all available personnel. Subsequent courses shall be held as and when required.

Construction personnel information posters

 The Contractor shall erect and maintain information posters for the information of his employees depicting actions to be taken to ensure compliance with the Environmental EMP. Construction personnel information posters shall be laminated and erected in all eating areas, workshops and site offices. The Contractor shall ensure that the construction personnel

information posters are not damaged in any way, and shall replace them if any part becomes illegible.  Examples of these posters will be supplied to the Contractor by the ECO in electronic format.

Fire control

 The Contractor shall take all the necessary precautions to ensure that fires are not started as a result of his activities on site.  No open fires shall be permitted on the site.  Smoking shall not be permitted in those areas where there is a fire hazard. Such areas shall include the workshop and fuel storage areas and any areas where the vegetation or other material is such as to support the rapid spreading of an initial flame.  The Contractor shall appoint a Fire Officer who shall be responsible for ensuring immediate and appropriate actions in the event of a fire and shall ensure that employees are aware of the procedures to be followed. The Contractor shall forward the name of the Fire Officer to the ECO for his approval within 7 days of being on site.  The Contractor shall ensure that there is basic fire-fighting equipment available on site at all times. This shall include at least rubber beaters when working in urban open spaces and natural areas, and at least one fire extinguisher of the appropriate type when welding or other “hot” activities are undertaken.  The Contractor shall be liable for any expenses incurred by any organisations called to assist with fighting fires that were started as a result of his activities or personnel, and for any cost relating to the rehabilitation of burnt areas, or consequential damages.

Emergency procedures

 Emergency procedures, including the names and contact details of responsible personnel and emergency services shall be made available to all staff and shall be clearly displayed at relevant locations at the site. The Contractor shall advise the ECO of any emergencies on Site, together with a record of action taken, within 24 hours of the emergency occurring.  Telephone numbers of emergency services shall also be posted conspicuously in the Contractor’s office near the telephone.  The Contractor shall submit a Method Statement covering the procedures for the following emergencies:

Fire

 The Contractor shall advise the relevant authority of a fire as soon as one starts and shall not wait until he can no longer control it.  The Contractor shall ensure that his employees are aware of the procedures to be followed in the event of a fire.

Accidental leaks and spillages

 The Contractor shall ensure that his employees are aware of the procedures to be followed for dealing with spills and leaks, which shall include notifying the ECO and the relevant authorities. The Contractor shall ensure that all the necessary materials and equipment for dealing with spills and leaks are available on site at all times. Treatment and remediation of the spill areas shall be undertaken to the reasonable satisfaction of the ECO.  In the event of a hydrocarbon spill, the source of the spillage shall be isolated and the spillage contained. The area shall be cordoned off and secured. The Contractor shall ensure that there is always a supply of absorbent material readily available to absorb/ breakdown or where possible, be designed to encapsulate minor hydrocarbon spillages. The quantities of such materials shall be able to handle a minimum of 200 ℓ of hydrocarbon liquid spill.  Any spills must be cleared and the contaminated soil/sludge disposed of in an appropriate manner, approved by the ECO, or at a licensed hazardous waste disposal site.

Protection of natural features

 The Contractor shall not deface, paint, damage or mark any natural features (e.g. rock formations or trees) situated in or around the site for survey or other purposes unless agreed beforehand with the ECO. Any features affected by the Contractor in contravention of this clause shall be restored / rehabilitated to the satisfaction of the ECO.  The Contractor shall not permit his employees to make use of any natural water sources (e.g. the Kariega River) for the purposes of swimming, personal washing and the washing of machinery or clothes.

Protection of flora and fauna

 A plant search and rescue to identify species of special concern should be conducted prior to commencing of construction.  Protected plant species should be removed from the designated construction footprint and relocated to adjacent areas of similar habitat that will not be affected by construction and used in landscaping once construction is complete.  Except to the extent necessary for the carrying out of the works, flora shall not be removed, damaged or disturbed nor shall any vegetation be planted.  The removal and stockpiling of topsoil must also be carried out in accordance with the EMP.  Trapping, poisoning and/or shooting of animals is strictly forbidden. No domestic pets or livestock are permitted on site.  The use of chemicals of all forms should be carefully controlled and monitored to avoid contamination of areas, particularly the Kariega River.  Construction phases should allow for education of staff as to the significance of species of concern.

Protection of heritage features

 Construction managers/foremen must be informed before construction starts on the possible types of heritage sites and cultural material they may encounter and the procedures to follow when they find sites.  If concentrations of palaeontological/archaeological heritage material and human remains are uncovered during construction, all work must cease immediately and be reported to the Albany Museum (046 622 2312) and/or the South African Heritage Resources Agency (SAHRA) (021 642 4502) so that systematic and professional investigation/ excavation can be undertaken.  Any person who causes intentional damage to archaeological or historical sites and/or artefacts could be penalised or legally prosecuted in terms of the National Heritage Resources Act 25 of 1999.

Vegetation Clearance

 Vegetation clearing should occur in parallel with the construction progress to minimise erosion and/or run-off. Large tracts of bare soil will either cause dust pollution or quickly erode and then cause sedimentation in the Kariega River.  The Contractor must work according to a plan, which demarcates areas to be cleared. The plan should be part of the Project Layout Plan developed in the Site Design Phase.  The minimum amount of vegetation clearance must take place.  All plants not interfering with construction should be left undisturbed.  Collection or wilful damage to any plants outside of the areas demarcated for clearing is not allowed.  The Contractor shall destroy all tagged alien vegetation within the designated area.

 The Contractor will take care of seeds collected during the removal of alien vegetation in order to counter the spread of this vegetation type. Failure to do so may result in prosecution in terms of the Conservation of Agricultural Resources Act, Act 43 of 1983, which states that any person removing any weed (which includes alien vegetation) shall ensure that it is not able to reproduce itself. A fine not exceeding R5 000 and/or 2 years imprisonment can be imposed.  No breaking of branches, outside of the demarcated areas will be allowed without prior approval from the ECO.

Alien Vegetation Clearance

 The construction phase should employ eradication programmes to remove existing invasives as well as the removal of any new invasives, especially those categorized as 1, 2 and 3 on the NEMBA list.  Long-term operational eradication programs to eradicate invasives should be implemented if possible.

Revegetation

 All areas disturbed during construction shall be reinstated to a state that approximates or betters the state that they were in before construction.  Cut and fill areas must be restored and reshaped.  Areas compacted by vehicles during construction must be scarified to allow penetration of plant roots and the regrowth of natural vegetation.  The revegetation programme must take cognisance of the climatic and seasonal conditions with the most favourable period being in spring and early summer.  The rehabilitated areas will be weeded by the nominated rehabilitation contractor for a period of 1 year.  Plant lists with species indigenous and or endemic to the region should be proposed in place of exotics and encouraged.  The transplanting of indigenous species within the study area should be done.  It is also advised that an Environmental Control Officer, with a good understanding of the local flora be appointed during the construction phase. The ECO should be able to make clear recommendations with regards to the re-vegetation of the newly completed / disturbed areas, using species selected by an appropriate botanist. All alien plant re-growth must be monitored and should it occur these plants should be eradicated.

Topsoil

 Topsoil can only be stripped from the areas as indicated below: o Any area which is to be used for temporary storage of materials o Areas which could be polluted by any aspect of the construction activity and; o Areas designated for the dumping of soil.  Stripping of topsoil will be undertaken in such a manner as to minimise erosion by wind or runoff.  Outside of the development footprint, topsoil will be stripped to a depth not exceeding 150mm from the original ground level.  Areas from which the topsoil is to be removed will be cleared of any foreign material which may come to form part of the topsoil during removal including bricks, rubble, any waste material, litter, excess vegetation and any other material which could reduce the quality of the topsoil.  The Contractor shall ensure that subsoil and topsoil are not mixed during stripping, excavation, reinstatement and rehabilitation. If mixed with clay sub-soil the usefulness of the topsoil for rehabilitation of the site will be lost.  Soils should be exposed for the minimum time possible once cleared.  Topsoil will be temporarily stockpiled, separately from (clay) subsoil and rocky materials.  Topsoil will be stockpiled in areas designated by the ECO.  Soil must not be stockpiled near the Kariega River without prior consent from the ECO.

 Stockpiles will either be vegetated with indigenous grasses or covered by a suitable fabric to prevent erosion and invasion of weeds.  Stockpiled topsoil will not be compacted.

Stormwater management

 Stormwater should be managed using suitable structures such as swales, gabions and rock rip-wrap so that any run-off from the development site is attenuated prior to discharge. Silt and sedimentation should be kept to a minimum, through the use of the above mentioned structures by also ensuring that all structures don’t create any form of erosion.  Natural run-off must be diverted to stormwater drains where these are available. The Contractor shall take appropriate measures to prevent sand, silt and silt-laden waters from entering the Kariega River.

Erosion and sedimentation control

 The Contractor shall take all reasonable measures to limit erosion and sedimentation due to construction activities and shall, in addition, comply with such detailed measures as may be required by the EMP.  Revegetate areas that have been disturbed as soon as possible.  Cut and fill slopes must be made stable and be revegetated as soon as possible during the construction phase.  Newly formed terraces within the facility must be vegetated in order to stabilise the soil.  Where erosion and/or sedimentation, whether on or off the site, occurs despite the Contractor complying with the foregoing, rectification shall be carried out in accordance with details specified by the ECO. Where erosion and/or sedimentation occur due to the fault of the Contractor, rectification shall be carried out to the reasonable requirements of the ECO and at the expense of the Contractor.

Aesthetics

 The Contractor shall take reasonable measures to ensure that construction activities do not have an unreasonable impact on the aesthetics of the area.

Community relations

 If so required by the Project Specification, the Contractor shall erect and maintain information boards in the positions, quantities, designs and dimensions specified. Such boards shall include contact details for complaints by members of the public in accordance with details provided by the ECO.  The Contractor shall keep a "Complaints Register" on site. The Register shall contain all contact details of the person who made the complaint, and information regarding the complaint itself and note the date and time that the complaint was resolved.  The ECO shall be responsible for responding to queries and/or complaints and may request assistance from the Contractor’s Management Staff.

Temporary site closure

If the Site is closed for a period exceeding 5 days, the Contractor’s SHE Officer in consultation with the ECO shall carry out the following checklist procedure and ensure that the following conditions pertain and report on compliance with this clause:

Fuels / flammables / hazardous materials stores

 Fuel stores are as low in volume as practicable.  There are no leaks.

 The outlet is secure and locked.  The bund is empty.  Fire extinguishers are serviced and accessible.  The area is secure from accidental damage through vehicle collision and the like.  Emergency and contact numbers are available and displayed.  There is adequate ventilation in enclosed spaces.

Safety

 Site safety checks have been carried out in accordance with the Occupational Health and Safety Act (No. 85 of 1993) prior to site closure.  An inspection schedule and log for use by security or contracts staff is developed.  All trenches and manholes are secured.  Applicable notice boards are in place and secured.  Emergency and Management contact details are prominently displayed.  Security personnel have been briefed and have the facilities to contact or be contacted by relevant management and emergency personnel.  Night hazards such as reflectors, lighting, traffic signage etc. have been checked.  Fire hazards identified and the local authority notified of any potential threats e.g. large brush stockpiles, fuels etc.  Pipe stockpiles are wedged / secured.  Scaffolds are secure.  Structures vulnerable to high winds are secure.

Erosion

 Wind and dust mitigation measures such as straw, brush packs, irrigation etc. is in place.  Excavated and filled slopes and stockpiles are at a stable angle and capable of accommodating normal expected water flows.  Re-vegetated areas have a watering schedule and the supply to such areas is secured.  There are sufficient detention ponds or channels in place.

Water contamination and pollution

 Hazardous fuel stores are secure.  Cement and materials stores are secure.  Toilets are empty and secured.  Refuse bins are empty and secured.  Bunding is clean and treated with appropriate material that will absorb/ breakdown and where possible be designed to encapsulate minor hydrocarbon spillage.  Drip trays are empty & secure.

OPERATIONAL AND MAINTENANCE PHASE

Regular inspection of the low level bridge as well as the connecting road by the relevant authority (District Roads Engineer) must take place to monitor its up keep. In addition to the regular inspection of the low level bridge and connecting road regular maintenance must be undertaken to ensure its upkeep (at least once a year).

CONCLUSION

Although all foreseeable actions and potential mitigations or management actions are contained in this document, the EMPr should be seen as a day-to-day management document. The EMPr thus sets out the environmental standards that are required to minimise the negative impacts and maximise the positive benefits of the proposed low level bridge as detailed in the BAR. The EMPr

is a “live document”, and if continuously reviewed and managed correctly can result in successful construction and operation of the proposed development.

All attempts should be made to have this EMPr available, as part of any tender documentation, so that the contractors are made aware of the potential cost and timing implications needed to fulfil the implementation of the EMPr, thus adequately costing for these.

Further guidance should also be taken on any conditions contained in the Environmental Authorisation, if the project is granted approval, and that these conditions must be incorporated into the final EMPr.

ANNEXURE F1: METHOD STATEMENTS

Method statements need to be compiled by the Contractor for approval by the ECO. For the purposes of the environmental specification, a method statement is defined as a written submission by the Contractor to the ECO setting out the plant, materials, labour and method the Contractor proposes using to carry out an activity, in such detail that the ECO is enabled to assess whether the Contractor’s proposal is in accordance with the EMP and / or will produce results in accordance with EMP.

The method statement shall cover applicable details with regard to:

 Construction procedures,  Materials and equipment to be used,  Getting the equipment to and from site,  How the equipment/ material will be moved while on site,  How and where material will be stored,  The containment (or action to be taken if containment is not possible) of leaks or spills of any liquid or material that may occur,  Timing and location of activities,  Compliance/ non-compliance with the Specifications, and  Any other information deemed necessary by the Engineer.

The Contractor shall abide by these approved method statements, and any activity covered by a method statement shall not commence until the ECO has approved the method statement. The method statement shall be submitted to the ECO not less than 20 days prior to the intended date of commencement of the activity, or as directed by the ECO.

METHOD STATEMENT

CONTRACT:…………………………………………………….... DATE:………………….

PROPOSED ACTIVITY (give title of method statement and reference number from the EMP):

WHAT WORK IS TO BE UNDERTAKEN (give a brief description of the works):

WHERE ARE THE WORKS TO BE UNDERTAKEN (where possible, provide an annotated plan and a full description of the extent of the works):

Start Date: End Date:

START AND END DATE OF THE WORKS FOR WHICH THE METHOD STATEMENT IS REQUIRED:

HOW ARE THE WORKS TO BE UNDERTAKEN (provide as much detail as possible, including annotated sketches and plans where possible):

* Note: please attach extra pages if more space is required

DECLARATIONS

1) ENVIRONMENTAL CONTROL OFFICER The work described in this Method Statement, if carried out according to the methodology described, is satisfactorily mitigated to prevent avoidable environmental harm:

______(Signed) (Print name)

Dated:.______

2) PERSON UNDERTAKING THE WORKS I understand the contents of this Method Statement and the scope of the works required of me. I further understand that this Method Statement may be amended on application to other signatories and that the ECO will audit my compliance with the contents of this Method Statement

______(Signed) (Print name)

Dated: ______

ANNEXURE F.2: BASIC ENVIRONMENTAL EDUCATION COURSE OUTLINE

Air Soil Water Plants Animals People Buildings, cars and houses

http://www.webweaver.nu/clipart/environmental.shtml

APPENDIX G: OTHER INFORMATION

TERRESTRIAL ECOLOGICAL INPUT

Due to the fact that the majority of the construction phase and the entire operational phase will be within the aquatic environment, no terrestrial ecological assessment was completed. However, included below is a short description of the current status of the vegetation based on input from spatial development tools and site visits.

Mucina and Rutherford

Mucina and Rutherford (2006) have developed the National Vegetation map as part of a South African National Biodiversity Institute (SANBI) funded project: “It was compiled in order to provide floristically based vegetation units of South Africa, Lesotho and Swaziland at a greater level of detail than had been available before.” The map was developed using a wealth of data from several contributors and has allowed for the best national vegetation map to date, the last being that of Acocks developed over 50 years ago. This map forms the base of finer scale bioregional plans such as STEP and SKEP.

The map and accompanying book describe each vegetation type in detail, along with the most important species including endemic species and those that are biogeographically important. This is the most comprehensive data for vegetation types in South Africa.

Mucina and Rutherford (2006) define the following vegetation type (Figure 1) from which source these descriptions are derived:

Figure 1: Vegetation Classification according to Mucina and Rutherford

Figure 2: Conservation Status according to Mucina and Rutherford

Kowie Thicket

Kowie Thicket occurs mainly on steep and north-facing (dry) slopes. Tall thickets are dominated by succulent euphorbias and aloes with a thick understorey composed of thorny shrubs, woody lianas (Capparis, Secamone, Rhoicissus and Aloe), and shrubby succulents (Crassulaceae and Asphodelaceae). Moister south-facing slopes support thorny thickets dominated by low evergreen trees (Cussonia, Euclea, Hippobromus, Pappea, Ptaeroxylon and Schotia) and shrubs (Azima, Carissa, Gymnosporia and Putterlickia) with fewer succulent shrubs and trees. The herbaceous layer is poorly developed. Distribution of Kowie Thicket within the Eastern Cape Province is limited to the river valleys of the Bushmans, Kariega, Kowie, Kleinemonde and Kap Rivers from near the Mouth to Kenton-on-Sea, extending inland up these valleys past Grahamstown to just past Riebeeck East and Alicedale to north of the Zuurberg. The conservation status of this vegetation type is classified as ‘Least Threatened’ and the protection status as ‘Poorly Protected’. The conservation target (percent of area) as set by the NSBA is 19%. At present only 5% of this vegetation unit is statutorily protected in various reserves, including the Water’s Meeting, Kowie, Cycad, Blaauwkrantz and the Kap River Nature Reserves. A further 14% is conserved in private conservation areas such as game ranches (Shamwari, Emlanjeni, Amakhala, Fourie Safaris, Hunters Lodge, Elephant Park and Schotia Safaris) and in the Aylesbury Nature Reserve. Approximately 7% of Kowie Thicket has been transformed by cultivation.

STEP

STEP (2006) define the following vegetation types (Figure 3) from which source these descriptions are derived:

Figure 3: Vegetation Classification according to STEP

Figure 4: Conservation Status according to STEP

Albany Thicket Albany Thicket, which in places is very forest-like, is dominated by spike thorn (Gymnosporia buxifolia), wild olive (Olea africana subsp. africana), bosboerboon (Schotia latifolia) and false current (Allophylus decipiens). The tree euphorbia, Euphorbia triangularis, is typically present, as is the turkey-berry tree (Canthium inerme). Albany Thicket is classified as ‘Least Threatened’.

Albany Valley Thicket Within the Albany Valley Thicket vegetation unit dominant trees are doppruim (Pappea capensis) and gwarrie (Euclea undulata) with characteristic species are the succulents, Aloe africana and Kalanchoe rotundifolia. This vegetation type is easily recognised by the abundance of tall Euphorbia tetragona plants that emerge above the canopy. Albany Valley Thicket is classified as ‘Vulnerable’, but much of it has been destroyed by overgrazing and now exists as savanna-like vegetation with isolated trees in a matrix of opslag (fast-growing weeds that appear after rain).

Figure 5: Transformed areas according to STEP

ECBCP

Figure 6: Terrestrial CBA’s according to the ECBCP

Figure 7: Aquatic CBA’s according to the ECBCP

Site specific vegetation

East of the bridge

33°36’32.16”S, 26°39’16.54”E

Cross-section point Description Dominant species East thicket Very steep slope. Euphorbia triandra, Olea europaea subsp. Dominated by climax woody and succulent africana, Cussonia spicata, Schotia latifolia, thicket trees (± 8 meters from bridge to Sideroxylon inerme, Ptaeroxylon obliquum, intact thicket) Senecio angularis, Aloe africana East ecotone Disturbance zone between the intact thicket Searsia refracta, Azima tetracantha, and the grass ecotone, roughly 3 m in width Ptaeroxylon obliquum, Plumbago auriculata, Rhoicissus digitata, Euclea undulate, Grewia occidentalis, Gymnosporia spp., Scutia myrtina

Middle of bridge 33°36’32.02” S, 26°39’15.86” E

Cross-section point Description Dominant species Road/ causeway Weedy species along the road Galenia pubescecns, Chenopodium album, Panicum colaratum, Cynodon incompletus,

West of the bridge 33°36’31.79” S, 26°39’14.64” E

Cross-section point Description Dominant species West grassy ecotone Disturbed riparian area dominated by Pentameris disticha Kikuyu grass West thicket Thin thicket band running between the river Acacia karroo, Opuntia ficus-indica, Searsia and the above plains. refracta, Scutia myrtina, Eragrostis curvula, Veprisundulata, Gymnosporia spp, Tecomaria capensis, Plumbago auriculata

Proposed site camp location 33°36’32.71” S, 26°39’13.40” E

Cross-section point Description Dominant species West plains above Old lands, degraded, no intact thicket Pelargonium alchemilloides, Sporobolus river present africana, Solanum sp, Oxalis spp, Indigofera spp.