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PROPOSED DEVELOPMENT OF A NEW SCHOOL AND ASSOCIATED INFRASTRUCTURE ON ERF 4742 AND ERF 4743 NOORDHOEK, SOUTH PENINSULA, CITY OF CAPE TOWN

SPECIALIST FRESHWATER ASSESSMENT

Prepared for: Propgen (Pty) Ltd

Prepared by: Natasha van de Haar SACNASP Reg. no. 400229/11

Date: March 2017

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Executive Summary

KHULA Environmental Consultants (hereafter “KHULA”) has been appointed by Propgen (Pty) Ltd to undertake a specialist assessment of the impact of the development of a new school and associated infrastructure on Erf 4742 and Erf 4743, Noordhoek (the proposed site) on the site’s freshwater features. The specialist assessment is required as part of the required Basic Assessment process in terms of the NEMA EIA Regulations, 2014.

Summary of background Information:

The proposed site falls within the quaternary catchment G22A and within the Berg Water Management Area (WMA) and Greater Cape Town sub-Water Management Area (sub-WMA) as defined by the National Freshwater Ecosystem Priority Areas project (NFEPA, 2011). According to Mucina and Rutherford (2006, updated 2012), the proposed site is located within the Hangklip Sand Fynbos vegetation type. Hangklip Sand Fynbos is listed as endangered by the National List of Threatened Terrestrial Ecosystems (2011). Wetlands associated with the proposed site fall within the Southwest Sand Fynbos wetland vegetation group (NFEPA, 2011), listed as critically endangered within the region.

No wetland features are indicated within 500m of the proposed site by NFEPA. However, the City of Cape Town’s wetland layer (2015) indicates three features within the proposed site of which two are considered to be natural. These two wetlands were chosen as Other Ecological Support Areas (OESAs). OESAs are lower ranking artificial wetlands and the lowest ranking natural or semi-natural wetlands. The objectives for these features are to maintain natural ecosystems, restore degraded land to natural and to manage for no further degradation.

Summary of freshwater assessment results:

Historically a large portion of the proposed site could have consisted of well-defined wetland habitat prior to disturbance. This assumption was supported by the presence of hydromorphic soil1 encountered at most areas throughout the proposed site where hand augering was conducted. However, the proposed site has been used as grazing pastures for decades. Infilling, tilling as well as possible irrigation has resulted in the transformation of the indigenous vegetation assemblage as well as the natural hydrological regime, to the extent that the larger portion of the proposed site can be described as severely degraded wetland habitat. Semi-degraded habitat is associated with three wetland seeps, the central channel and a dam where more diverse indigenous vegetation communities were identified. There is no pristine wetland habitat on the application site.

Table A: Coverage of semi-degraded wetland habitat and severely degraded wetland habitat as determined during the infield delineation. Area Size Proposed site 25 511m2 Semi-degraded wetland habitat 3 900m2 Severely degraded wetland habitat 21 611m2

WET-Health2 is defined as a measure of the similarity of a wetland to a natural or reference condition and the assessment was undertaken in line with the findings of the field survey which suggest that the proposed site formed part of a larger wetland system historically. As a result, the proposed site was assessed as one wetland system, with the dam and the central channel contributing to impact incurred as a result of anthropogenic activity in the past. The overall wetland health3 score calculated for the wetland falls within a Present Ecological State (PES) Category E (The change in ecosystem processes and loss of natural habitat and biota is great but some remaining natural habitat features are still recognisable). Considering the extent to which the wetland habitat is already transformed, it would most likely remain in its current PES Category for the next 5 years, should development not take place.

1 A soil that, in its undrained condition, is saturated or flooded long enough to develop anaerobic conditions favouring the growth and regeneration of hydrophytic vegetation. 2 Macfarlane et al., 2007 WRC Report No TT 340/09 3 (hydrology score) x 3 + (geomorphology score) x 2 + (vegetation score) x 2 / 7 = overall wetland health

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The WET-Ecoservices tool was applied to severely degraded wetland habitat and semi-degraded wetland habitat4, separately. The assessment was repeated for wetland habitat after construction of the Applicants Preferred Alternative (assuming successful implementation of the rehabilitation and management plan); in order to determine the potential loss or gain of Ecosystem Services should the development proceed. The Residential Alternative was also assessed, however due to isolation of the dam and central channel these features were assessed separately. Wetland habitat associated with the proposed site, regardless of degree of transformation, can be considered the most important in terms of assimilation of nitrate, phosphate and toxicants as well as erosion control (all falling within a moderate to high class). None of the results indicate a significant decrease of any Ecosystem Services after development of the Applicants Preferred Alternative. However, six Ecosystem Services showed a potential to increase. Indicating an opportunity to increase Ecosystem Services with environmentally sensitive design and rehabilitation. All rates calculated for Ecoservices as part of the Residential Alternative decreased.

The method that was used to determine the Ecological Importance and Sensitivity (EIS) of the different areas as described for the Ecosystem Services assessment above, is based on the assessment tool developed by Rountree et. al. (2014). The EIS score calculated for the semi-degraded wetland habitat (seeps, dam and central channel) fall within a High Category, and for the remaining degraded wetland habitat, within a Low Category. It should be noted that PES determines the similarity of a wetland to its natural or reference condition and EIS is used to determine its present importance and sensitivity regardless of transformation.

Impact assessment:

Two development alternatives have been proposed, namely the Applicants Preferred Alternative and the Residential Alternative. Both alternatives are briefly summarised below.

Applicants Preferred Alternative: • Development of a school. • Rehabilitation of semi-degraded wetland habitat e.g. wetland habitat falling within a High EIS Category. • Incorporation of a wetland corridor along the eastern boundary of the proposed site.

Residential Alternative: • 6 residential developments with associated infrastructure. • Conservation of the dam and the central channel, all other wetland habitat infilled. • Landscaping in between residences and infrastructure.

Potential direct impacts expected to occur as a result of the construction and operation of both development alternatives as well as potential impacts associated with the ‘no go’ alternative are summarised in the tables below.

Table B: Impact assessment results for the ‘No Go’ Scenario.

Probability Significance Status Confidence Highly probable Medium -ve High

Table C: Impact assessment results for the construction phase for the Applicants Preferred Alternative.

Loss of wetland habitat Probability Significance Status Confidence Without mitigation Definite Medium -ve High With mitigation No mitigation possible

Sedimentation of retained wetland habitat due to rehabilitation activities and replacement of soil within adjacent construction areas Probability Significance Status Confidence Without mitigation Definite High -ve High With mitigation Definite Very Low -ve Medium

4 4 Considering all characteristics of the dam, seep wetlands and central channel as presented in Figure 10.

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Transformation of the present hydrological regime of retained wetland habitat Probability Significance Status Confidence Without mitigation Definite Medium -ve High With mitigation Definite Low -ve Medium

Disturbance of the retained wetland habitat and the eastern wetland corridor as result of rehabilitation Probability Significance Status Confidence Without mitigation Definite High -ve High With mitigation Definite Very Low -ve Medium

Table D: Impact assessment results for the operational phase for the Applicants Preferred Alternative

Increased stormwater runoff into retained wetland habitat from hard surfaces Probability Significance Status Confidence Without mitigation Probable Medium -ve High With mitigation Improbable Very Low -ve Medium

Increase in wetland biodiversity and function Probability Significance Status Confidence Without mitigation Probable Low +ve Medium With mitigation Highly probable Medium +ve High

Table E: Impact assessment results for the construction phase for the Residential Alternative.

Loss of wetland habitat Probability Significance Status Confidence Without mitigation Definite High -ve High

Sedimentation of the dam and central channel Probability Significance Status Confidence Without mitigation Definite Medium -ve High With mitigation Probable Very Low -ve Medium

Table F: Impact assessment results for the operational phase for the Residential Alternative.

Increased stormwater runoff Probability Significance Status Confidence Without mitigation Definite Medium -ve High With mitigation Probable Low -ve Medium

Increase in wetland biodiversity and function Probability Significance Status Confidence Without mitigation Definite Very Low +ve Medium With mitigation Highly probable Low +ve Medium

Conclusion and recommendation:

Indicators of hydromorphic5 soil were identified throughout the proposed site. In addition, varying abundances of floral species adapted to continuous moist soil conditions were also identified throughout the proposed site. Hydromorphic soil that sustains a hydrophytic community is considered to be the key indicator used to identify wetland habitat as defined by the National Water Act (NWA). Therefore, in its present condition, the entire proposed site can be considered a watercourse and any development within the proposed site will require Environmental Authorisation in terms of the National Environmental Management Act (NEMA) Environmental Impact Assessment Regulations (2014) as well as authorisation from the Department of Water and Sanitation (DWS) in terms of Section 21 (c) and (i) of the NWA.

5 A soil that, in its undrained condition, is saturated or flooded long enough to develop anaerobic conditions favouring the growth and regeneration of hydrophytic vegetation (vegetation adapted to living in anaerobic soils).

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Currently the larger portion of the proposed site is dominated by alien grasses (21 611m2), with only four isolated areas encountered where indigenous floral species diversity increases (3 900m2). Therefore, wetland habitat within the proposed site can be considered severely degraded and would remain in this degraded state should development not proceed. There is also the potential of the site being used for livestock grazing if not developed, which could result in additional impact on semi-degraded wetland habitat.

Two development alternatives have been proposed, namely the Residential Alternative and the Applicants Preferred Alternative which is to develop a school on the site. The loss of wetland habitat as a result of the extensive infilling associated with the Residential Alternative, was rated to be of high (negative) impact significance and no mitigation measure would decrease the significance of the impact. The layout and design of the proposed school as per the Applicants Preferred Alternative has accommodated both the mitigation measures recommended in this report as well as those of the faunal specialist and as such it is the opinion of the specialist that wetland biodiversity and function6 can be increased with the development of this alternative to the extent that, despite the reduction in wetland area, a net gain in wetland function and wetland service provision is achieved. It is therefore the opinion of the specialist that authorisation for the development of the Applicants Preferred Alternative, from a freshwater ecological perspective may be granted, provided that all essential mitigation measures listed within this report as well as the faunal specialist report are strictly adhered too.

6 Note that faunal impact with special mention of Amietophrynus pantherinus (Western leopard toad) has been considered within the faunal impact assessment report.

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Table of Contents Executive Summary ...... 1 List of Figures ...... 6 List of Tables ...... 7 Disclaimer...... 7 Glossary ...... 7 Acronyms ...... 9 1. Introduction ...... 10 1.1. Background ...... 10 1.2. Limitations and Assumptions ...... 11 1.3. Legislation ...... 11 1.3.1. National Water Act (Act no.36 of 1998) ...... 11 1.3.2. General Notice 509 of the NWA (2016) ...... 12 1.3.3. National Environmental Management Act (Act no. 107 of 1998) ...... 12 1.3.4. Floodplain and River Corridor Management Policy ...... 12 2. Method of Assessment ...... 13 2.1. Desktop Assessment ...... 13 2.2. Watercourse Identification and Delineation ...... 13 2.3. Freshwater Feature Classification ...... 14 2.4. Wetland EcoServices and Function Assessment ...... 14 2.5. Present Ecological State - Wet-Health ...... 15 2.6. Ecological Importance and Sensitivity ...... 15 2.7. Recommended Ecological Category ...... 15 2.8. Buffer Determination ...... 15 2.9. Impact Assessment ...... 15 3. Results ...... 16 3.1. Overview of Background Information ...... 16 3.2. Site Description ...... 19 3.3. Freshwater Feature Classification ...... 22 3.4. Watercourse Delineation ...... 22 3.5. Present Ecological State – WET-Health ...... 24 3.6. Wetland EcoServices and Function Assessment ...... 25 3.7. Ecological Importance and Sensitivity (EIS) ...... 27 3.8. Recommended Ecological Category ...... 29 3.9. Buffer Determination ...... 29 4. Activity Description ...... 30 4.1. Applicant’s Preferred Alternative ...... 30

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4.2. Residential Alternative ...... 32 5. Assessment of Impacts ...... 33 5.1. Impact Identification ...... 33 5.1.1. Applicant’s Preferred Alternative ...... 34 5.1.2. Residential Alternative ...... 39 5.2. ‘No Go’ Scenario ...... 42 5.3. Indirect Impacts ...... 42 5.4. Cumulative Impacts ...... 43 6. Conclusion and Recommendation ...... 43 7. References ...... 44 Appendix 1 – Impact Assessment Criteria ...... 46

List of Figures

Figure 1: Proposed site, presented with green, in relation to its surroundings (Google Earth, 2016)...... 10 Figure 2: 1: 50 000 Topo-Cadastral map, dated 2010; indicating the location of the proposed site...... 10 Figure 3: Classification System for wetlands and other aquatic ecosystems in South Africa...... 14 Figure 4: Historical image dated 1973...... 16 Figure 5: Wetlands with conservational importance as indicated by the City of Cape Town wetlands layer (2015)...... 17 Figure 6: Wetlands indicated by the City of Cape Town wetlands layer (2015). Area where the drainage line has been impounded is indicated with a red circle...... 17 Figure 7: Topo-Cadastral map dated 1942; presenting the drainage line along the eastern boundary of the proposed site...... 18 Figure 8: Topo-Cadastral map dated 1962; following the redirecting of the drainage line through the centre of the proposed site...... 18 Figure 9: Encroachment by Pennisetum clandestinum throughout the proposed site (left) with depressional areas dominated by Stenotaphrum secundatum (right; vegetation with slightly more red appearance)...... 19 Figure 10: Delineation of wetland areas with relatively abundant indigenous vegetation within the proposed site. The remainder of the proposed site is considered to be severely degraded wetland habitat...... 20 Figure 11: Central channel...... 21 Figure 12: North eastern seep (left) and north western seep (right)...... 21 Figure 13: Dam...... 21 Figure 14: Areas where the soil profile was investigated with the use of a handheld auger, indicated by orange markers...... 23 Figure 15: Photographs representative of the soil within seasonal / permanent wetland zones of the seeps. Note high organic matter content and lower chroma...... 23 Figure 16: Photographs representative of the soil encountered within the remainder of the proposed site with distinct mottling observed indicative of temporary wetland zones...... 23 Figure 17: WET-EcoServices results: Light Green – wetland areas with relatively abundant vegetation; Orange – severely degraded wetland habitat; Light Blue – Post development (Applicants Preferred Alternative); Dark Blue – Post Development (Residential Alternative – central channel); Dark Green – Post Development (Residential Alternative – dam)...... 27 Figure 18: Brookwood Stream situated adjacent to the southern tip of the proposed development...... 30 Figure 19: Designated No Go wetland habitat...... 31 Figure 20: Applicant’s Preferred Alternative ...... 31

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Figure 21: Residential Alternative...... 32

List of Tables

Table 1: WET-Health results table...... 24 Table 2: PES Categories used by WET-Health for describing the integrity of wetlands (after Macfarlane et al., 2007)...... 25 Table 3: Classes for determining the likely extent to which a benefit is being supplied based on the overall score for that benefit (after Kotze et al., 2007)...... 26 Table 4: WET-EcoServices results table. Ecosystem Services that showed an increase following development are highlighted with green. Noteworthy differences between wetland areas with relatively abundant indigenous vegetation and severely degraded wetland habitat are highlighted with blue...... 26 Table 5: EIS results...... 28 Table 6: EIS Categories...... 29 Table 7: Impact assessment results for the construction phase...... 37 Table 8: Impact assessment results for operational phase...... 39 Table 9: Impact assessment results for the construction phase...... 40 Table 10: Impact assessment results for operational phase...... 42 Table 11: Impact assessment results for the ‘No Go’ Scenario...... 42 Table 12: Criteria used to determine the consequence of the impact...... 46 Table 13: Method used to determine the consequence score...... 47 Table 14: Probability classification...... 47 Table 15: Impact significance rating...... 47 Table 16: Impact status and confidence classification...... 48

Disclaimer

KHULA Environmental Consultants (hereafter “KHULA”) has exercised all due care in the reviewing of all available information and the identification of wetland habitat. The accuracy of the results and conclusions from the assessment are entirely reliant on the accuracy and completeness of available desktop information, site conditions at the time of the assessment and professional judgment. KHULA does not accept responsibility for any errors or omissions in the assessment and therefore does not accept any consequential liability arising from commercial decisions made, which are based on the information contained in this report. Opinions presented in this report apply to conditions/site conditions applicable at time of review and those which are reasonably foreseeable.

Glossary7

Alluvial soil: A deposit of sand, mud, etc. formed by flowing water, or the sedimentary matter deposited thus within recent times, especially in the valleys of large rivers. Biodiversity: The number and variety of living organisms on earth, the millions of plants, animals and micro-organisms, the genes they contain, the evolutionary history and potential they encompass and the ecosystems, ecological processes and landscape of which they are integral parts. Buffer: A strip of land surrounding a wetland or riparian area in which activities are controlled or restricted, in order to reduce the impact of adjacent land uses on the wetland or riparian area. Catchment: The area contributing to runoff at a particular point in a river system.

7 As provided by DWA (2005) and WRC Report No. TT 434/09.

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Chroma: The relative purity of the spectral colour which decreases with increasing greyness. Critical Biodiversity Areas: Areas of the landscape that need to be maintained in a natural or near- natural state in order to ensure the continued existence and functioning of species and ecosystems and the delivery of ecosystem services. Delineation (of a wetland): To determine the boundary of a wetland based on soil, vegetation and/or hydrological indicators. Ecoregion: A recurring pattern of ecosystems associated with characteristic combinations of soil and landform that characterise that region. Ephemeral stream: A stream that has transitory or short-lived flow. Groundwater: Subsurface water in the saturated zone below the water table. Habitat: The natural home of species of plants or animals. Hue (of colour): The dominant spectral colour. Hydromorphic soil: A soil that, in its undrained condition, is saturated or flooded long enough to develop anaerobic conditions favouring the growth and regeneration of hydrophytic vegetation (vegetation adapted to living in anaerobic soils). Hydrology: The study of the occurrence, distribution and movement of water over, on and under the land surface. Hydrophytes: Also called obligate wetland plants - plants that are physiologically bound to water where at least part of the generative cycle takes place in the water or on the surface. Halophytes: Salt tolerant plants. Helophytes: Also called facultative wetland plants - essentially terrestrial plants of which the photosynthetically active parts tolerate long periods of submergence or floating on water. Indicator species: A species whose presence in an ecosystem is indicative of particular conditions (such as saline soils or acidic waters). Intermittent flow: Flows only for short periods. Macrophyte: A large plant - in wetland studies usually a large plant growing in shallow water or waterlogged soils. Perennial: Permanent - persisting from year to year. Riparian area delineation: The determination and marking of the boundary of the riparian area. Riparian habitat: Includes the physical structure and associated vegetation of the areas associated with a watercourse which are commonly characterized by alluvial soils (deposited by the current river system) and which are inundated or flooded to an extent and with a frequency sufficient to support vegetation of species with a composition and physical structure distinct from those of adjacent areas. Shrub: A shrub is a small to medium-sized woody plant. Temporary zone: The zone that is alternately inundated and exposed. Terrain unit morphological classes: Areas of the land surface with homogenous form and slope. A watercourse is defined by the National Water Act: (a) A river or spring; (b) A natural channel in which water flows regularly or intermediately; (c) A wetland, lake or dam into which or from which water flows; and (d) Any collection of water which the Minister may, by notice in the Gazette, declare to be a watercourse. Water table: The upper surface of groundwater or that level below which the soil is saturated with water. The water table feeds base flow to the river channel network when the river channel is in contact with the water table. Wetland: An area of marsh, peatland or water, whether natural or artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt, including areas of marine water the depth of which at low tide does not exceed ten metres.

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Acronyms

CBA Critical Biodiversity Area DWA Department of Water Affairs DWAF Department of Water Affairs and Forestry DWS Department of Water and Sanitation EIS Ecological Importance and Sensitivity FEPA Freshwater Ecological Support Area GPS Global Positioning System HGM Hydrogeomorphic IHI Index of Habitat Integrity IHIA Intermediate Habitat Integrity Assessment MAP Mean Annual Participation NEMA National Environmental Management Act NFEPA National Freshwater Ecosystem Priority Areas NWA National Water Act OESA Other Ecological Support Area PES Present Ecological State QDS Quarter Degree Square REC Recommended Ecological Category SANBI South African National Biodiversity Institute Sub-WMA Sub - Water Management Area VEGRAI Riparian Vegetation Response Assessment Index WCBF Western Cape Biodiversity Framework WMA Water Management Area WUL Water Use Licence

Specialist Details and Experience

Natasha van de Haar

Natasha is a registered Professional Natural Scientist (Pr.Sci.Nat) with the South African Council for Natural Scientific Professions (SACNASP). She also holds a Masters Degree in Science (M.Sc.) in the field of Botany. Over the course of Natasha’s career, she completed a number of floral identification short courses and also obtained a certificate of competence for wetland assessments from Rhodes University. She is also a member of the South African Wetland Society, Botanical Society of SA as well as the Western Cape Wetlands Forum.

Her career kicked off as a field ecologist in 2009, focusing on floral biodiversity and ecological functioning, with special mention of wetland ecology and functioning within South Africa (all provinces). She further worked as a specialist project member in Mauritius, Lesotho and Ghana. During the course of her career she obtained extensive experience in conducting terrestrial as well as wetland related surveys in the mining, residential and infrastructure development industries as well as development of several alternative energy facilities. Natasha also gained experience in Biodiversity Offset Initiatives as well as RDL/protected plant permit applications. Presently her main focus is wetland assessments including delineation as well as present ecological state and function assessments.

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1. Introduction

1.1. Background

KHULA Environmental Consultants (hereafter “KHULA”) has been appointed by Propgen (Pty) Ltd to undertake a specialist assessment of the impact of the development of a new school and associated infrastructure on Erf 4742 and Erf 4743, Noordhoek (the proposed site) on the site’s freshwater features. The specialist assessment is required as part of the required Basic Assessment process in terms of the NEMA EIA Regulations, 2014. The location of the proposed site with general surroundings are presented in Figure 1 and 2 below.

Figure 1: Proposed site, presented with green, in relation to its surroundings (Google Earth, 2016).

Figure 2: 1: 50 000 Topo-Cadastral map, dated 2010; indicating the location of the proposed site.

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1.2. Limitations and Assumptions

Only freshwater features within the proposed site were assessed and delineated during the field survey. The Brookwood Stream is located immediately to the south of the proposed site. Detailed assessment of the stream was not included as part of the freshwater assessment, however consideration was afforded to potential impact that may result due to development of the proposed site. All other freshwater features located within 500m of the proposed site were discussed on a desktop level only.

The onsite identification of wetland habitat was made difficult due to the significantly disturbed nature of the proposed site. As a result, some discrepancies relating to the extent of the wetland boundary may be possible. However, as far as practically possible, conclusions made during the field survey were confirmed with the use of digital satellite imagery (Google Earth Pro, 2016) as well as available background information, and the findings as presented within this report were considered sufficient in order to guide layout planning.

WET-Health is a rapid assessment tool which relies on expert opinion and judgement and which relies on qualitative rather than quantitative information. That being said, WET-Health is currently the most suitable technique available to undertake the assessment of wetland Present Ecological State (PES). For the purposes of this study only WET-Health level 1 was undertaken and it is the opinion of the specialist that the method of assessment used, provides a true reflection of the PES as well as human benefit associated with the wetlands.

The accuracy of the Global Positioning System (GPS) utilised will affect the accuracy of the wetland delineation. A Garmin GPSMap 64 was used which has an estimated accuracy rating of 3-5 metres. KHULA is of the opinion however that this limitation is of no material significance and that the wetland-related constraints have been adequately identified.

The assessment was confined to the top 50 cm of soil, in line with the delineation guideline provided by Department of Water Affairs and Forestry (DWAF, updated 2008). Therefore, groundwater was not considered as part of this assessment.

1.3. Legislation

1.3.1. National Water Act (Act no.36 of 1998)

The purpose of the NWA is to ensure that the nation's water resources are protected, used, developed, conserved, managed and controlled in ways which take into account amongst other factors - (g) protecting aquatic and associated ecosystems and their biological diversity; and (h) reducing and preventing pollution and degradation of water resources.

In order to understand and interpret the Act correctly, the following definitions are applicable to this project: ``pollution'' means the direct or indirect alteration of the physical, chemical or biological properties of a water resource; ``protection'', in relation to a water resource, means - (a) maintenance of the quality of the water resource to the extent that the water resource may be used in an ecologically sustainable way; (b) prevention of the degradation of the water resource; and (c) the rehabilitation of the water resource; ``resource quality'' means the quality of all the aspects of a water resource including - (a) the quantity, pattern, timing, water level and assurance of instream flow; (b) the water quality, including the physical, chemical and biological characteristics of the water; (c) the character and condition of the instream and riparian habitat; and (d) the characteristics, condition and distribution of the aquatic biota; “watercourse'' means - (a) a river or spring; (b) a natural channel in which water flows regularly or intermittently; (c) a wetland, lake or dam into which, or from which, water flows; and (d) any collection of water which the Minister may, by notice in the Gazette, declare to be a watercourse, and a reference to a watercourse includes, where relevant, its bed and banks; and ``water resource'' includes a watercourse, surface water, estuary, or aquifer.

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The NWA deals with pollution prevention, and in particular the situation where pollution of a water resource occurs or might occur as a result of activities on land. The person who owns, controls, occupies or uses the land in question is responsible for taking measures to prevent pollution of water resources. The measures may include measures to - (a) cease, modify or control any act or process causing the pollution; (b) comply with any prescribed waste standard or management practice; (c) contain or prevent the movement of pollutants; (d) eliminate any source of the pollution; (e) remedy the effects of the pollution; and (f) remedy the effects of any disturbance to the bed and banks of a watercourse.

Water use is defined broadly, and includes taking and storing water, activities which reduce stream flow, waste discharges and disposals, controlled activities (activities which impact detrimentally on a water resource), altering a watercourse, removing water found underground for certain purposes, and recreation. In general a water use must be licensed unless it is listed in Schedule I, is an existing lawful use, is permissible under a general authorisation, or if a responsible authority waives the need for a licence. 1.3.2. General Notice 509 of the NWA (2016)

According to GN509 of 2016 the extent of a watercourse means: a) a river, spring or natural channel in which water flows regularly or intermittently “within the outer edge of the 1 in 100 year floodline or riparian habitat measured from the middle of the watercourse from both banks”, and for b) wetlands and pans “within a 500 m radius from the boundary (temporary zone) of any wetland or pan” (when the temporary zone is not present then the seasonal zone is delineated as the wetland boundary), and for c) lakes and dams “purchase line plus a buffer of 50 m”.

According to the GN509 a General Authorisation (GA) may be acquired for the use of water in terms of Section 21 c and i within the extent of a watercourse where the Risk Class as determined by the new Risk Assessment Matrix is Low.

1.3.3. National Environmental Management Act (Act no. 107 of 1998)

The NEMA states the following: “Every person who causes, has caused or may cause significant pollution or degradation of the environment must take reasonable measures to prevent such pollution or degradation from occurring, continuing or recurring, or, in so far as such harm to the environment is authorised by law or cannot reasonably be avoided or stopped, to minimise and rectify such pollution or degradation of the environment.”

The Act also makes special mention of the importance of the protection of wetlands: “Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal shores, estuaries, wetlands and similar systems require specific attention in management and planning procedures, especially where they are subject to significant human resource usage and development pressure.”

1.3.4. Floodplain and River Corridor Management Policy

The Floodplain and River Corridor Management Policy was approved by council in 2009. This policy supports the Roads and Stormwater Department objectives incorporated in the Integrated Development Plan for the City of Cape Town. Mainly as a result of the City’s By-law relating to Stormwater Management defining a stormwater system as “both the constructed and natural facilities, including pipes, culverts, watercourses and their associated floodplains, whether over or under public or privately owned land, used or required for the management, collection, conveyance, temporary storage, control, monitoring, treatment, use and disposal of stormwater”. It is in terms of this By-law therefore that Council may prohibit or conditionally permit development in areas adjacent to watercourses and wetlands.

The framework of the policy provides guidance in terms of the set back required from a specific land use or a development / activity. Requirements and conditions are defined in terms of the floodplain zone (flood recurrence interval in years) and ecological buffer (width in meters).

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Determination of ecological buffer widths is based on classification of the watercourse or wetland in terms of a recognized national classification system followed by an assessment of the ecological condition and importance of the system (using nationally recognized methods). Watercourses and wetlands with high ecological condition and importance require a wider buffer than those which have been exposed to considerable modification. For watercourses, buffer width may also be adjusted on the basis of the width of the active channel. The buffer is measured from watercourse “top of bank” or outer edge of the wetland (which must be delineated according to nationally accepted guidelines / methodologies e.g. Department of Water Affairs and Forestry (DWAF; 1999 and 2005). Buffers can vary in width between 10 m and 40 m for watercourses, and up to 75 m for wetlands. A minimum buffer of 10 m is required for concrete canals. 2. Method of Assessment

2.1. Desktop Assessment

The scope of work included a desktop assessment using available national and provincial databases such as municipal Fine Scale Plans and the National Freshwater Ecosystem Priority Areas project (NFEPA, 2011). 2.2. Watercourse Identification and Delineation

A field survey was undertaken on the 4th of July 2016.

For the purpose of the identification of water resources, the definition as provided by the NWA (Act no. 36, 1998) was used to guide the site survey. The NWA defines a water resource as a watercourse, surface water, estuary or aquifer, of which the latter two are not applicable to this assessment due to an estuary being associated with the sea and, in line with best practice guidelines, wetland and riparian assessments only include the assessment of the first 50 cm from the soil surface, therefore aquifers are excluded. In addition, reference to a watercourse as provided above includes, where relevant, its bed and banks.

In order to establish if the watercourse in question can be classified as ‘wetland habitat’ or ‘river habitat’, the definitions as drafted by the NWA (Act no. 36, 1998)8, and the proposed national wetland classification system9 for South Africa and the DWAF (2008) were taken into consideration.

Wetland habitat and riparian habitat are defined in the NWA as the following: ● A ‘wetland’ is land which is transitional between terrestrial and aquatic systems where the water table is usually at or near the surface, or the land is periodically covered with shallow water, and which land in normal circumstances supports or would support vegetation typically adapted to life in saturated soil; and ● ‘Riparian’ habitat includes the physical structure and associated vegetation of the areas associated with a watercourse which are commonly characterized by alluvial soils, and which are inundated or flooded to an extent and with a frequency sufficient to support vegetation of species with a composition and physical structure distinct from those of adjacent areas’.

Whereas wetlands generally display more diffuse flow and are lower energy environments, riparian areas are commonly found along streams and rivers that reflect the high-energy conditions associated with the water flowing in a strongly defined channel (DWAF, 2008). Both rivers and wetlands are listed as types of watercourses and are afforded appropriate protection under the NWA.

Freshwater habitat was identified with the use of the definitions provided above and the delineation took place according to the method supplied by DWAF (2008) in combination with the wetland soil characteristics guidelines drafted by Job (2009).

8 The definitions as provided by the NWA (Act No. 36 of 1998) are the only legislated definitions of wetlands in South Africa. 9 SANBI 2009.

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2.3. Freshwater Feature Classification

Ecosystems included within the ‘Classification System for Wetlands and other Aquatic Ecosystems in South Africa’ (hereafter referred to as ‘the Classification System’) developed by Ollis et al., (2013) encompass those that the Ramsar Convention defines, rather broadly, as ‘wetlands’, namely areas of marsh, fen, peatland or water, whether natural or artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt, including areas of marine water the depth of which at low tide does not exceed six metres (cited by Ramsar Convention Secretariat, 2011). The inland component of the Classification System has a six-tiered structure presented in the figure below.

LEVEL 1 LEVEL 2 REGIONAL SETTING

❖ Marine ❖ DWA Level 1 Ecoregion

❖ Estuarine ❖ NFEPA WetVeg Groups

❖ Inland ❖ Other spatial framework

LEVEL 6 DESCRIPTORS LEVEL 3 LANDSCAPE UNIT

❖ Natural vs artificial ❖ Valley floor

❖ Salinity ❖ Slope

❖ Plain ❖ Substratum type ❖ Bench (hilltop/saddle/shelf) ❖ Vegetation cover type ❖ Geology

LEVEL 4 HYDROGEOMORPHIC (HGM) UNIT LEVEL 5 HYDROLOGICAL REGIME ❖ River ❖ Floodplain

❖ Rivers = Perenniality ❖ Channelled valley-bottom wetland

❖ Period and depth of inundation ❖ Unchannelled valley-bottom wetland ❖ Period of saturation ❖ Depression ❖ Seep ❖ Wetland flat

Figure 3: Classification System for wetlands and other aquatic ecosystems in South Africa.

2.4. Wetland EcoServices and Function Assessment

WET-EcoServices10 was designed for inland palustrine wetlands11 and has been developed to help assess 15 key goods and services that individual wetlands provide in order to allow for more informed planning and decision making. Central to WET-EcoServices is the characterisation of Hydrogeomorphic (HGM) units (refer to the Section above). The rationale behind characterising the HGM units of a wetland is that areas belonging to the same HGM type and falling within a similar geological and climatic setting are likely to have a similar structure and exhibit similar processes.

10 Kotze et al., 2007 WRC Report No TT 339/08 11 marshes, floodplains, vleis and seeps.

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In addition, WET-EcoServices allows for the assessment of potential and actual ecosystem service outcomes of rehabilitation projects by applying the assessment to ‘with rehabilitation’ and ‘without rehabilitation’ situations and comparing the difference between the two. 2.5. Present Ecological State - Wet-Health

WET-Health12 is a tool designed to assess the health or integrity of a wetland. Wetland health is defined as a measure of the deviation of wetland structure and function from the wetland’s natural reference condition. This technique attempts to assess hydrological, geomorphological and vegetation health in three separate modules. A Level 1 WET-Health assessment was undertaken as part of this assessment. 2.6. Ecological Importance and Sensitivity

The EIS method applied to wetlands is based on the assessment tool developed by Rountree et. al (2014) and was used in order to determine the ecological importance and sensitivity of wetlands, incorporating the traditionally examined criteria used in EIS assessments of other water resources by DWA and thus enabling consistent assessment approaches across water resource types.

Hydro-functional importance and basic human needs have been assessed as part of the WET-EcoServices and were therefore excluded.

The EIS method applied for rivers is based on the approach adopted by the DWA as detailed in the document “Resource Directed Measures for Protection of Water Resources” (1999). In the method a series of determinants are assessed on a scale of 0 to 4, where “0” indicates no importance and “4” indicates very high importance. 2.7. Recommended Ecological Category

The Recommended Ecological Category (REC) is determined by the PES score as well as importance and/or sensitivity. Water resources which have a PES falling within an E or F ecological category are deemed unsustainable. In such cases the REC must automatically be increased to a D. Where the PES is determined to be within an A, B, C or D ecological category, the EIS components must be evaluated to determine if any of the aspects of importance and sensitivity are high or very high. If this is the case, the feasibility of increasing the PES (particularly if the PES is in a low C or D category) should be evaluated and either set at the same ecological category or higher depending on feasibility. This is recommended to enable important and/or sensitive water resources to maintain their functionality and continue to provide the goods and services for the environment and society.

2.8. Buffer Determination

The recently published Buffer Zone Guidelines for Rivers, Wetlands and Estuaries (Macfarlane and Bredin, 2016), allows the user to rate key elements such as threats posed by land use / activities on the water resource, climatic factors, the sensitivity of the water resource (i.e. river, wetland or estuary), and buffer zone attributes in order to determine the size a buffer would need to be in order to sufficiently protect a river, wetland or estuary. 2.9. Impact Assessment

A method of assessment summary is provided below; the detailed method is provided in Appendix 1.

The following criteria were taken into consideration when determining the impact of the proposed activities: • The nature of the impact i.e. positive, negative, direct, indirect; • The extent and location of the impact; • The duration of the impact i.e. short term, long term, intermittent or continuous; • The magnitude/intensity of the impact i.e. high, medium, low; and • The likelihood or probability of the impact actually occurring.

12 Macfarlane et al., 2007 WRC Report No TT 340/09 – Level 1 assessment

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Mitigation measures were subsequently identified and recommended for all impacts to reduce the overall impact significance to an acceptable level, where and if possible. Mitigation measures were aimed to ensure that: • More environmentally sound designs / layouts / technologies, etc., are investigated and implemented, if feasible; • Environmental benefits of a proposed activity are enhanced; • Negative impacts are avoided, minimised or remedied; and • Residual negative impacts are within acceptable levels. 3. Results

3.1. Overview of Background Information

The proposed site falls within the quaternary catchment G22A and within the Berg Water Management Area (WMA) and Greater Cape Town sub-Water Management Area (sub-WMA) as defined by NFEPA (2011). According to Mucina and Rutherford (2006, updated 2012), the proposed site is located within the Hangklip Sand Fynbos vegetation type. Hangklip Sand Fynbos is listed as endangered by the National List of Threatened Terrestrial Ecosystems (2011). Wetlands associated with the proposed site fall within the Southwest Sand Fynbos wetland vegetation group (NFEPA, 2011), listed as critically endangered within the region.

The proposed site is not indicated to be of any terrestrial conservational importance by the City of Cape Town Biodiversity Network (BioNet, 2016). The Land Use Decision Support (LUDS) tool indicates the land cover within the proposed site as being primarily shrubland fynbos with some small isolated areas with thickets within the immediate surroundings. This is however not considered representative of the present condition. Historical imagery indicates that natural vegetation was already removed by 1973 for the development of grazing pastures (refer to Figure 4).

Figure 4: Historical image dated 1973.

No wetland features are indicated within 500m of the proposed site by NFEPA. However, the City of Cape Town’s wetland layer (2015) indicates three features within the proposed site of which two are considered to be natural and one is indicated to be a dam (Figure 5 and Figure 6). The two natural wetlands as well as the dam were chosen as Other Ecological Support Areas (OESAs). OESAs are lower ranking artificial wetlands and the lowest ranking natural or semi-natural wetlands. The objectives for these features are to maintain natural ecosystems, restore degraded land to natural and to manage for no further degradation. The presence of the dam was confirmed during the site survey; however the two natural wetlands were found to be part of the severely degraded wetland habitat found throughout most of the proposed site, discussed in detail in Section 3.2.

The Topo-Cadastral map dated 1942, indicates a drainage line along the south eastern boundary of the proposed site (Figure 7). The following Topo-Cadastral map dated 1962, shows that the drainage line was redirected through the centre of the proposed site (Figure 8), coinciding with the central natural wetland feature as presented by the City of Cape Town’s wetland layer. However, the drainage line was impounded

Freshwater Assessment: Generation School March 2017 KHULA Environmental Consultants Page 17 approximately 700m upstream of the proposed site at some point between 1962 and 1983 and all further Topo-Cadastral maps do not indicate the drainage line downstream of the impoundment.

Figure 5: Wetlands with conservational importance as indicated by the City of Cape Town wetlands layer (2015).

Figure 6: Wetlands indicated by the City of Cape Town wetlands layer (2015). Area where the drainage line has been impounded is indicated with a red circle.

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Figure 7: Topo-Cadastral map dated 1942; presenting the drainage line along the eastern boundary of the proposed site.

Figure 8: Topo-Cadastral map dated 1962; following the redirecting of the drainage line through the centre of the proposed site.

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3.2. Site Description

Noordhoek is known for extensive wetland areas and it is therefore deemed possible that a large portion of the proposed site could have consisted of well-defined wetland habitat prior to disturbance. This assumption was supported by the presence of hydromorphic soil13 encountered at most areas throughout the proposed site where hand augering was conducted, discussed in detail in Section 3.4. However, the proposed site has been used as grazing pastures for decades. Infilling, tilling as well as possible irrigation has resulted in the transformation of the indigenous vegetation assemblage as well as the natural hydrological regime, to the extent that the larger portion of the proposed site (21 611m2 of the 25 511m2) can be described as severely degraded wetland habitat.

Indigenous vegetation was mainly encountered within a channel running through the centre of the proposed site, within a dam as well as within three seeps, these features will be discussed in more detail below. As a result, wetland habitat associated with these features is considered semi-degraded and comprises approximately 3 900m2 of the site. The remainder of the proposed site is dominated by the alien grass species Pennisetum clandestinum and Stenotaphrum secundatum, both known to dominate moist disturbed areas. Only scattered individuals of indigenous species such as Sporobolus africanus and Zantedeschia aethiopica, also indicative of moist soil conditions, were identified within depressional areas.

Figure 9: Encroachment by Pennisetum clandestinum throughout the proposed site (left) with depressional areas dominated by Stenotaphrum secundatum (right; vegetation with slightly more red appearance).

13 A soil that, in its undrained condition, is saturated or flooded long enough to develop anaerobic conditions favouring the growth and regeneration of hydrophytic vegetation.

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Figure 10: Delineation of wetland areas with relatively abundant indigenous vegetation within the proposed site considered to be semi-degraded. The remainder of the proposed site is considered to be severely degraded wetland habitat.

Central channel

The development of grazing pastures necessitated the channelling and straightening of the historical drainage line as discussed in Section 3.1. Hydromorphic soil encountered within lower lying areas to the west of the channel indicates potential seepage of water from the channel, however this may also indicate the extent of wetland habitat before transformation. Augering at several points along the channel proved difficult, indicating that the channel may have been lined originally, however lack of maintenance over decades has resulted in fragmentation of the concrete and consequent seepage into immediate surroundings.

Wetland seeps

Stormwater channels border the proposed site on the northern as well as western peripheries. Seepage from these channels has resulted in the formation of three wetland seeps, two of which remain saturated long enough to support obligate14 wetland species such as Typha capensis, Juncus sp. and Ficinia nodosus.

Dam

Excavation has resulted in the formation of a depression, indicated as a dam in Figure 10. The dam has been supplied with sufficient volumes of subsurface water from the seep directly to the north of the feature as well as from precipitation to allow for the establishment of obligate wetland species. Discussions with the ToadNUTS (Noordhoek Unpaid Toad Savers) revealed the possibility that the dam may be augmented by a spring, however this could not be established with certainty.

14 Plants that are physiologically bound to water where at least part of the generative cycle takes place in the water or on the surface.

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Figure 11: Central channel.

Figure 12: North eastern seep (left) and north western seep (right).

Figure 13: Dam.

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3.3. Freshwater Feature Classification

The method developed by Ollis et. al. (2013) was used to classify the wetland system identified within the proposed site, as best as possible prior to disturbance taking place. In order to obtain the most representative result, findings of the site assessment as well as historical imagery and Topo-Cadastral maps were used to inform the classification process. Discussed in detail in Section 3.1 and 3.2. The bullet points below summarise the results from Level 1 through to Level 6: ● Level 1 – o Inland Systems: An inland system is defined as an aquatic ecosystem with no existing connection to the ocean. These ecosystems are characterised by the complete absence of marine exchange and/or tidal influence. ● Level 2 – ○ Southwest Sand Fynbos wetland vegetation group listed as critically endangered (NFEPA, 2011) and the Southern Folded Mountains Ecoregion (DWA, Level 1 Ecoregions, 2005). ● Level 3 – ○ Slope: An inclined stretch of ground typically located on the side of a mountain, hill or valley. The gradient of the slope is taken to be typically greater or equal to 1:100. ● Level 4 – o Seep: A wetland area located on gently to steeply sloping land and dominated by colluvial (i.e. gravity-driven), unidirectional movement of water and material down-slope. ● Level 5 – ○ Seasonally inundated: with surface water present for extended periods during the wet season. ○ Seasonally saturated: with all the spaces between the soil particles filled with water for extended periods. ● Level 6 – ○ Wetland descriptors: ■ Substratum: Silt (temporary/seasonal wetland zone) / organic soil (permanent wetland zone). ■ Vegetation: Herbaceous – Grasses, sedges and herbs/forbs.

3.4. Watercourse Delineation

A site survey was undertaken on the 4th of July 2016, during which the wetland indicators as mentioned in Section 2.2 were identified and utilised in order to delineate the boundaries of wetland habitat which consists of higher diversity wetland floral species.

Three areas were identified where obligate15 wetland vegetation dominated, presented in Figure 10. The remainder of the site was dominated by two exotic graminoid species known to proliferate in disturbed moist conditions namely Pennisetum clandestinum and Stenotaphrum secundatum, Only scattered individuals of indigenous species such as Sporobolus africanus and Zantedeschia aethiopica, also indicative of moist soil conditions, were identified within depressional areas.

Hand augering was conducted in order to determine the presence of indicators of hydromorphic soils16 such as gleying, mottling, organic streaking and leaching (wetland indicators defined by DWAF, 2008 and Job, 2009) within the first 50cm of the soil surface.17 The first 2 to 3 cm of most of the areas investigated consisted of a decomposed organic material layer, this 2 to 3 cm of soil was underlain by silty soil with a high organic matter content and overall low chroma18. Mottling was also observed throughout the proposed site (refer to Figure 15 and Figure 16).

15 Floral species almost always found in wetlands (> 99% of occurrences). 16 A soil that, in its undrained condition, is saturated or flooded long enough to develop anaerobic conditions favouring the growth and regeneration of hydrophytic vegetation (vegetation adapted to living in anaerobic soils). 17 In line with the DWAF 2008 delineation guidelines. 18 The relative purity of the spectral colour, which decreases with increasing greyness.

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Figure 14: Areas where the soil profile was investigated with the use of a handheld auger, indicated by orange markers.

Figure 15: Photographs representative of the soil within seasonal / permanent wetland zones of the seeps. Note high organic matter content and lower chroma19.

Figure 16: Photographs representative of the soil encountered within the remainder of the proposed site with distinct mottling observed indicative of temporary wetland zones.

19 Soils with variegated colour patterns are described as being mottled. A grey soil matrix and/or mottles must be present within 50cm of the surface for the soil horizon to be classified as a wetland (DWA, 2008).

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The proposed site is located on gradually sloping land without distinct terrain units that would indicate areas conducive for the formation of wetland conditions. In addition, surface water was mainly restricted to the dam. As a result, terrain units as well as the presence of surface water was of limited use with the identification of wetland habitat. Therefore, hydromorphic soil20 in combination with the presence of vegetation known to thrive in soil that would be saturated for at least part of the year were used as the primary indicators of wetland conditions during the site survey. 3.5. Present Ecological State – WET-Health

WET-Health21 is defined as a measure of the similarity of a wetland to a natural or reference condition and the assessment was done in line with the findings of the field survey which suggest that the proposed site formed part of a larger wetland system historically. As a result, the proposed site was assessed as one wetland system, with the dam and central channel contributing to impact incurred as a result of anthropogenic activity in the past.

This technique22 assesses the hydrological, geomorphological and vegetation health in three separate modules. The probable trajectory of change was also considered should development proceed as well as if the project does not prove feasible. The key findings for the WET-Health assessment are summarised below: • The development of grazing pastures necessitated the channelling and straightening of the historical drainage line as discussed in Section 3.1. • The natural hydrological regime has further been altered by the construction of Silvermine Road which impedes flow from upstream areas. In addition, channels conveying stormwater from the catchment as well as from Silvermine Road have been developed through the site and on the periphery of the site. • Historical aerial imagery indicates that the entire site was used for crop cultivation in the past which has impacted the geomorphology and vegetation significantly. It is highly unlikely that diversity and abundance of indigenous hydrophytes would increase within the proposed site without intervention and ongoing management.

Table 1: WET-Health results table.

Hydrology Geomorphology Vegetation

Impact category E E E

Ecological state without → → → development

Ecological state with ↓ ↓ N/A23 development

→ State is likely to remain stable over the next 5 years. ↓ State is likely to deteriorate slightly over the next 5 years. ↓↓ State is expected to deteriorate substantially over the next 5 years.

The overall wetland health24 score calculated for the wetland falls within a PES Category E, refer to the table below for Category definitions. Considering the extent to which wetland habitat is already transformed it would most likely remain in its current PES Category for the next 5 years, should current land use activities continue and should development not take place.

20 A soil that, in its undrained condition, is saturated or flooded long enough to develop anaerobic conditions favouring the growth and regeneration of hydrophytic vegetation (vegetation adapted to living in anaerobic soils). 21 Macfarlane et al., 2007 WRC Report No TT 340/09 22 A Level 1 WET-Health assessment was undertaken as part of the wetland PES assessment. 23 The trajectory of change does not make provision for the potential increase of a present state. 24 (hydrology score) x 3 + (geomorphology score) x 2 + (vegetation score) x 2 / 7 = overall wetland health

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Table 2: PES Categories used by WET-Health for describing the integrity of wetlands (after Macfarlane et al., 2007). Description PES Category Unmodified, natural. A Largely natural with few modifications. A slight change in ecosystem processes is discernible B and a small loss of natural habitats and biota may have taken place. Moderately modified. A moderate change in ecosystem processes and loss of natural habitats C has taken place but the natural habitat remains predominantly intact Largely modified. A large change in ecosystem processes and loss of natural habitat and biota D and has occurred. The change in ecosystem processes and loss of natural habitat and biota is great but some E remaining natural habitat features are still recognisable. Modifications have reached a critical level and the ecosystem processes have been modified F completely with an almost complete loss of natural habitat and biota.

3.6. Wetland EcoServices and Function Assessment

The WET-Ecoservices tool was applied to severely degraded wetland habitat and areas with relatively abundant indigenous vegetation considered to be semi-degraded25. The assessment was repeated for wetland habitat after construction of the Applicants Preferred Alternative, assuming successful implementation of the rehabilitation and management plan; in order to determine the potential loss or gain of Ecosystem Services should the development proceed. The Residential Alternative was also assessed, however due to isolation of the dam and central channel these features were assessed separately.

Fifteen Ecosystem Services were assessed and the results are presented in Table 4 below. Brief explanations of the most noteworthy results are provided below: ● The results indicate that wetland habitat within the proposed site can be considered of greater importance in terms of the provision of indirect benefits such as enhancement of water quality and erosion control. ● Wetland habitat, regardless of degree of transformation, can be considered the most important in terms assimilation of nitrate, phosphate and toxicants as well as erosion control (all falling within a moderate to high class). It is the opinion of the specialist that the revegetation of remaining wetland habitat with wetland floral species with a higher assimilation capability compared to the dominant species currently within the proposed site, may increase the assimilation capabilities of wetland areas considerably (Applicants Preferred Alternative). ● Cultivation and fertilization of areas within the catchment of the proposed site is considered to increase the overall importance of wetland areas within the proposed site in terms of the assimilation of nitrates, phosphates and toxicants which may enter into the wetland areas in runoff. ● None of the results indicate a significant decrease of any Ecosystem Services after development of the Applicants Preferred Alternative. However, six Ecosystem Services showed a potential to increase (highlighted in green in Table 4 below) indicating an opportunity to increase Ecosystem Services with environmentally sensitive design and rehabilitation. ● All rates calculated for Ecoservices as part of the Residential Alternative decreased. ● Semi-degraded wetland habitat is considered of increased importance when compared to degraded wetland habitat in terms of streamflow regulation, erosion control and carbon storage. However, the degraded wetland habitat is considered of increased importance in terms of phosphate and nitrate assimilation as well as harvestable resources. The difference in scores can be attributed to hydrological zonation and direct inflow of stormwater from roads into wetland seeps which lowers the capacity of these wetlands to assimilate further solutes. Harvestable resources calculated a higher score due to grazing of livestock. ● Semi-degraded wetland habitat calculated a moderate score for one direct benefit namely maintenance of biodiversity mainly as a result of the breeding habitat provided by the dam for Amietophrynus pantherinus (Western leopard toad).

25 25 Considering all characteristics of the dam, seep wetlands and central channel as presented in Figure 10.

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Table 3: Classes for determining the likely extent to which a benefit is being supplied based on the overall score for that benefit (after Kotze et al., 2007).

Score (range 0 - <0.5 0.5-1.2 1.3-2.0 2.1-2.8 >2.8 4)

Rating of the Low Moderately Low Intermediate Moderately High High likely extent to which a benefit is being supplied

Table 4: WET-EcoServices results table. Ecosystem Services that showed an increase following development are highlighted with green. Noteworthy differences26 between semi-degraded wetland habitat and severely degraded wetland habitat are highlighted with blue.

Indirect benefits (Regulating and supporting benefits) Pre-development Pre-development Post Post Post (semi-degraded (severely development development development wetland habitat) degraded (Applicant’s (Residential (Residential wetland habitat) Preferred Alternative = Alternative = Alternative) dam) central channel Flood attenuation**** 1.3 1.3 1.8 0.0 0.8 Streamflow regulation** 1.6 1.2 1.6 0.0 1.0 Sediment trapping**** 0.8 0.8 1.0 0.0 0.4 Phosphate removal**** 2.2 2.8 2.3 1.0 1.8 Nitrate removal*** 2.8 3.5 3.0 2.1 2.3 Toxicant removal*** 2.3 2.3 2.3 1.1 1.4 Erosion control*** 2.5 2.3 2.6 0.9 1.5 Carbon storage*** 1.3 0.3 1.0 1.3 0.3 Direct benefits Maintenance of biodiversity** 2.0 0.9 2.2 0.3 0.0 Water supply for direct human use** 0.5 0.2 0.3 0.7 0.2 Harvestable natural resources** 0.0 1.2 0.0 0.0 0.0 Provision of cultivated foods*** 0.0 0.0 0.0 0.0 0.0 Cultural significance* 0.0 0.0 0.0 0.0 0.0 Tourism, recreation, scenic value** 0.0 0.0 1.1 0.0 0.0 Education and research* 1.3 0.3 2.0 1.0 1.0 Size is seldom important *; Size is usually moderately important**; Size is usually very important***; Size is always very important****

26 Where the difference in score results in a different class, refer to Table 3.

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Figure 17: WET-EcoServices results: Light Green – semi-degraded wetland habitat; Orange – severely degraded wetland habitat; Light Blue – Post development (Applicants Preferred Alternative); Dark Blue – Post Development (Residential Alternative – central channel); Dark Green – Post Development (Residential Alternative – dam).

3.7. Ecological Importance and Sensitivity (EIS)

The EIS method applied to wetlands is based on the assessment tool developed by Rountree et. al. (2014). The method was applied to severely degraded wetland habitat and semi-degraded wetland habitat27, separately. The assessment was repeated for wetland habitat after construction of the Residential Alternative as well as the Applicants Preferred Alternative, assuming successful implementation of the rehabilitation and management plan; in order to determine the potential increase or decrease of EIS should development proceed.

The key aspects considered during this EIS assessment are summarised below and in the table to follow: • In its current impacted state, the possibility of wetland habitat within the proposed site providing breeding or feeding habitat for a diverse community of wetland dependent faunal species is considered to be low. However, it should be noted that the endangered Amietophrynus pantherinus (Western leopard toad) is known to breed within the dam located within the proposed site. One of the aims of landscaping should therefore be to recreate and expand breeding and foraging habitat for this species as well as other faunal species. • The proposed site is located within the Hangklip Sand Fynbos vegetation type. Hangklip Sand Fynbos is listed as endangered by the National List of Threatened Terrestrial Ecosystems (2011) which increases the EIS of the wetland habitat present. • Although the wetland itself is not located within a formally protected nature reserve and therefore does not have any protection status it is still considered to fall within the Southwest Sand Fynbos wetland vegetation group listed as critically endangered (NFEPA, 2011). • It has been assumed that sensitivity to floods and flow will decrease with development, regardless of alternative authorised.

27 Considering all characteristics of the dam, seep wetlands and central channel as presented in Figure 10.

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The final EIS scores places the semi-degraded wetland habitat in a High Category (refer to Table 6 for definitions) and the severely degraded wetland habitat within a Low Category. Should development of the Applicant’s Preferred Alternative prove feasible and should an environmentally sensitive rehabilitation and landscaping plan be implemented, the overall EIS of remaining wetland habitat will fall within a High Category. The overall EIS score for the Residential Alternative falls with a Moderate Category, solely due to the dam providing breeding habitat for Amietophrynus pantherinus (Western Leopard Toad) as well as the threat status of the vegetation type.

Table 5: EIS results.

Score (0-4) Pre-development Pre-development Post Confidence Post (semi-degraded (severely development development wetland habitat) degraded (Applicants (Residential wetland habitat) Preferred Alternative) Alternative) Biodiversity High Low (average) High Moderate support (average) (average) (average) Presence of Red 4 2 4 2 4 Data species Populations of 1 0 2 1 2 unique species Migration/breedin 3 1 4 2 3 g/feeding sites Landscape scale Moderate Low High Moderate

(average) (average) (average) (average) Protection status 0 0 0 0 4 of the wetland Protection status of the vegetation 4 4 4 4 4 type Regional context of the ecological 1 0 2 0 4 integrity Size and rarity of the wetland type/s 1 0 2 0 4 present Diversity of 2 0 3 2 4 habitat types Sensitivity of the Moderate Low Low Low

wetland (average) (average) (average) (average) Sensitivity to 1 1 0 0 3 changes in floods Sensitivity to changes in low 2 1 0 1 3 flows/dry season Sensitivity to changes in water 1 1 2 1 2 quality ECOLOGICAL IMPORTANCE High Low High Moderate

AND (average) (average) (average) (average) SENSITIVITY

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Table 6: EIS Categories.

EIS Category definitions Range of EIS score Very high: Wetlands that are considered ecologically important and sensitive on a national >3 and <=4 or even international level. The biodiversity of these systems is usually very sensitive to flow and habitat modifications. They play a major role in moderating the quantity and quality of water of major rivers High: Wetlands that are considered to be ecologically important and sensitive. The >2 and <=3 biodiversity of these systems may be sensitive to flow and habitat modifications. They play a role in moderating the quantity and quality of water of major rivers. Moderate: Wetlands that are considered to be ecologically important and sensitive on a >1 and <=2 provincial or local scale. The biodiversity of these systems is not usually sensitive to flow and habitat modifications. They play a small role in moderating the quantity and quality of water of major rivers. Low/marginal: Wetlands that are not ecologically important and sensitive at any scale. The >0 and <=1 biodiversity of these systems is ubiquitous and not sensitive to flow and habitat modifications. They play an insignificant role in moderating the quantity and quality of water of major rivers.

3.8. Recommended Ecological Category

The Applicants Preferred Alternative as described in Section 4.1 allows for the establishment of diverse indigenous vegetation communities around each of the wetland seeps and dam (refer to Figure 10) as well as within a wetland corridor along the eastern boundary of the proposed site. In addition, this alternative would ensure wetland habitat retained in the development stays connected in order to enable migration of faunal species through the proposed site. Different hydrological zones28 will also be incorporated which will increase the diversity of wetland habitat as well as increase ability of wetland habitat to provide functions and services. An ecological Category of at least C29 is therefore considered achievable for these wetland areas. It is the opinion of the specialist that with adequate management there is a possibility to achieve an ecological Category B30 in the long term.

It is also considered possible to increase the floral diversity within the areas earmarked for landscaping with the construction of the Residential Alternative. However, urban gardens tend to be terrestrial and connectivity within the site will not be maintained. Therefore, it is recommended that a Category D31 be attained within landscaped areas in the vicinity of the dam. 3.9. Buffer Determination

It will not be practical to designate buffer zones (wherein no development should be allowed) around the dam and central channel should the Residential Alterative be selected due to the extent of infrastructure required in order for development to prove feasible (refer to Figure 21 below). This is also largely the challenge with the Applicants Preferred Alternative, however, retained in the areas designated as open space are the site’s semi-degraded habitat and some of the severely degraded wetland habitat where rehabilitation is proposed (refer to Figure 20 below).

The use of the Buffer Zone Guidelines for Rivers, Wetlands and Estuaries (Macfarlane and Bredin, 2016) for the determination of a buffer zone for the Brookwood Stream was considered. However, it is the opinion of the specialist that any impact on the Brookwood Stream that might arise due to development will be insignificant. This conclusion is based on the fact that buildings required as part of the Residential Alternative and the Applicant Preferred Alternative are set back approximately 40m and 50m, respectively from the edge of the watercourse. A wetland detention pond has been proposed within the setback area as part of the Applicants Preferred Alternative. However, guidelines have been provided in Section 5.1.1. order to enhance wetland biodiversity and function within the proposed site with the use of the detention pond and it is therefore unlikely that the creation of the pond would impact the Brookwood Stream.

28 Permanent, seasonal and temporary wetland habitat. 29 Moderately modified. A moderate change in ecosystem processes and loss of natural habitats has taken place but the natural habitat remains predominantly intact. 30 Largely natural with few modifications. A slight change in ecosystem processes is discernible and a small loss of natural habitats and biota may have taken place. 31 Largely modified. A large change in ecosystem processes and loss of natural habitat and biota and has occurred.

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Figure 18: Brookwood Stream situated adjacent to the southern tip of the proposed development. 4. Activity Description

Two alternative development options are being considered, the Applicant’s Preferred Alternative which would entail the development of a school for approximately 600 learners, and a Residential Alternative comprising 6 residential erven. The two alternatives are discussed in the sections below. 4.1. Applicant’s Preferred Alternative

The proposed site comprising of Portion 1 and Portion 18 of the Farm 931 Noordhoek, extends over approximately 25 511m2. The new school will be built to accommodate approximately 600 learners in the pre-primary, primary, middle and high school levels. The school will also accommodate approximately 50 staff. The school will comprise of the following: • Buildings with a floor area of 5 495m² • A playing field of 2 200m² • Courtyard space, surfaced spaces between buildings and walkways comprising 5 065m² • Internal roads and parking comprising 3 800m² • Natural open space comprising rehabilitated wetlands, ponds, landscaped swales and other greenspace 10 150m2 • Access to the site will be gained via a new traffic circle which will be constructed on Silvermine Road.

The geotechnical survey concluded that the soils within the proposed site are not optimal for development. Therefore, existing organic, silty sand will be replaced with clean free draining Philippi sand in order to facilitate the development of the sports fields, parking and paved pathways. Phillipi sand is largely inert with no available minerals to leach out (pers. communication Mr. D. Stonestreet of de Villiers Sheard cc Consulting Structural and Civil Engineers). For the buildings, use will be made of concrete bases, and piers with ground beams which would be founded in the in-situ material i.e. no sand replacement.

As part of the natural open space catered for as part of the Applicant’s Preferred Alternative, parts of the site with less degraded wetland habitat will be set aside and rehabilitated. Buildings and roads will be restricted to areas consisting of severely degraded wetland habitat currently dominated by Pennisetum clandestinum and Stenotaphrum secundatum. In addition, one wetland swale and one terrestrial swale as well as a wetland corridor along the eastern boundary of the proposed site have been incorporated as part of the stormwater plan.

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Figure 19: Semi-degraded wetland habitat that will be designated No Go wetland habitat as part of the Applicant’s Preferred Alternative.

Vegetated swale (wetland)

Vegetated swale (terrestrial)

Eastern wetland corridor

Figure 20: Applicant’s Preferred Alternative

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4.2. Residential Alternative

The residential alternative will be in line with the City of Cape Town Development Management Scheme (DMS) Overlay Zone that prescribes a minimum erf size of 4000m². It is considered reasonable to assume that such a scheme would entail the following:

Retain its underlying Rural Zoning and therefore the following uses would be permitted: • Primary Uses - dwelling house, agriculture and additional use rights • Additional Use Rights - second dwelling, home occupation, bed and breakfast establishment or home child care • Consent Use - guest house, tourist facility, wind turbine infrastructure, intensive animal farming, farm shop and agricultural industry • An application for subdivision into six portions, each 4000sqm and an access road portion • Access off Silvermine Road

Each property permitted as per DMS: • 1500m² floor area (total 9000m²) • 40% coverage • 11 meters height • Possible second dwelling by consent thereby increasing the footprint of the development

All of the less degraded wetland areas, as delineated and presented in Figure 10, will be infilled with the exception of the incorporation of the existing dam and the channel running through the centre of the proposed site. No allowance has been made for stormwater detention facilities that would have reduced post-development runoff volumes or polishing of stormwater prior to release in the Brookwood Stream.

Dam

Central channel

Vegetated swale

Figure 21: Residential Alternative.

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5. Assessment of Impacts

5.1. Impact Identification

The layout and design of the Applicant’s Preferred Alternative has been extensively workshopped with involvement of both the freshwater specialist as well as faunal specialist in order to attain the most environmentally sensitive layout which could also accommodate the development of the school. As a result, many direct impacts typically associated with developments near or within wetland environments have been addressed within the layout design phase of the project. The most pertinent outcomes include: • Demarcation of the site’s least degraded wetland areas (i.e. those areas with higher levels of indigenous vegetation) as No Go areas, as presented in Figure 19. • Rehabilitation of additional sections of degraded wetland habitat in order to increase total net wetland function and wetland service provision on the proposed site. Additional areas earmarked for rehabilitation include areas adjacent to all three seeps as well as the proposed wetland corridor located along the eastern boundary of the proposed site. Although extensive rehabilitation measures may not be practical along the proposed wetland swale due to width and location, it will be vegetated with indigenous species which will provide shelter and foraging habitat for wetland fauna. The swale will also provide a migration corridor for faunal species from Noordhoek Main Road towards the eastern wetland corridor. • Retaining the breeding habitat (specifically the dam) and a migration corridor through the proposed site for Amietophrynus pantherinus (Western Leopard Toad). A suitably qualified specialist was appointed in order to ensure these concerns are addressed as part of the design of the school.

In assessing the identified potential construction phase impacts, it has been assumed that good housekeeping measures (listed below) will be implemented through adherence to the Environmental Management Programme (EMPr), regardless of the development alternative authorised: • Avoid the use of infill material or construction material with pollution / leaching potential. • Clean up any spillages (e.g. concrete, oil, fuel), immediately. Remove contaminated soil and dispose of it appropriately. • Service vehicles and machinery within demarcated areas, preferably off-site. • Use bunded surfaces within designated areas for re-fuelling vehicles. Vehicles should preferably be refueled off site. • Provide adequate temporary toilets for the duration of the construction phase, the temporary toilets should be located within areas earmarked for construction. Placement of temporary toilets within areas where wetland habitat will be retained should be strictly prohibited. • Store fuel, chemicals and other hazardous substances in suitable, secure, weather-proof containers and within an area with impermeable and bunded floors, preferably off-site or otherwise within areas earmarked for construction. • Cover equipment and storage piles to limit dust generation. • Restrict the dumping or storage of construction material to the footprint of construction areas. These areas should be located at least 15m from all the semi-degraded wetland habitat to be retained in the development and the eastern wetland corridor (applicable to the Applicants Preferred Alternative only). • Dispose of used oils, wash water from cement and other pollutants at an appropriately licensed landfill site. • Dispose of concrete and cement-related mortars in an environmental sensitive manner (can be toxic to aquatic life). Washout should not be discharged into the dam or Brookwood Stream. A washout area should be designated at least 15m from any remaining wetland area, and wash water should be treated on-site or discharged to the sanitary sewer. • No grey water should be passed into swales or any other watercourses. Placement of backwash water from swimming pools into swales or watercourses should be strictly be prohibited. • Remove all construction material and waste upon completion of the project.

The potential impact on faunal communities (focussing on wetland fauna) has been assessed by Mr. M. Burger as a separate study therefore this freshwater study does not specifically address these impacts. Potential direct impacts on watercourses32 expected to occur as a result of the construction and operation of both development alternatives as well as potential impacts associated with the No Go Alternative are

32 Watercourses as defined by Notice 509 gazetted on the 26th of August 2016.

Freshwater Assessment: Generation School March 2017 KHULA Environmental Consultants Page 34 discussed in the sections below. Mitigation measures are also recommended to either avoid, minimise or mitigate the identified potential impacts. The impact ratings are followed by discussions on the indirect and cumulative impacts in Section 5.3 and 5.4, respectively. 5.1.1. Applicant’s Preferred Alternative

The following direct construction phase impacts are expected to occur should the Applicant’s Preferred Layout be selected; with reference to Table 7 below:

Impact 1 - Loss of wetland habitat.

In order to allow for sufficient development space, only semi-degraded wetland habitat33 (extending over approximately 10 150m2) will be conserved whereas most of the degraded wetland habitat will be lost regardless of the implementation of mitigation measures. The degraded wetland habitat was found to be of low ecological importance and sensitivity (refer to Section 3.7). As a result, the intensity of losing 16 560 m² degraded wetland habitat within the proposed site (25 511 m²) is considered to be of medium intensity. The impact resulting from the permanent loss of degraded wetland habitat was therefore assessed to be of medium (negative) significance.

Essential mitigation measures: • N/A

Impact 2 – Sedimentation of retained wetland habitat due to rehabilitation activities and replacement of soil within adjacent construction areas.

Activities associated with landscaping of the semi-degraded wetland habitat being retained in the Applicant’s Preferred Alternative would involve removal of alien vegetation and earthworks (sloping and grading). In addition, soil within the proposed site has been found to be unfavourable for construction and would therefore need to be replaced with foreign material which would aid structural stability as well as movement of subsurface water through the site. Therefore, sedimentation of semi-degraded wetland habitat will occur as a result of increased sediment loads within surface runoff originating from disturbed / infilled areas. It is however considered possible to decrease the probability as well as intensity of the impact with the implementation of sediment control measures.

Restricting site preparation and construction activities to the dry summer months (November to April) would greatly decrease impact significance, however in practice this is not always achievable. As a result, in rating the impact significance, after mitigation, it was assumed that meeting this timeframe would not be feasible.

Due to the proximity of the construction footprint to the semi-degraded wetland habitat, the likelihood of the impact is considered to be ‘definite’ and the intensity ‘high’ without the implementation of mitigation measures. The impact prior to the implementation of mitigation measures was therefore rated to be of high (negative) significance. Although it is not considered possible to entirely avoid any impact, the intensity of the impact would decrease with the implementation of the listed essential mitigation measures. The potential impact, with the implementation of mitigation measures, was therefore rated to be of very low (negative) significance.

Essential mitigation measures: • Complete earthworks required within the retained wetland habitat before the onset of the rainy season followed by revegetation of retained wetland habitat from late April, early May shortly before the onset of the rainy season. • Place sediment fences / traps along the boundary of each retained wetland area and ensure these are maintained and sediment is removed as needed. Use should be made of vegetative bundles / fibre bags or rolls, within the retained wetland habitat itself, where earthworks or the removal of vegetation could result in sedimentation of surrounding wetland habitat. In addition, the remainder of each retained wetland area should be monitored by the appointed ECO, weekly, for sedimentation and erosion in order to ensure erosion and sedimentation is dealt with timeously. Removal of sediment from retained wetland areas should be done manually.

33 All semi-degraded wetland habitat will be retained, except for the central channel.

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• Water pumped from construction areas, following heavy rain, should be pumped to a demarcated settlement area and should not be discharged into any retained wetland habitat or the Brookwood Stream. • Strategically divert stormwater runoff from the construction footprint into sediment trapping devices. All sediment trapping devices should be checked weekly by the ECO and cleared as needed.

Optional mitigation measures: • Restrict, construction to the dry summer months (November to April).

Impact 3 – Transformation of the present hydrological regime of retained wetland habitat.

Permanent wetland habitat associated with the seepage wetlands designated as No Go wetland habitat (refer to Figure 10 for a locality map) has formed due to the supplementation of groundwater by pooling of stormwater runoff from the adjacent roads. No infrastructure proposed as part of the Applicants Preferred Alternative would result in diversion of stormwater away from these areas. However, an increase in the volume of stormwater runoff entering the wetlands is expected due the clearing of vegetation within the construction footprint. This will result in a change in the hydrological regime during the construction phase. However, the change of the hydrological regime is not expected to have a significant secondary impact on the present floral community due to the ability of the identified species to survive extended periods in saturated soil.

Decades of anthropogenic activity has resulted in a significant change of the natural hydrological regime of the watercourses within and surrounding the proposed site. This conclusion is supported by the Topo- Cadastral map dated 1942 (refer to Section 3.2) illustrating the historical path of a drainage line along the eastern boundary of the proposed site. The Applicant’s Preferred Alternative proposes the development of a wetland corridor along the eastern boundary of the proposed site, therefore, re-creating the original flow path of the historical drainage line depicted in 1942. To enable the creation of the eastern wetland corridor, surface water presently augmenting the central channel will need to be intercepted and passed into the north-eastern corner of the proposed site. Therefore the present hydrological regime will be permanently altered, regardless of the implementation of mitigation measures. However, the strategic redirection of water entering the site e.g. to support wetland communities as opposed to being conveyed within the partially lined central channel, will result in an increase in wetland biodiversity and function during the operational phase. The potential impact was therefore rated to be of medium (negative) significance prior to the implementation of mitigation measures and low with the implementation of mitigation measures.

Essential mitigation measures: • Water pumped from construction areas, following heavy rain, should be pumped to a demarcated settlement area and should not be discharged into any retained wetland habitat or the Brookwood Stream. • Ensure that crossings over swales are adequate to enable surface water to flow freely underneath crossings. • Ensure surface water can flow freely underneath the bridge required to access the refuse loading bay. • Implement a Stormwater Management System in accordance with the City’s Management of Urban Storm Water Impacts Policy (2009) that also achieves the following: o Use porous/permeable paving around school buildings. o Use unlined vegetated swales that will allow for infiltration as appose to stormwater pipes. o As far as practically possible stormwater originating from hard surfaces should be passed into vegetated swales in order to decrease water volume and velocity before reaching No Go wetland habitat and the eastern wetland corridor. Otherwise, surface runoff should be diverted away from roads, pavements etc. as quickly as possible, to minimise the amount of water running directly from these areas into wetland habitat. This can be achieved with construction of multiple drains from roads, pavements etc. to ensure the least amount of surface water is discharged directly into a specific area. • Implement the Wetland Rehabilitation and Toad Management Plan which details the manner in which the north-eastern corner of the proposed site where water enters is landscaped. • Cordon off the area where earthworks will be required prior to commencement of any activity within the retained wetland habitat. Disturbance of surrounding wetland habitat should be strictly prohibited. • Complete earthworks within the retained wetland areas before the onset of the rainy season followed by revegetation from late April, early May shortly before the onset of the rainy season.

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• Only undertake earthworks within the retained wetland areas at times recommended by the fauna specialist as earthworks should not affect the breeding season of Amietophrynus pantherinus (Western Leopard Toad). • Thoroughly plan the required activities within retained wetland habitat and discuss the method with the team before any activity commences in order to ensure the disturbance period is kept to an absolute minimum. • The ECO should inspect retained wetland habitat at least on a weekly basis, in order to ensure any unnecessary disturbance are addressed timeously and effectively.

Impact 4 – Disturbance of the retained wetland habitat and the eastern wetland corridor as result of rehabilitation.

It has been assumed that all semi-degraded wetland habitat except for the central channel, will be retained in the development of the school regardless of the implementation of mitigation measures. However, in order to increase aesthetic value of the school grounds as well as increase ecological importance and sensitivity of the retained wetland habitat, the applicant would need to remove alien vegetation and re- introduce indigenous floral species. Minor earthworks in order to create smaller ponds and vegetated swales will also be required. All the required activities will need to take place within the No Go wetland habitat as well as within degraded wetland habitat located along the eastern boundary of the proposed site. In total 10 150m2 has been set aside for natural open space areas which includes wetlands, ponds and greenspace.

The proposed rehabilitation activities, if not carefully planned and executed, may result in a long term impact to wetland habitat which may have a high (negative) significance. However, it is considered possible to decrease the intensity of the negative impact with the implementation of the essential mitigation measures listed below, and to ultimately achieve a positive impact long term. A long term positive impact was assessed as part of the operational phase. Impact during the construction phase considers initial disturbance of wetland habitat as part of the implementation of rehabilitation measures. The potential impact, with the implementation of mitigation measures, is expected to be short term and was rated to be of very low (negative) significance.

Essential mitigation measures: • Implement the Construction phase Environmental Management Programme (EMPr) that includes the following: o All semi-degraded wetland habitat as well as the area earmarked for the wetland corridor along the eastern boundary of the proposed site should be cordoned off and declared a No Go area prior to commencement of site clearing activities. o Only allow construction activities within the demarcated No Go areas in accordance with approved method statements. o Stabilise steep slopes on the periphery of the No Go areas that resulted due to the removal of undesirable soil until the excavated areas have been infilled. • Implement the Wetland Rehabilitation and Toad Management Plan which allows for the creation of shallow depressional areas as part of the design of the eastern wetland corridor. • Implement the Wetland Rehabilitation and Toad Management Plan that details the design of the stormwater detention pond. • Ensure that crossings over swales are adequate to enable surface water to flow freely underneath crossings. Crossings should also cater for the movement of smaller faunal species and amphibians. • Ensure surface water can flow freely underneath the bridge required to access the refuse loading bay. • As far as practically possible, direct permanent outdoor lighting e.g. street and security lights away from the retained wetland habitat and eastern wetland corridor. • Use of palisade fencing is preferred, to facilitate movement of smaller faunal species and amphibians through the site. • Adhere to all design related measures listed within the faunal specialist report. • Implement a Stormwater Management System in accordance with the City’s Management of Urban Storm Water Impacts Policy (2009) that also achieves the following: o Use porous/permeable paving around school buildings. o Use unlined vegetated swales that will allow for infiltration as appose to stormwater pipes. o Revegetate swales with indigenous fynbos as far as practically possible. Recommended species are listed in the Wetland Rehabilitation and Toad Management Plan.

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o As far as practically possible stormwater originating from hard surfaces should be passed into vegetated swales in order to improve water quality before reaching No Go wetland habitat and the eastern wetland corridor. Otherwise, surface runoff should be diverted away from roads, pavements etc. as quickly as possible, to minimise the amount of water running directly from these areas into wetland habitat. This can be achieved with construction of multiple drains from roads, pavements etc. to ensure the least amount of surface water is discharged directly into a specific area. o Construct energy dissipaters (such as lining with stones, concrete, grass or gabions) where surface water disperses out of a drain to reduce the water velocity and therefore erosion. • Implement the Wetland Rehabilitation and Toad Management Plan which lists the preferred floral species34 for each area. • Alien vegetation must be eradicated and monitored for the remainder of the lifespan of the development in accordance with the Wetland Rehabilitation and Toad Management Plan.

Table 7: Impact assessment results for the construction phase.

Alternatives Extent Intensity Duration Consequence Probability Significance Status Confidence Loss of wetland habitat Applicant’s Preferred Long Local Medium Layout – term Medium Definite Medium -ve High (1) (2) without (3) mitigation Sedimentation of retained wetland habitat due to rehabilitation activities and replacement of soil within adjacent construction areas Applicant’s Preferred Long Local High Layout– term High Definite High -ve High (1) (3) without (3) mitigation Applicant’s Short Preferred Local Medium term Very Low Definite Very Low -ve Medium Layout – with (1) (2) (1) mitigation Transformation of the present hydrological regime of retained wetland habitat Applicant’s Preferred Long Local Medium Layout– term Medium Definite Medium -ve High (1) (2) without (3) mitigation Applicant’s Long Preferred Local Low term Low Definite Low -ve Medium Layout – with (1) (1) (3) mitigation Disturbance of the retained wetland habitat and the eastern wetland corridor as result of rehabilitation Applicant’s Preferred Long Local High Layout– term High Definite High -ve High (1) (3) without (3) mitigation Applicant’s Short Preferred Local Medium term Very Low Definite Very Low -ve Medium Layout – with (1) (2) (1) mitigation

The following direct operational phase impact is expected to occur should the Applicant’s Preferred Layout be selected.

34 In line with the species recommended by the City of Cape Town’s Stormwater Management Planning and Design Guidelines for New Developments (2002) and City of Cape Town’s Sustainable Urban Drainage Systems (2010).

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Impact 1 – Increased stormwater runoff into retained wetland habitat from hard surfaces.

The development of hard surfaces e.g. parking areas, buildings and sports fields will result in an increase in the volume as well as velocity of stormwater entering wetland habitat. If not adequately addressed during the construction phase, stormwater runoff could result in erosion and sedimentation as well as pooling of stormwater within newly created temporary / seasonal wetland habitat during the operational phase. Pooling of water will ultimately result in loss of floral communities not adapted to survive extended periods of time in saturated soil.

It has been assumed that post development runoff from the proposed site will not exceed pre-development runoff and that any additional stormwater related requirements listed by the Cape Town’s Stormwater Management Planning and Design Guidelines for New Developments (2002) and City of Cape Town’s Sustainable Urban Drainage Systems (2010) will be met. Therefore, it is the opinion of the specialist that stormwater related impact on the Brookwood Stream would be marginal.

The impact expected to result due to increased stormwater volumes entering wetland habitat within the proposed site during the operation phase was rated to be of medium (negative) significance prior to the implementation of mitigation measures. With the implementation of mitigation measures listed for the construction phase it is deemed possible to adequately address and decrease the impact to a very low (negative) significance.

Essential mitigation measures (to be implemented during the construction phase): • Ensure that crossings over swales are adequate to enable surface water to flow freely underneath crossings. • Ensure surface water can flow freely underneath the bridge required to access the refuse loading bay. • Implement a Stormwater Management System in accordance with the City’s Management of Urban Storm Water Impacts Policy (2009) that also achieves the following: o Use porous/permeable paving around school buildings. o Use unlined vegetated swales that will allow for infiltration as appose to stormwater pipes. o As far as practically possible stormwater originating from hard surfaces should be passed into vegetated swales in order to decrease water volume and velocity before reaching No Go wetland habitat and the eastern wetland corridor. Otherwise, surface runoff should be diverted away from roads, pavements etc. as quickly as possible, to minimise the amount of water running directly from these areas into wetland habitat. This can be achieved with construction of multiple drains from roads, pavements etc. to ensure the least amount of surface water is discharged directly into a specific area. Essential mitigation measures (to be implemented during the construction phase): • Implement the Wetland Rehabilitation and Toad Management Plan that addresses the requirement for monitoring and management of wetland areas.

Impact 2 - Increase in wetland biodiversity and function.

It is considered possible that the positive impact resulting from alien clearing and revegetation may only persist short term without monitoring and management. However, with continued management it is expected that floral and faunal diversity as well as wetland function will continue to increase for as long as the facility remains operational. The impact significance prior to mitigation was rated to be low (positive) and after the implementation of mitigation measures medium (positive).

Essential mitigation measures: • Implement the Wetland Rehabilitation and Toad Management Plan that addresses the requirement for monitoring and management of wetland areas.

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Table 8: Impact assessment results for operational phase.

Alternatives Extent Intensity Duration Consequence Probability Significance Status Confidence Increased stormwater runoff into retained wetland habitat from hard surfaces Applicant’s Preferred Long Local Medium Layout – term Medium Probable Medium -ve High (1) (2) without (3) mitigation Applicant’s Long Preferred Local Low term Low Improbable Very Low -ve Medium Layout – with (1) (1) (3) mitigation Increase in wetland biodiversity and function Applicant’s Preferred Long Local Low Layout – term Low Probable Low +ve Medium (1) (1) without (3) mitigation Applicant’s Long Preferred Local Medium Highly term Medium Medium +ve High Layout – with (1) (2) probable (3) mitigation

5.1.2. Residential Alternative

The extent to which the present hydrological regime of wetland seeps and degraded wetland habitat will be altered following construction of the Residential Alternative will be significant. The ‘loss / change’ thereof has been considered as part of Impact 1. There is a slight possibility that the dam levels may rise following the construction of hard surfaces and the consequential increase of stormwater runoff introduced into the catchment of the dam. However, open water within the dam is currently at a depth that can only sustain obligate species on the fringes of the dam. Therefore, an increase in water depth is not expected to result in any significant impact on the current wetland biodiversity. It has been assumed that the impact due to water volume and quality changes on Amietophrynus pantherinus (Western Leopard Toad) has been assessed within the faunal specialist report. The central channel will remain intact and, except for an increase in surface water volumes following rainfall events, the hydrological regime will remain largely unchanged.

The following direct construction phase impacts are expected to occur should the Residential Alternative be selected; with reference to Table 9 below:

Impact 1 - Loss of semi-degraded wetland habitat and degraded wetland habitat.

Six residential erven each with a swimming pool and patio area are proposed as part of the Residential Alternative. Access to all six erven will be provided by one private road, to be developed adjacent to the central channel. All wetland seeps, considered to comprise semi-degraded wetland habitat, will be infilled. The dam will be retained and incorporated within the landscaped open space area in-between two of the residential developments. In total, development of the Residential Development will result in permanent loss of semi-degraded wetland habitat extending over approximately 3 200m2 as well as severely degraded wetland habitat within areas earmarked for roads, buildings and swimming pools.

The potential impact due to loss of both the semi-degraded and degraded wetland habitat was rated to be of high (negative) significance. The potential impact is unavoidable and it is not considered possible to mitigate the impact.

Essential mitigation measures: • N/A

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Impact 2 – Sedimentation of the dam and central channel.

Vegetation clearing and construction related activities will be required in very close proximity to the retained wetland habitat which for the residential alternative comprises the dam and the central channel. The potential of impact resulting from increased sediment loads within surface runoff originating from disturbed areas is therefore deemed definite if not adequately managed. Although both these wetland features are already severely disturbed, large volumes of deposited sediment may be detrimental to retained wetland habitat resulting in loss of vegetation, habitat as well as function. Therefore, an impact intensity of medium and a duration of long term is considered applicable, prior to the implementation of mitigation measures. It would be difficult to entirely avoid the impact with the implementation of mitigation measures along the central channel due to close proximity of construction areas. However, with timeous removal of sediment deposited within the dam and channel, the duration of the impact can be reduced. The potential impact was rated to be of medium (negative) significance prior to the implementation of mitigation measures and very low (negative) significance with the implementation of mitigation measures.

Restricting site preparation and construction activities to the dry summer months (November to April) would decrease impact significance, however in practice this is not always achievable. As a result, in rating the impact significance, after mitigation, it was assumed that this will not be feasible.

Essential mitigation measures: • Place sediment fences / traps along the boundary of the construction footprint in the vicinity of the dam. As much of the vegetation surrounding the dam should be left intact (not cut / mowed) for the duration of the construction phase. Landscaping activities may only commence once the bulk of the earthworks have been completed. • A strip of vegetation at least 1m wide should be left intact (not cut / mowed) along the western boundary of the channel, followed by an uninterrupted row of fibre bags / straw bales. In addition, fibre bags / straw bales should be placed along the entire length of the channel on the eastern boundary, in order to intercept sediment laden runoff from the road. The runoff from the road should be diverted to a sediment trapping device before it reaches the southern portion of the proposed site as well as the Brookwood Stream. • Removal of sediment deposited within the dam and channel should be undertaken manually on a weekly basis, where required, with as little disturbance to intact vegetation as possible. • The entire proposed site should be monitored by the appointed ECO, weekly, for sedimentation and erosion in order to ensure erosion and sedimentation is dealt with timeously. • Strategically divert stormwater runoff from the construction footprint into sediment trapping devices. All sediment trapping devices should be checked weekly by the ECO and cleared as needed.

Optional mitigation measures: • Restrict construction to the dry summer months (November to April).

Table 9: Impact assessment results for the construction phase.

Alternatives Extent Intensity Duration Consequence Probability Significance Status Confidence Loss of semi-degraded wetland habitat and degraded wetland habitat Residential Long Alternative – Local High term High Definite High -ve High without (1) (3) (3) mitigation Sedimentation of the dam and central channel Residential Long Alternative – Local Medium term Medium Definite Medium -ve High without (1) (2) (3) mitigation Residential Short Alternative – Local Low term Very Low Probable Very Low -ve Medium with (1) (1) (1) mitigation

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Impact 1 – Increased stormwater runoff and water quality impairment.

The development of hard surfaces e.g. parking areas, roads and buildings will result in an increase in the volume as well as velocity of stormwater entering the dam, central channel, and Brookwood Stream. Without the incorporation of stormwater detention ponds as part of the layout plan, it would be difficult to manage stormwater runoff successfully during the operational phase. In addition, stormwater runoff from roads and buildings also have the potential to impact water quality of both remaining wetland habitat as well as the Brookwood Stream. It is however considered possible to decrease the probability as well as significance of the impact with the implementation of the listed mitigation measures as part of the construction phase. The potential impact was rated to be of medium (negative) significance prior to the implementation of mitigation measures and low (negative) significance with the implementation of mitigation measures.

Essential mitigation measures, to be implemented during the construction phase: • Use porous/permeable paving around buildings. • All concrete should be removed from the central channel and the channel vegetated with the use of indigenous species. Preferably, the side slopes should not exceed 3:1 (horizontal to vertical slope). • Use unlined vegetated swales that will allow for infiltration as appose to stormwater pipes. • Revegetate swales with indigenous fynbos as far as practically possible. Preferably, swales should not be mowed, therefore species with good ground covering capability which would not impede flow would need to be introduced. Species selection will need to be undertaken with guidance from the landscape architect in order to identify species that will be commercially available. • As far as practically possible stormwater originating from hard surfaces should be passed into vegetated swales in order to improve water quality. • Surface runoff should be diverted away from roads, pavements etc. as quickly as possible, to minimise the amount of water running directly from these areas into the dam or central channel. This can be achieved with construction of multiple drains from roads, pavements etc. to ensure the least amount of surface water is discharged directly into a specific area. • Stormwater runoff released in the vicinity of the dam, should be dispersed gradually over a large area as opposed to being channelled and passed into the dam at one specific point. Energy dissipaters (such as lining with stones, concrete, grass or gabions) should be constructed where surface water disperses to reduce the water velocity and erosion potential. • Manage irrigation, if required, to prevent over-application. This helps prevent nutrient runoff and leaching into ground water. • The use by residents of fertilisers or chemical soil ameliorants should be kept to a minimum.

Recommended mitigation measures, to be implemented during the construction phase: • It is recommended that a wetland detention pond, similar to the pond proposed by the Applicant’s Preferred Alternative be constructed within the southern portion of the proposed site. • Vegetated swales, as proposed as part of the essential mitigation measures, should be used to direct stormwater to the wetland detention pond before entering the Brookwood Stream.

Impact 2 – Increase in wetland biodiversity and function.

A substantial increase in biodiversity or function of wetland habitat within the proposed site is considered unlikely due the extensive construction footprint and spread-out layout design of the Residential Alternative. However, it is considered possible to improve wetland biodiversity within the immediate surroundings of the dam as well as the channel; although improvement of the present state of the channel will be marginal due to the close proximity of the road and residential infrastructure. The potential impact was rated to be of very low (positive) significance without the implementation of mitigation measures and medium (positive) significance with the implementation of mitigation measures.

Essential mitigation measures: • Only indigenous species should be used as part of landscaping. • Alien vegetation must be eradicated and monitored for the remainder of the lifespan of the development. A suitably qualified landscape architect should be consulted in order to establish the most effective means of ongoing removal of Pennisetum clandestinum. • All concrete must be removed from the central channel.

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• The central channel must be managed as a vegetated swale, therefore alien vegetation should be replaced with a diversity of hardy flow resistant wetland floral species that will aid in water quality improvement. • A fynbos buffer of at least 15m must be created around the dam, in order to enhance faunal and avifaunal breeding / foraging habitat as well as protection. • Areas earmarked for landscaping should consist of large fynbos gardens, with lawned areas kept to an absolute minimum. The use of Pennisetum clandestinum for lawns should be strictly prohibited.

Table 10: Impact assessment results for operational phase.

Alternatives Extent Intensity Duration Consequence Probability Significance Status Confidence Increased stormwater runoff Residential Long Alternative – Local Medium term Medium Definite Medium -ve High without (1) (2) (3) mitigation Residential Long Alternative – Local Low term Low Probable Low -ve Medium with (1) (1) (3) mitigation Increase in wetland biodiversity and function Residential Long Alternative – Local None term Very Low Definite Very Low +ve Medium without (1) (0) (3) mitigation Residential Long Alternative – Local Low Highly term Low Low +ve Medium with (1) (1) probable (3) mitigation

5.2. ‘No Go’ Scenario

Decades of anthropogenic activity within the proposed site has resulted in severe modification of the natural hydrological regime as well as transformation of the natural vegetation assemblage. As a result, an improvement of wetland EIS is considered to be unlikely without significant efforts to rehabilitate the site’s wetlands. Therefore, without development, alien grass species will persist, and will continue to suppress indigenous floral species within the larger portion of the proposed site. A low diversity, hardy wetland floral community will presumably remain dominant within the semi-degraded wetland habitat due to the soils remaining saturated for an extended period of time which prevents the proliferation and spread of the alien grass species within these areas. Given the site’s zoning and the current use of the abutting site for livestock grazing and horse paddocks there is a strong likelihood that should no development on the site be permitted that the site would also be used as grazing which would result in more significant impacts to the site’s freshwater features with particular reference to trampling of semi-degraded wetland habitat.

It is therefore highly likely that the current trend of modification of the site’s hydrology and degradation of the vegetation assemblage will continue in the long term should development of the site not prove feasible. This trend is rated to have a low (negative) significance impact.

Table 11: Impact assessment results for the ‘No Go’ Scenario.

Extent Intensity Duration Consequence Probability Significance Status Confidence Modification of wetland habitat from its natural reference condition Local Medium Long term Highly Medium Medium -ve High (1) (2) (3) probable

5.3. Indirect Impacts

No indirect impacts are deemed probable, provided that mitigation measures as listed for the direct impacts are adhered too.

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5.4. Cumulative Impacts

Cumulative impacts are impacts that result from the incremental impact of the proposed activity on freshwater systems within a greater catchment, ecoregion and wetland vegetation group when added to the impacts of other past, present or reasonably foreseeable future activities. The primary cumulative impacts in respect of the proposed development include: • Loss of wetland habitat. • Alteration of flow regime in the catchment. • Proliferation of alien vegetation in turn outcompeting indigenous vegetation.

The proposed construction of infrastructure within wetland habitat would add to the cumulative loss of wetland habitat from the region. However, the wetland habitat in its present state is no longer considered representative of the critically endangered Southwest Sand Fynbos wetland vegetation group (i.e. the loss of the site’s current wetland habitat will not increase the cumulative impact on this critically endangered wetland vegetation group). Furthermore, the rehabilitation and landscaping of remaining wetland areas within the proposed site could reduce the negative cumulative impact to some extent, or possibly have a positive cumulative impact as it would add to functional wetland habitat in the region which is more representative of the natural wetland vegetation type. The cumulative loss of wetland habitat in the Noordhoek area for fauna species (and in particular the Western Leopard Toad) has been addressed in the fauna specialist study. 6. Conclusion and Recommendation

The majority of the proposed site consists of severely degraded wetland habitat which has been impacted upon as a result of decades of anthropogenic activity and disturbance (21 611m2). This habitat is currently dominated by the alien grass species Pennisetum clandestinum and Stenotaphrum secundatum which are known to thrive in disturbed, moist soil conditions. However, three seeps, a dam and a central channel with an increased diversity and abundance of hydrophytes were also encountered within the proposed site which are considered to be semi-degraded wetland habitat and comprises approximately 3 900m2 of the site. There is no pristine wetland habitat on the proposed site.

Soil was investigated by means of hand augering (DWAF, 2008) in order to confirm the presence of wetland conditions within the areas currently dominated by alien grass species. Indicators of hydromorphic soils35 were identified within most of the areas investigated and it was therefore concluded that the entire proposed site can be considered wetland habitat. Therefore, in its present condition the entire proposed site is considered a watercourse and any development within the proposed site will require Environmental Authorisation in terms of the NEMA Environmental Impact Assessment Regulations (2014) as well as authorisation from DWS in terms of Section 21 (c) and (i) of the NWA.

The PES of wetland features was determined assuming that the entire site consisted of one extensive seep wetland, prior to disturbance and transformation taking place. The calculated score, including the severely degraded wetland habitat and the seeps, dam and channel, falls within a PES Category E. However, the severely degraded wetland habitat was calculated to be of a low EIS while the seeps, dam and central channel (considered to be semi-degraded) were calculated to be of a high EIS. This high EIS rating was primarily as a result of the value of the site as important habitat for the endangered Amietophrynus pantherinus (Western Leopard Toad).

Two development alternatives have been proposed, namely the Applicants Preferred Alternative and the Residential Alternative. In summary, the Applicants Preferred Alternative involves the development of a school for approximately 600 learners and rehabilitation of the high EIS wetland areas, in addition a wetland corridor will be created along the eastern boundary of the proposed site. The Residential Alternative, involves the construction of 6 residential units with associated infrastructure. The dam and the central channel will be conserved and all other wetland habitat will be infilled.

The infilling of some of the high EIS wetland habitat as well as all low EIS wetland habitat required as part of the Residential Alternative was rated to be of high (negative) significance and no practical mitigation measure can be implemented in order to reduce the impact significance. Two additional direct impacts were

35 A soil that, in its undrained condition, is saturated or flooded long enough to develop anaerobic conditions favouring the growth and regeneration of hydrophytic vegetation (vegetation adapted to living in anaerobic soils).

Freshwater Assessment: Generation School March 2017 KHULA Environmental Consultants Page 44 assessed, one negative due to possible sedimentation of remaining wetland habitat and one positive following landscaping. The negative impact can be reduced to a very low significance, with the implementation of mitigation measures and it is deemed possible to increase the positive significance of the second impact with the implementation of the provided environmentally sensitive landscape recommendations.

The loss of degraded wetland habitat required for the construction of the Applicants Preferred Alternative was rated to be of medium (negative) significance and as with the Residential Alternative there would be no practical mitigation that could lower significance of this impact. However, it is considered possible to reduce the negative impact significance of all other construction and operational direct impacts to a low or very low level, with the implementation of mitigation measures. Impact relating to the increase of wetland biodiversity and function was rated to be of medium (positive) significance, provided that rehabilitation and management are successful long term.

It is highly likely that the current trend of modification of the site’s hydrology and degradation of the vegetation assemblage will continue in the long term should development of the site not prove feasible. There is also the potential of the site being used for livestock grazing which could result in additional impact on semi-degraded wetland habitat. This trend was rated to have a low (negative) significance impact.

The layout and design of the proposed school as per the Applicants Preferred Alternative has accommodated both the mitigation measures recommended in this report as well as those of the faunal specialist and as such it is the opinion of the specialist that wetland biodiversity and function36 can be increased with the development of this alternative to the extent that, despite the reduction in wetland area, a net gain in wetland function and wetland service provision is achieved. It is therefore the opinion of the specialist that authorisation for the development of the Applicants Preferred Alternative, from a freshwater ecological perspective may be granted, provided that all essential mitigation measures listed within this report as well as the faunal specialist report are strictly adhered too. 7. References

Bromilow, C. 2010. Revised Edition, First Impression. Problem Plants of South Africa. Briza Publications, Pretoria, RSA. City of Cape Town, 2016. City of Cape Town Biodiversity Network 2016. Available from the Biodiversity GIS website. City of Cape Town, 2016. City of Cape Town Wetlands 2014. Available from the Biodiversity GIS. Dada, R., Kotze D., Ellery W. and Uys M. 2007. WET-RoadMap: A Guide to the Wetland Management Series. WRC Report No. TT 321/07. Water Research Commission, Pretoria. De Villiers, C., Driver, A., Clark, B., Euston-Brown, D., Day, L., Job, N., Helme, N., Van Ginkel, CE., Glen, RP., Gordon-Gray, KD., Cilliers, CJ., Muasya, M and van Deventer, PP. 2011. Easy identification of some South African Wetland Plants. WRC Report No TT 479/10, Water Research Commission, Pretoria, RSA Department of Environmental Affairs. DEA National Landcover (TIFF) 2015 [Raster] 2015. Department of Water Affairs and Forestry. 1999. Resource Directed Measures for Protection of Water Resources. Volume 3: River Ecosystems Version 1.0, Pretoria. Department of Water Affairs and Forestry 2005. A practical field procedure of identification and delineation of wetlands and riparian areas. DWA, Pretoria, RSA. Department of Water Affairs and Forestry. 2008. Updated Manual for the Identification and Delineation of Wetlands and Riparian Areas, prepared by M. Rountree, A. L. Batchelor, J. MacKenzie and D. Hoare. Stream Flow Reduction Activities, Department of Water Affairs and Forestry, Pretoria, South Africa. Du Preez, L. and Carruthers, V. 2009. A complete guide to the frogs of Southern Africa. Struik Nature, Cape Town.

36 Note that faunal impact with special mention of Amietophrynus pantherinus (Western leopard toad) has been considered within the faunal impact assessment report.

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Esler, K.J, Pierce, S.M. and de Villiers, C. 2014. Fynbos: Ecology and Management. Briza Publications, Pretoria. Google Earth 2015. 34° 5'59.09"S, 18°22'51.80"E, elevation 47M. Roads data layer. [Viewed July 2016]. Holmes, P., Brownlie, S., Robelo, T. 2005. Fynbos Forum Ecosystem Guidelines for Environmental Assessment in the Western Cape. Fynbos Forum and Botanical Society of South Africa, Kirstenbosch, Cape Town Holmes P, Stipinovich A and Purves A. 2012, updated 2015. City of Cape Town's Biodiversity Network: Methods and Results - Technical Report (C-Plan & Marxan Analysis). City of Cape Town, South Africa. Job, N. 2009. Application of the Department of Water Affairs and Forestry (DWAF) wetland delineation method to wetland soils of the Western Cape. Kirkwood, D., Pence, G.Q.K. & von Hase, A. 2010 Western Cape Biodiversity Framework: Critical Biodiversity Areas and Ecological Support Areas of the Western Cape. A C.A.P.E. Land-use planning project. Unpublished Project Report. Kleynhans, C.J., Thirion, C. and Moolman, J. 2005. A Level I River Ecoregion Classification System for South Africa, Lesotho and Swaziland. Report No. N/0000/00/REQ0104. Resource Quality Services, Department of Water Affairs and Forestry, Pretoria, South Africa. Kotze, D.C., Marneweck, G.C., Batchelor, A.L., Lindley, D.S., and Collins, N.B., 2007. Wet-EcoServices: A technique for rapidly assessing ecosystem services supplied by wetlands. WRC Report No TT 339/09, Water Research Commision, Pretoria. Kotze, D., Ellery, W., Rountree, M., Grenfell, M., Marneweck, G., Nxele, I., Breen, C., Dini, J., Batchelor, A., Sieben, E. 2009. WET-RehabPlan. Guidelines for planning wetland rehabilitation in South Africa. WRC Report TT 336/09. Water Research Commision, Pretoria Macfarlane, D.M. and Bredin, I.P. 2016. Buffer zone guidelines for rivers, wetlands and estuaries. Part 1: Technical Manual. WRC Report No (tbc), Water Research Commission, Pretoria. Macfarlane, D.M. and Bredin, I.P. 2016. Buffer zone guidelines for rivers, wetlands and estuaries. Part 2: Practical Guide. WRC Report No (tbc), Water Research Commission, Pretoria. Macfarlane, D.M., Kotze, D.C., Ellery, W.N., Walters, D., Koopman, V., Goodman, P. and Goge, C. 2007. WET-Health: A technique for rapidly assessing wetland health. WRC Report No TT 340/09, Water Research Commision, Pretoria. Macfarlane, D., Holness, S.D., von Hase, A., Brownlie, S. & Dini, J., 2014. Wetland offsets: a best practice guideline for South Africa. South African National Biodiversity Institute and the Department of Water Affairs. Pretoria. Manning, J. 2007. Field Guide to Fynbos. Struik Nature, Cape Town. Mucina, L. and Rutherford, M.C. (EDS.). 2006. The vegetation of South Africa, Lesotho and Swaziland. Strelitizia 19. South African National Biodiversity Institute, Pretoria, South Africa. Nel, JL, Driver, A., Strydom W.F., Maherry, A., Petersen, C., Hill, L., Roux, D.J, Nienaber, S., Van Deventer, H., Swartz, E. & Smith-Adao, L.B. 2011a. Atlas of Freshwater Ecosystem Priority Areas in South Africa: Maps to support sustainable development of water resources. Water Research Commission Report No. TT 500/11, Water Research Commission, Pretoria, RSA. Ollis, D.J., Day J.A., Malan, H.L., Ewart-Smith J.L., and Job N.M. 2014 Development of a decision-support framework for wetland assessment in South Africa and a decision-support protocol for the rapid assessment of wetland ecological condition. WRC Report No. TT 609/14 Ollis, D.J., Snaddon, C.D., Job, N.M. and Mbona, N. 2013 Classification System for Wetlands and other Aquatic Ecosystems in South Africa. User Manual: Inland Systems. SANBI Biodiversity Series 22. South African National Biodiversity Institute, Pretoria. Pence, Genevieve Q.K. 2008. C.A.P.E. Fine-Scale Systematic Conservation Planning Assessment: Technical Report. Produced for CapeNature as part of the GEF-funded C.A.P.E. Fine-Scale Biodiversity Planning Project. Cape Town, South Africa. Pence, G Q.K. 2014. Western Cape Biodiversity Framework 2014 Status Update: Critical Biodiversity Areas of the Western Cape. Unpublished CapeNature project report. Cape Town, South Africa.

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Rountree, M.W., Malan, H.L., Weston, B.C. 2013. Manual for the Rapid Ecological Reserve Determination of Inland Wetlands (Version 2.0). WRC Report No. 1788/1/12 Rowntree, K.M., Wadeson, R.A. and O’Keeffe, J. 2000. The Development of a Geomorphological Classification System for the Longitudinal Zonation of South African Rivers. Russel, W.B., 2009. WET-Rehab Methods. National guidelines and methods for wetland rehabilitation. WRC Report No 341/09. Water Research Commission, Pretoria. The South African National Biodiversity Institute - Biodiversity GIS (BGIS) [online]. URL: http://bgis.sanbi.org. Van Oudtshoorn, F. 2004. Second Edition, Third Print. Guide to Grasses of South Africa. Briza Publications, Pretoria, RSA.

Appendix 1 – Impact Assessment Criteria

The significance of an impact was defined as a combination of the consequence of the impact occurring and the probability that the impact will occur. The criteria used to determine impact consequence are presented in Table 12 below.

Table 12: Criteria used to determine the consequence of the impact. Rating Definition of Rating Score A. Extent – the area over which the impact will be experienced. None 0 Local Confined to project or study area or 1 part thereof (e.g. site) Regional The region, which may be defined in 2 various ways, e.g. cadastral, catchment, topographic (Inter) national Nationally or beyond 3 B. Intensity – the magnitude of the impact in relation to the sensitivity of the receiving environment None 0 Low Natural and/or social functions and 1 processes are negligibly altered Medium Natural and/or social functions and 2 processes continue albeit in a modified way High Natural and/or social functions or 3 processes are severely altered C. Duration – the time frame for which the impact will be experienced None 0 Short-term Up to 2 years 1 Medium-term 2 to 15 years 2 Long-term More than 15 years 3

The combined score of these three criteria corresponds to a Consequence Rating, as set out in Table 13.

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Table 13: Method used to determine the consequence score. Combined 0-2 3-4 5 6 7 8-9 Score (A+B+C) Consequence Not significant Very low Low Medium High Very high Rating

Once the consequence was derived, the probability of the impact occurring was considered, using the probability classification presented in Table 14.

Table 14: Probability classification. Probability of impact – the likelihood of the impact occurring Improbable <40% chance of occurring Probable 40% - 70% chance of occurring Highly probable >70% - 90% chance of occurring Definite >90% chance of occurring

The overall significance of the individual impacts was determined by considering consequence and probability using the rating system as prescribed in Table 15.

Table 15: Impact significance rating. Significance Rating Consequence Probability Insignificant Very Low & Improbable Very Low & Possible Very Low Very Low & Probable Very Low & Definite Low & Improbable Low & Possible Low Low & Probable Low & Definite Medium & Improbable Medium & Possible Medium Medium & Probable Medium & Definite High & Improbable High & Possible High High & Probable High & Definite Very High & Improbable Very High & Possible Very High Very High & Probable Very High & Definite

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The impacts were also considered in terms of their status (positive or negative impact) and the confidence in the ascribed impact significance rating. The prescribed system for considering impact status and confidence (in assessment) is laid out in Table 16.

Table 16: Impact status and confidence classification. Status of impact +ve (positive – a benefit) Indication whether the impact is adverse (negative) or -ve (negative – a cost) beneficial (positive). Neutral Confidence of assessment Low The degree of confidence in predictions based on available Medium information, judgement and knowledge. High

The impact significance rating should be considered by the authority in their decision making process based on the implications of ratings described below: • Insignificant: the potential impact is negligible and will not have an influence on the decision regarding the proposed activity/development. • Very Low: the potential impact should not have any meaningful influence on the decision regarding the proposed development/activity. • Low: the potential impact may not have any meaningful influence on the decision regarding the proposed development/activity. • Medium: the potential impact should influence the decision regarding the proposed development/activity. • High: the potential impact will influence the decision regarding the proposed development/activity. • Very High: The proposed activity should only be approved under special circumstances.

In the impact assessment practicable mitigation measures will be recommended and impacts rated in the prescribed way both without and with the assumed effective implementation of mitigation measures.

Mitigation measures provided are either: • Essential: must be implemented (as they minimise potential significant negative impacts) and are non-negotiable. • Optional / Recommended: “nice to have’s” as they do little to minimise a key potentially significant impact and or improve benefits.

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