Draft Basic Assessment Report for the Proposed Westville

Triangle Housing Development, eThekwini Municipality

Report Prepared for

Woodglaze Trading (Pty) Ltd.

Report Number 496762/DBAR-01

Report Prepared by

November 2020

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Draft Basic Assessment Report for the Proposed Westville Triangle Housing Development, eThekwini Municipality

Woodglaze Trading (Pty) Ltd.

SRK Consulting (South Africa) (Pty) Ltd. Section A Second Floor, Suite 02/B1 Norfolk House 54 Norfolk Terrace, off Blair Atholl Drive Westville 3630 South Africa

e-mail: @srk.co.za website: www.srk.co.za

Tel: +27 (0) 31 279 1200 Fax:+27 (0) 31 279 1204

SRK Project Number 496762

November 2020

Compiled by: Reviewed by:

Mrs T. Hale Cert. EAP Pr. Sci. Nat. Mr. M. van Huyssteen Senior Environmental Scientist Partner

Email: [email protected] Authors: T. Hale

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INTERESTED AND AFFECTED PARTIES (I&AP) ARE INVITED TO REVIEW THIS REPORT AND SUBMIT COMMENTS TO TAMARYN HALE OF SRK CONSULTING (TEL: 031 279 1200; EMAIL: [email protected]; FAX: 031 279 1204)

Executive Summary a) Introduction Woodglaze Trading (Pty) Ltd. (Woodglaze Trading) are proposing the construction of the Westville Triangle Housing Development in Ward 30 of the eThekwini Municipality (Error! Reference source not found. in Section 3 provides a locality map of the proposed project).

b) Listed Activities In terms of the Environmental Impact Assessment (EIA) Regulations, 2014 (as amended in Government Notice (GN) 326 of 07 April 2017), the following trigger activities are applicable:

• NEMA EIA Listing Notice 1 (GN 327) – listed activity No. 27. • NEMA EIA Listing Notice 3 (GN 324) – listed activity No. 4d.viii, 12d.v and 14(ii)(a)d.vii.

An application for Environmental Authorisation via a Basic Assessment (BA) process is required.

c) Project Description

Woodglaze Trading proposes to develop approximately 300 residential housing units at Westville Triangle, KwaZulu-Natal. The proposed development includes apartments that consist of two- and three-storey walk-up blocks accommodating 2-bedroom apartments on each floor (92 units in total) and 208 semi-detached, double-storey units. The following infrastructure and services will form part of the development:

• Two (2) tarred access roads with internal roads 8 m, 12 m and 16 m wide. • Two (2) community facilities. • Recreation facilities including: a sports field; a basketball court, a tennis court; fifteen (15) play areas and three (3) water features. • Parking areas (1.5 per unit). • Open space areas. • Services to include: electricity, water and sewer connections, and stormwater infrastructure. The project site is located within Ward 30 of the eThekwini Metropolitan Municipality, within the Inner West Region of the Municipality, in the suburb of Berea-West in Westville. The project site is bordered by the M13 King Cetswayo Highway to the north, the National Road to the east and the to the south.

The site is approximately 20.9 hectares in extent with the area to be developed approximately 17.5ha. The Applicant, Woodglaze Trading, is the owner of the properties.

The centre coordinate of the site is: 29°36'46.05"S; 31°03'18.77"E.

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d) Impact Identification

An impact assessment process was undertaken to identify the aspects and potential impacts. The potential significant impacts identified for the proposed Westville Triangle Housing Project include:

• Construction Phase: - Traffic. - Loss of biodiversity. - Aquatic and wetland impacts. - Employment (opportunities). - Construction nuisance impacts. • Operational Phase: - Traffic. - Alien plant invasion. - Increased run-off. - Aquatic and wetland impacts. - Pollution of water resources. - Employment (opportunities).

e) Specialist studies

The following specialist studies were undertaken: 1) Traffic Impact Assessment The Traffic Impact Assessment (TIA) notes that traffic impacts of new developments are concentrated on the immediate transportation network with these impacts dissipating rapidly further away from the development as more access opportunities become available and traffic disperses onto the broader road network. As such the assessment focused on the following roads and intersections that will be used to access the site:

• Konigkramer Avenue and Essex Terrace. • Coventry Road and Essex Terrace. • Warspite Road and Essex Terrace. Traffic counts where undertaken on 13 November 2019. The morning peak period (07:00 – 08:00) and afternoon peak period (16:00 – 17:00) was assessed and it was assumed that most of the commuters will be utilizing private vehicles. The assessment extended for a 5-year period until 2024.

2) Vegetation and Wetland Assessment 2.1 Vegetation

The main vegetative habitat units across the site include:

• Dense woody vegetation. • Open scrublands. • Secondary grasslands. • Wetland habitat. A summary of the Ecological Importance and Sensitivity (EIS) of the vegetation habitats assessed in the project area is presented in Table ES-1.

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Table ES-1: Summary of the Ecological Importance and Sensitivity of vegetation

Vegetation habitat Condition Threat Status Sensitivity Dense woody vegetation Very Poor Low Concern Low Open scrublands Poor Low Concern Low Secondary grassland Poor Critically Endangered Moderate

Wetland habitat Good Critically Endangered High

When the physical site findings, in relation to vegetation, are considered against relevant legislation and the EKZNW CPLAN, the vegetation within the property is transformed and does not support key biodiversity features that would qualify it as a Critical Biodiversity Area.

No plant species of conservation concern were encountered within the property during the site assessment by the vegetation specialist. The only vegetation habitat occurring within the property that is of conservation concern is the wetland habitats.

2.2 Wetlands

The wetlands on site were delineated based on three indicators, namely terrain, wetland vegetation and soil. The Terrain Indicator (TI) Areas identified are as follows:

• TI Area A – Hydro-geomorphic (HGM): Hillslope seepage (seep) (HGM A). • TI Area B – HGM: Channelled valley bottom (HGM B). • TI Area C: Since wetland vegetation and wetland soil indicators are not representative of wetland habitat, TI Area C (this is referred to as the Recommended Limited Development Zone in this report) did not qualify as a wetland and therefore no HGM unit has been assigned to it1. In line with the SANBI national classifications system, water inputs for both HGM Units are primarily due to flows emanating from up-slope discharge. Water movement through the seep is mainly in the form of diffuse sub-surface flow, often during the rainy season whereas the channelled valley bottom primarily receives inflows from a channel near the site and gentle slopes.

A Level 1 Wetland Health Assessment was conducted on the wetlands identified (i.e. HGM A and HGM B) and both HGM units were categorised as PES Category D, which is associated with a largely modified wetland system. Changes to the functionality (hydrology, geomorphology and vegetation) and integrity of the wetlands include:

• Obstruction of the flow by the existing road (M13). • Pollution (plastic, cardboard, tins) within the permanent zone of saturation of the wetland. • Infestation of alien invasive vegetation. A Level 2 WET-EcoServices assessment was undertaken for the HGM A and B wetlands, the results are detailed in Table ES-2.

Table ES-2: Results of the Level 2 WET-EcoServices assessment on HGM A and B

HGM Main eco-services provided HGM A (seep wetland) • Sediment trapping. • Streamflow regulation. • Erosion control. • Phosphate, nitrate and toxicant trapping. • Carbon storage.

1 Although TI Area C is not characterised as a wetland or a watercourse, it is identified as an area where stormwater management and control interventions could potentially be incorporated into the design layout of the proposed development.

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HGM Main eco-services provided HGM B (channelled valley bottom wetland) • Flood attenuation. • Streamflow regulation. • Phosphate, nitrate and toxicant trapping. • Erosion control (to a larger extent). • Carbon sequestration. • Maintenance of biodiversity. • Water supply for humans. The Ecological Importance and Sensitivity (EIS) of both the wetland units were recorded as being Low. This is due to the largely degraded nature of the wetland systems sedimentation, presence of alien invasive species, and pollution. Despite this, some natural vegetation was observed in clumps around the wetland and this provides natural habitat for varying faunal species (reptiles, amphibians and birds). Surface water was also observed in the permanent zones of saturation of both wetlands increasing the likelihood of these wetlands being used by faunal species for breeding, feeding and protection.

The Preliminary Guideline for the Determination of Buffer Zones for Rivers, Wetlands and Estuaries (WRC, 2015) was used for the determination of buffer zones associated with the channelled valley bottom wetland and seep, in relation to the proposed development. The buffer width serves to protect the ecosystem services provided by the two wetlands. The results showed that a 30m buffer is appropriate for the protection of the channelled valley bottom wetland, as well as the seep wetland.

In addition, the development footprint within TI Areas C is likely to be limited by the presence of a network of ephemeral drainage lines resulting from upslope stormwater discharge. A comprehensive stormwater design shall be required to accommodate intermittent flows associated with the ephemeral drainage lines.

3) Heritage Impact Assessment Following a desktop survey of existing literature on the general History and Archaeology of the area, a field survey was carried out on 21 September 2009. Ground visibility was relatively clear, although in some places restricted as the result of dense overgrowth, mainly due to alien invaders.

The results of the specialist investigation concluded that no remains of the Stone or Iron Ages were observed, no declared Heritage Sites (former National Monuments) are in close vicinity to the site and no buildings occur on the site.

In April 2019, the heritage specialist provided a letter confirming that it is not anticipated that the development will have any influence on cultural heritage resources in the area. Archaeological deposits are most unlikely. 4) Impact Assessment

A summary of the positive and negative impacts of the proposed activity is provided in Table ES-3.

Table ES-3: Summary of impact significance ratings for the proposed

Impact Before/After Consequence Probability Significance mitigation T1-1: Additional traffic will be Before 10 5 50 (moderate) generated on the existing road network mitigation: and may affect the level of service After mitigation: 6 2 12 (low) T1-2: Additional traffic will be Before 8 3 24 (low) generated on the existing road network mitigation: and may affect the level of service After mitigation: 8 3 24 (low)

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Impact Before/After Consequence Probability Significance mitigation T2-1: Additional traffic will be Before 5 1 5 (low) generated that may affect the space mitigation: available for pedestrian and cyclist movement After mitigation: 5 1 5 (low) B1-1: Construction activities involve Before 14 5 70 (high) removal of indigenous vegetation, mitigation: which provides an area for alien plant establishment and infestation with a After mitigation: resultant loss of biodiversity and 9 4 36 (moderate) potential reduction in the functionality of the wetland B1-2: Disturbance linked to the human Before 14 5 70 (high) presence and activities in the wetland mitigation: area is likely to result in opportunities for alien plants to recolonise any After mitigation: rehabilitated areas with the resultant increase in competition and potential replacement of indigenous species 8 4 24 (low) causing the alteration of indigenous species composition across the site and vegetation structure of the wetland B2-1: Disruption of surface flows Before 17 5 85 (high) feeding the wetlands on site could mitigation: cause erosion and the resultant sedimentation of the wetlands After mitigation: 10 4 40 (moderate) B2-2: An increase in post-development Before 17 5 85 (high) runoff as a result of increased mitigation: hardened surfaces could result in decreased infiltration capacity and an After mitigation: increase in stormwater runoff, which 12 3 36 (moderate) may cause erosion and sedimentation of the wetlands on site B3-1: Accumulation of sediment in the Before 14 5 70 (high) wetland as a result of construction mitigation: activities could eventually lead to the After mitigation: alteration of the geomorphological 9 3 27 (low) integrity of the wetlands B3-2: Accumulation of sediment in the Before 17 5 85 (high) wetland as a result of uncontrolled run- mitigation: off could eventually lead to the After mitigation: alteration of the geomorphological 12 3 36 (moderate) integrity of the wetlands B4-1: Pollution of water resources on Before 15 5 75 (high) site through mismanagement of waste mitigation: and pollutants during construction activities After mitigation: 9 4 36 (moderate) B4-2: Pollution of water resources Before 15 5 75 (high) mitigation: After mitigation: 10 3 30 (moderate) Before H1: Construction activities involve 5 1 5 (low) earth moving that may unearth mitigation: archaeological sites After mitigation: 5 1 5 (low) SE1-1: Employment opportunities Before & after created during construction activities mitigation: potentially result in improvement in 11 5 55 (moderate) quality of life (NOTE: this is a positive impact)

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Impact Before/After Consequence Probability Significance mitigation SE2: Injury and/or loss of life to people Before 13 5 65 (high) working on the site, people residing in mitigation: close proximity and people passing After mitigation: through/by the site as a result of 7 2 14 (low) construction activities SE3: Noise from construction activities Before 10 5 50 (moderate) could potentially cause a nuisance to mitigation: the surrounding residents residing in the area After mitigation: 11 2 22 (low) SE4: Deterioration in air quality from Before 10 5 50 (moderate) dust that may be created through the mitigation: construction process and fires on-site After mitigation: 11 2 22 (low) 5) Environmental Impact Statement

In accordance with Item 3(1)(p) in Appendix 1 of GN 326, this chapter provides a reasoned opinion as to whether the proposed activity should or should not be authorised, and recommended conditions that should be made in respect of that authorisation.

Although SRK is not an elected entity mandated to make decisions on behalf of society, we hereby provide a qualified opinion. In this regard, SRK is of the opinion that this BA Report, EMPr and the attached specialist reports comply with the relevant guidelines and contain all the information required in terms of GN 326 to enable EDTEA to take a decision.

The fundamental decision is whether to allow development that brings socio-economic advantages and is consistent with planning and development policies, given the potential environmental impacts. In this case, identified potential negative impacts arising from the proposed Westville Triangle Housing Project can be managed to remain within acceptable environmental limits so long as measures set out in the EMPr are implemented.

It is noted that the stormwater management plan was not available at the time of the assessment of potential impacts. This has therefore been excluded from this assessment. Based on the specialist input, however, it is recommended that the final stormwater management plan is submitted to, and approved by the EDTEA and the DHSWS prior to commencement of construction.

SRK believes that the specialist studies have confirmed that the preferred layout alternative (as presented in Figure 5-1) is environmentally acceptable. The EMPr stipulates the mitigation measures identified that will mitigate the potential impacts identified to within acceptable limits. In conclusion, SRK is of the opinion that on purely ‘environmental’ grounds (i.e. the project’s potential socio-economic and biophysical implications) the application, as it is currently articulated in this BA Report, should be approved (i.e. for the development footprint as indicated in Figure 5-1). This statement is conditional on implementation of the mitigation measures stipulated in the EMPr. These measures include undertaking further investigations and monitoring during the remaining project phases and the operational phase. The results of the investigations and monitoring may result in refinement of certain environmental measures and provisions.

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Table of Contents

Executive Summary ...... ii Disclaimer ...... xii List of Abbreviations ...... xiii 1 Introduction ...... 1 1.1 Basic Assessment Process Objectives ...... 2 1.2 Scope of Assessment and Content of BA Report ...... 2 2 Environmental Assessment Practitioner ...... 5 3 Project Location ...... 5 4 Site Overview ...... 7 4.1 Climate ...... 7 4.2 Topography ...... 8 4.3 Geology and Soils ...... 8 4.4 Vegetation ...... 8 4.5 Water Resources ...... 12 4.6 Land use and zoning of the site and surrounding area...... 14 4.7 Socio-economic Setting ...... 14 4.8 Heritage Resources ...... 15 5 Project Description ...... 15 5.1 Overview of Layout Plan ...... 17 5.2 Services ...... 18 5.3 External and Internal Access ...... 18 5.4 Housing Unit Typologies ...... 19 5.4.1 Apartment Development...... 19 5.4.2 Duplex Development ...... 19 5.5 Amenities and Facilities ...... 19 5.6 Natural Environment and Vegetation ...... 19 5.7 Parking ...... 19 6 Policy and Legislative Context ...... 19 6.1 South African Constitution ...... 19 6.2 Environmental Management ...... 20 6.3 Water Management...... 21 6.4 Biodiversity Management ...... 22 6.5 Heritage Management ...... 24 6.6 National Environmental Screening Tool ...... 24 6.7 Other Legislation, Policies and Guidelines ...... 25 7 Project Need and Desirability ...... 25 8 Project Alternatives ...... 27

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8.1 Property / Site Location Alternatives ...... 27 8.2 Type of Activity Alternatives ...... 27 8.3 Design or Layout Alternatives ...... 27 8.4 Technology Alternatives ...... 30 8.5 Operational Alternatives ...... 30 8.6 No-go Alternative ...... 30 9 Public Participation ...... 30 9.1 Pre-application meeting ...... 30 9.2 Identification of interested and affected parties ...... 31 9.3 Project Announcement ...... 31 9.3.1 Background Information Document (BID) ...... 31 9.3.2 Site notices ...... 31 9.3.3 Advertisements ...... 32 9.4 Distribution of Draft Basic Assessment Report ...... 33 9.5 Key Stakeholder Meetings ...... 33 9.6 Public Meeting ...... 33 9.7 Summary of I&AP Issues Raised ...... 34 10 Identification and assessment of potential environmental impacts ...... 41 10.1 Impact assessment methodology ...... 41 10.1.1 Ranking scales ...... 42 10.1.2 Reversibility ...... 42 10.1.3 Irreplaceable Loss ...... 43 10.2 Traffic 43 10.2.1 Baseline Description ...... 43 10.2.2 Impact Assessment ...... 43 a) Impact T1 – Impact on the Existing Traffic Conditions ...... 44 b) Impact T2 – Impact on Existing Public Transport ...... 45 10.3 Biodiversity ...... 45 10.3.1 Baseline Description ...... 45 a) Vegetation ...... 45 b) Wetlands...... 46 10.3.2 Impact Assessment ...... 47 a) Impact B1 – Vegetation ...... 47 b) Impact B2 – Hydrology ...... 48 c) Impact B3 – Geomorphology impacts ...... 50 d) Impact B4 – Water quality impacts ...... 52 10.4 Heritage ...... 53 10.4.1 Baseline Description ...... 53 10.4.2 Impact Assessment ...... 53 10.5 Socio-economic ...... 54 10.5.1 Baseline Description ...... 54

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10.5.2 Impact Assessment ...... 54 a) Impact SE1 – Employment opportunities ...... 54 b) Impact SE2 – Health and safety ...... 55 c) Impact SE3 – Noise ...... 56 d) Impact SE4 – Air quality ...... 56 10.6 Cumulative Impacts...... 57 10.6.1 Traffic...... 57 10.6.2 Biodiversity ...... 57 11 Environmental Management Programme ...... 57 12 Environmental Impact Statement ...... 57 12.1 Impact Summary ...... 58 12.2 Recommended Conditions of Authorisation ...... 60 13 Assumptions, Limitations and Deviations ...... 60 14 EAP Affirmation ...... 60 Appendices ...... 62 Appendix A: Environmental Assessment Practitioner Curriculum Vitae and Declaration of Interest ...... 63 Appendix B: Maps...... 64 Appendix C: Construction Environmental Management Programme (EMPr) ...... 65 Appendix D: Letter Confirming Ownership ...... 66 Appendix E: Public Participation Record ...... 67 Appendix F: Specialist Investigations ...... 68 Appendix G: National Environmental Screening Tool ...... 69

List of Tables Table 1-1: Objectives of the BA Process (Appendix 1 of GN 326, 07 April 2017) ...... 2 Table 1-2: Legislated requirements for the content of an BA Report ...... 2 Table 2-1: SRK team involved with the BA process and compiling the BA Report ...... 5 Table 3-1: Property description ...... 7 Table 6-1: Applicable NEMA Listed Activities ...... 20 Table 6-2: National Environmental Screening tool – identified specialist studies ...... 24 Table 9-1: Comments received from I&AP and responses provided ...... 35 Table 10-1: Impact ranking scales ...... 42 Table 10-2: Impact T1-1: Impact on Existing Traffic Conditions during Construction ...... 44 Table 10-3: Impact T1-2: Impact on Existing Traffic Conditions during Operation ...... 44 Table 10-4: Impact T2-1: Impact on Existing Public Transport ...... 45 Table 10-5: Summary of the Ecological Importance and Sensitivity of vegetation ...... 46 Table 10-6: Results of the Level 2 WET-EcoServices assessment on HGM A and B ...... 47 Table 10-7: Impact B1-1: Disturbance of vegetation during Construction ...... 48

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Table 10-8: Impact B1-2: Disturbance of vegetation during Operation ...... 48 Table 10-9: Impact B2-1: Surface flow disruption during Construction ...... 49 Table 10-10: Impact B2-2: Disturbance of hydrological processes during operation ...... 50 Table 10-11: Impact B3-1: Alteration of geomorphological integrity of wetland during Construction ...... 51 Table 10-12: Impact B3-2: Alteration of geomorphological integrity of wetland during operation ...... 51 Table 10-13: Impact B4-1: Pollution of water resources during Construction ...... 52 Table 10-14: Impact B4-2: Pollution of water resources during operation ...... 53 Table 10-15: Impact H1: Disturbance of archaeological sites during Construction ...... 54 Table 10-16: Impact SE1-1: Employment opportunities during Construction ...... 55 Table 10-17: Impact SE1-2: Employment opportunities during Operation ...... 55 Table 10-18: Impact SE2: Health and safety during Construction ...... 55 Table 10-19: Impact SE3: Noise during Construction ...... 56 Table 10-20: Impact SE4: Air quality during Construction ...... 56 Table 12-1: Impact Assessment Summary ...... 58 List of Figures Figure 1-1: Overview of the Basic Assessment process ...... 1 Figure 3-1: Locality map ...... 6 Figure 4-1: Underlying geology of the site ...... 9 Figure 4-2: Vegetation habitats on site ...... 10 Figure 4-3: Ezemvelo KZN Wildlife Terrestrial Systematic Conservation Plan ...... 11 Figure 4-4: Water resources within the site and surrounding area ...... 13 Figure 5-1: Project layout plan (refer to Appendix B for an enlarged version) ...... 16 Figure 6-1: Location of proposed site in relation to D’MOSS designated areas ...... 23 Figure 8-1: Alternative layout plan ...... 29 Figure 9-1: Contents of site notices placed ...... 32

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Disclaimer The opinions expressed in this Report have been based on the information supplied to SRK Consulting (South Africa) (Pty) Ltd. (SRK) by Woodglaze Trading (Pty) Ltd. (Woodglaze Trading). The opinions in this Report are provided in response to a specific request from Woodglaze Trading to do so. SRK has exercised all due care in reviewing the supplied information. Whilst SRK has compared key supplied data with expected values, the accuracy of the results and conclusions from the review are entirely reliant on the accuracy and completeness of the supplied data. SRK does not accept responsibility for any errors or omissions in the supplied information and does not accept any consequential liability arising from commercial decisions or actions resulting from them. Opinions presented in this report apply to the site conditions and features as they existed at the time of SRK’s investigations, and those reasonably foreseeable. These opinions do not necessarily apply to conditions and features that may arise after the date of this Report, about which SRK had no prior knowledge nor had the opportunity to evaluate.

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List of Abbreviations BA Basic Assessment

BAR Basic Assessment Report

BID Background Information Document

CBA Critical Biodiversity Area

CPLAN Terrestrial Systematic Conservation Plan

DEA Department of Environmental Affairs

DWS Department of Water and Sanitation

EA Environmental Authorisation

EAP Environmental Assessment Practitioner

ECA Environmental Conservation Act, 1989 (Act No. 73 of 1989)

EIS Ecological Importance and Sensitivity

EKZNW Ezemvelo KwaZulu-Natal Wildlife

EIA Environmental Impact Assessment

EIS Ecological Importance and Sensitivity

EMPr Environmental Management Programme

GA General Authorisation

I&AP Interested and Affected Parties

KZN KwaZulu-Natal

NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998)

NEM: AQA National Environment Management: Air Quality Act, 2004 (Act No. 39 of 2004)

NEM: BA National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004)

NEM: WA National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008)

NFEPA National Freshwater Ecosystem Priority Area

NWA National Water Act, 1998 (Act No.36 of 1998)

PES Present Ecological State

PPP Public Participation Process

WUL Water Use Licence

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1 Introduction Woodglaze Trading (Pty) Ltd. (Woodglaze Trading) are proposing the construction of the Westville Triangle Housing Development in Ward 30 of the eThekwini Municipality (Error! Reference source not found. in Section 3 provides a locality map of the proposed project). In terms of the Environmental Impact Assessment (EIA) Regulations, 2014 (as amended in Government Notice (GN) 326 of 07 April 2017), an application for Environmental Authorisation via a Basic Assessment (BA) process is required. An overview of the BA process is provided in Figure 1-1.

SRK Consulting (South Africa) (Pty) Ltd (SRK) has been appointed as the independent Environmental Assessment Practitioner (EAP) to undertake the required BA Process on behalf of Woodglaze Trading for the proposed project.

This document constitutes the Draft BA Report.

WESTVILLE TRIANGLE BASIC ASSESSMENT Project No. BA PROCESS OVERVIEW 496762

Figure 1-1: Overview of the Basic Assessment process

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1.1 Basic Assessment Process Objectives The objectives of the BA process are specified in Appendix 1 of the EIA Regulations, 2014 (as amended).

Table 1-1 lists the BA objectives from GN 326 and provides a reference to the applicable chapter of this document where each objective is addressed.

Table 1-1: Objectives of the BA Process (Appendix 1 of GN 326, 07 April 2017)

BA objectives Reference in BA Report 2. The objective of the basic assessment process is to, through a consultative process – (a) determine the policy and legislative context within which the proposed activity is Chapter 6 located and how the activity complies with and responds to the policy and legislative context; (b) identify the alternatives considered, including the activity, location, and technology Chapter 8 alternatives; (c) describe the need and desirability of the proposed alternatives; Chapter 7 (d) through the undertaking of an impact and risk assessment process, inclusive of Chapter 10 cumulative impacts which focused on determining the geographical, physical, biological, social, economic, heritage, and cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity and technology alternatives on these aspects to determine— (i) the nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and (ii) the degree to which these impacts— (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be avoided, managed or mitigated; and (e) through a ranking of the site sensitivities and possible impacts the activity and Chapter 10 technology alternatives will impose on the sites and location identified through the life and of the activity to— Chapter 11 (i) identify and motivate a preferred site, activity and technology alternative; (ii) identify suitable measures to avoid, manage or mitigate identified impacts; and (iii) identify residual risks that need to be managed and monitored.

1.2 Scope of Assessment and Content of BA Report The legislated requirements for the content of a BA Report are specified in Appendix 1 of the Amendments to the EIA Regulations, 2014 (as amended).

Table 1-2 lists the content requirements from GN 326 and provides a reference to the applicable chapter or section of this document where the specified information is provided.

Table 1-2: Legislated requirements for the content of an BA Report

Scope of Assessment and BA Content Requirements Reference in BA Report 3(1) A basic assessment report must contain the information that is necessary for the competent authority to consider and come to a decision on the application, and must include— (a) details of— Chapter 2 and (i) the EAP who prepared the report; and Appendix A (ii) the expertise of the EAP, including a curriculum vitae; (b) the location of the activity, including: Chapter 3 (i) the 21-digit Surveyor General code of each cadastral land parcel;

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Scope of Assessment and BA Content Requirements Reference in BA Report (ii) where available, the physical address and farm name; (iii) where the required information in items (i) and (ii) is not available, the coordinates of the boundary of the property or properties; (c) a plan which locates the proposed activity or activities applied for as well as associated Chapter 3 and structures and infrastructure at an appropriate scale; Appendix B or, if it is— (i) a linear activity, a description and coordinates of the corridor in which the proposed activity or activities is to be undertaken; or (ii) on land where the property has not been defined, the coordinates within which the activity is to be undertaken; (d) a description of the scope of the proposed activity, including— Chapters 4-6 (i) all listed and specified activities triggered and being applied for; and (ii) a description of the activities to be undertaken including associated structures and infrastructure; (e) a description of the policy and legislative context within which the development is Chapter 6 proposed including— (i) an identification of all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks, and instruments that are applicable to this activity and have been considered in the preparation of the report; and (ii) how the proposed activity complies with and responds to the legislation and policy context, plans, guidelines, tools frameworks, and instruments; (f) a motivation for the need and desirability for the proposed development including the Chapter 7 need and desirability of the activity in the context of the preferred location; (g) a motivation for the preferred site, activity and technology alternative; Chapter 7 (h) a full description of the process followed to reach the proposed preferred alternative Chapters 8-11 within the site, including— (i) details of all the alternatives considered; (ii) details of the public participation process undertaken in terms of regulation 41 of the Regulations, including copies of the supporting documents and inputs; (iii) a summary of the issues raised by interested and affected parties, and an indication of the manner in which the issues were incorporated, or the reasons for not including them; (iv) the environmental attributes associated with the alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects; (v) the impacts and risks identified for each alternative, including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts— (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be avoided, managed or mitigated; (vi) the methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks associated with the alternatives; (vii) positive and negative impacts that the proposed activity and alternatives will have on the environment and on the community that may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects; (viii) the possible mitigation measures that could be applied and level of residual risk; (ix) the outcome of the site selection matrix; (x) if no alternatives, including alternative locations for the activity were investigated, the motivation for not considering such; and (xi) a concluding statement indicating the preferred alternatives, including preferred location of the activity; (i) a full description of the process undertaken to identify, assess and rank the impacts the Chapter 10 activity will impose on the preferred location through the life of the activity, including—

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Scope of Assessment and BA Content Requirements Reference in BA Report (i) a description of all environmental issues and risks that were identified during the environmental impact assessment process; and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures; (j) an assessment of each identified potentially significant impact and risk, including— Chapter 10 (i) cumulative impacts; (ii) the nature, significance and consequences of the impact and risk; (iii) the extent and duration of the impact and risk; (iv) the probability of the impact and risk occurring; (v) the degree to which the impact and risk can be reversed; (vi) the degree to which the impact and risk may cause irreplaceable loss of resources; and (vii) the degree to which the impact and risk can be avoided, managed or mitigated; (k) where applicable, a summary of the findings and impact management measures Chapter 10 identified in any specialist report complying with Appendix 6 to these Regulations and an indication as to how these findings and recommendations have been included in the final report; (l) an environmental impact statement which contains— Chapter 12 (i) a summary of the key findings of the environmental impact assessment; (ii) a map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers; and (iii) a summary of the positive and negative impacts and risks of the proposed activity and identified alternatives; (m) based on the assessment, and where applicable, impact management measures from Chapter 11 specialist reports, the recording of the proposed impact management outcomes for the and development for inclusion in the EMPr; Appendix C (n) any aspects which were conditional to the findings of the assessment either by the EAP Chapter 12 or specialist which are to be included as conditions of authorisation; (o) a description of any assumptions, uncertainties, and gaps in knowledge which relate to Chapter 13 the assessment and mitigation measures proposed; (p) a reasoned opinion as to whether the proposed activity should or should not be Chapter 12 authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation; (q) where the proposed activity does not include operational aspects, the period for which Not applicable the environmental authorisation is required, the date on which the activity will be concluded, and the post construction monitoring requirements finalised; (r) an undertaking under oath or affirmation by the EAP in relation to— Chapter 14 (i) the correctness of the information provided in the reports; (ii) the inclusion of comments and inputs from stakeholders and I&APs; (iii) the inclusion of inputs and recommendations from the specialist reports where relevant; and (iv) any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested and affected parties; and (s) where applicable, details of any financial provision for the rehabilitation, closure, and N/A ongoing post decommissioning management of negative environmental impacts; (t) any specific information that may be required by the competent authority; and N/A (u) any other matters required in terms of section 24(4)(a) and (b) of the Act. N/A

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2 Environmental Assessment Practitioner SRK Group Consulting Practices employs approximately 1400 professional staff operating from forty- eight (48) established offices on 6 continents. SRK offers expertise in a wide range of environmental and engineering disciplines. SRK’s Durban Environmental Department has a distinguished track record of managing large environmental and engineering projects and has been practicing in KwaZulu- Natal since 1990. SRK has rigorous quality assurance standards and is ISO 9001:2015 accredited.

The qualifications and experience of the environmental practitioners responsible for this project are provided in Table 2-1. Refer to Appendix A for the EAP, Mrs Tamaryn Hale, Declaration of Interest and curriculum vitae. The team that assisted Mrs. Hale with the BA process and the compilation of the BAR is detailed in Table 2-1.

Table 2-1: SRK team involved with the BA process and compiling the BA Report

Name Qualifications Professional affiliations Years of experience Tamaryn Hale • BSc (Hons) • Registered EAP with the Environmental Assessment 12 Years (Cert. EAP; Environmental Practitioners Association of South Africa (EAPASA) Pr.Sci.Nat) Science (Registration number 2020/1604) • BSc Biological • Registered as a Professional Natural Scientist with the Science South African Council for Natural Scientific Professions (Registration number 118704) • IAIAsa member. Marius van • BSc (Hons), • Registered EAP with the Interim Certification Board for 16 Years Huyssteen Geography & Environmental Assessment Practitioners Environmental • IAIAsa member. Management • BSc, Cellular, Molecular & Chemical Sciences Philippa • BSc (Hons), • Registered EAP with the Environmental Assessment 16 Years Burmeister Environmental Practitioners Association of South Africa (EAPASA) (Pr.Sci.Nat.; Science (Registration number 2020/1604) Cert. EAP) • Registered as a Professional Natural Scientist with the South African Council for Natural Scientific Professions (Registration number 400195/08) • IAIAsa member. Siphelele • BA • IAIAsa member. 3 Years Mkhize Environmental Management • BSc (Hons) Geography

3 Project Location The project site is located within Ward 30 of the eThekwini Metropolitan Municipality, within the Inner West Region of the Municipality, in the suburb of Berea-West in Westville. The project site is bordered by the M13 King Cetswayo Highway to the north, the National Road N2 to the east and the N3 to the south.

The site is approximately 20.9 hectares in extent with the area to be developed approximately 17.5ha. Refer to Figure 3-1 for the location of the site and Table 3-1 for the details of the properties. The Applicant, Woodglaze Trading, is the owner of the properties (Appendix D). The centre coordinate of the site is: 29°36'46.05"S; 31°03'18.77"E.

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Figure 3-1: Locality map

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Table 3-1: Property description

Property description SG 21-digit code REM OF ERF 2068 N0FT00450000204300000 REM OF ERF 2047 N0FT00450000204700001 REM OF ERF 2048 N0FT00450000204800000 REM OF PORTION 1 OF ERF 2053 N0FT00450000205300001 REM OF ERF 2053 N0FT00450000205300001 REM OF ERF 2054 N0FT00450000205400000 REM OF PORTION 1 OF ERF 2059 N0FT00450000205900001 REM OF PORTION 8 OF ERF 2059 N0FT00450000205900008 REM OF PORTION 2 OF ERF 2059 N0FT00450000205900002 REM OF PORTION 7 OF ERF 2059 N0FT00450000205900007 REM OF ERF 2060 N0FT00450000206000000 REM OF ERF 2059 N0FT00450000205900000 REM OF PORTION 5 OF ERF 2060 N0FT00450000206000005 REM OF PORTION 1 OF ERF 2061 N0FT00450000206100001 REM OF PORTION 4 OF ERF 2060 N0FT00450000206000004 REM OF ERF 2061 N0FT00450000206100000 REM OF PORTION 2 OF ERF 2061 N0FT00450000206100002 REM OF PORTION 1 OF ERF 2066 N0FT00450000206600001 REM OF PORTION 1 OF ERF 2060 N0FT00450000206000001 REM OF PORTION 3 OF ERF 2061 N0FT00450000206100003 REM OF ERF 2066 N0FT00450000206600000 REM OF PORTION 1 OF ERF 2067 N0FT00450000206700001 REM OF PORTION 2 OF ERF 2066 N0FT00450000206600002 REM OF PORTION 1 OF ERF 2069 N0FT00450000206900001 REM OF ERF 2067 N0FT00450000206700000 REM OF ERF 2069 N0FT00450000206900000 REM OF ERF 2068 N0FT00450000206800000

4 Site Overview A brief environmental baseline description of the site is provided in the subsections that follow.

4.1 Climate Durban typically receives on average 759mm of rain per year, with the most rainfall occurring during mid-summer in January (104mm) and its lowest rainfall in July (14mm). The average midday temperatures range between 22.2°C in July (Winter) to 27.4°C in February (Summer). The coldest time is during July when night-time temperatures drop to 9.5°C on average (SA Explorer, 2000-2017)2.

2 Source of information: http://www.saexplorer.co.za/southafrica/climate/durban_climate.asp

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4.2 Topography The site is characterized by slopes draining towards valley-bottom areas with an elevation varying between 100 to 130 metres above sea level.

Terracing of slopes is noticeable at the northern edge of the property. This terracing may have resulted from earthworks undertaken during the construction of the N2 and M13 highways.

4.3 Geology and Soils The underlying geology of the site consists of Ordovician Natal Group (refer to Figure 4-1). The geology associated with this formation includes Sandstone, Dwyka tillite, Ecca shale and Maphumulo gneiss. Weathering of old dunes has resulted in red sands called Berea Red Sand. The red sands are shallow over hard sandstone and deeper over softer rock (Mucina and Rutherford, 2006).

4.4 Vegetation The National South African Vegetation Map (Mucina & Rutherford, 2006) categorises the region as the Indian Ocean Coastal Belt (IOCB) Bioregion. At a local scale, the site broadly falls within the KwaZulu-Natal Coastal Belt (CB3) vegetation type (refer to Figure 4-2).

The Ezemvelo KwaZulu-Natal Wildlife (EKZNW) Terrestrial Systematic Conservation Plan (CPLAN)3 identifies the entire site as being a (CBA): Irreplaceable (refer to Figure 4-3). CBA: Irreplaceable areas are areas that are considered critically important for meeting biodiversity targets and thresholds, and which are required to ensure the persistence of viable populations of species and the functionality of ecosystems. These areas were likely identified at a desktop level due to the anticipated (but not verified) existence of rare graminoids, molluscs, millipedes and intact natural vegetation in the study area.

However, despite the CPLAN’s classification, ground truthing indicates that the vegetation in the project area is predominantly transformed. Anthropogenic disturbances such as earthworks, which previously took place within the property, have resulted in the alteration of the vegetation.

3 The KZN systematic conservation assessments were developed in 2016 by EKZNW to ensure that biodiversity areas and ecological support areas within KZN are identified and conserved (EKZNW, 2016). The conservation plan outlines three conservation categories, namely: • CBA: Irreplaceable • CBA: Optimal • Ecological Support Areas (ESAs)

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Figure 4-1: Underlying geology of the site

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Figure 4-2: Vegetation habitats on site

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Figure 4-3: Ezemvelo KZN Wildlife Terrestrial Systematic Conservation Plan

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4.5 Water Resources The site falls within the Pongola-Mtamvuna Water Management Area, specifically within the Mgeni Sub-Water Management Area. The quaternary catchment applicable to the development property is U60F.

Figure 4-4 shows desktop dataset of the water resources on site and within a 500m radius of the site. To verify the desktop assessment a wetland assessment was undertaken by a specialist in 2019 (refer to Appendix F-2). The assessment of the site by the specialist is detailed hereunder. Two wetland areas were confirmed and delineated – i.e. TI Area A (hydro-geomorphic (HGM) A) and TI Area B (HGM B) within the site boundary (refer to Figure 4-4). Both TI Area A and TI Area B are categorised as Present Ecological State (PES) Category D (i.e. largely modified wetland systems). The wetland Ecological Importance and Sensitivity (EIS) score indicated that both wetlands are rated as “low” in this regard, with the exception being that TI Area A (seep) received a “moderate” rating for Hydrological Functional Importance.

Despite the generally modified nature of the wetland systems, the Wetland Functions and Services Assessment (i.e. via a Level 2 WET-EcoServices assessment) indicated that these systems do still perform a variety of important ecosystem services (i.e. that should be preserved and preferable enhanced).

A third area (refer to area in Figure 4-4 called “Recommended Limited Development Zone”), which did not show wetland soil and vegetation characteristics, showed evidence of ephemeral drainage features which are inferred to be as a result of historical (but no longer occurring) stormwater discharges from neighbouring residential areas. This area, although identified on the dataset as being a river, is considered neither a wetland nor a drainage line (refer to Appendix F-2).

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4.6 Land use and zoning of the site and surrounding area The site for the proposed housing project is currently zoned Intermediate Residential 3 and the proposed development falls within the zone parameters (i.e. no rezoning application is required). The site is currently undeveloped with part of the site currently being used as a paintball shooting range.

Recreational activities have historically occurred within the project area and have resulted in hardened informal paths and loss of basal cover. Furthermore, this has culminated in uncontrolled run-off and erosion in some sections of the property.

Terracing of slopes is noticeable within the habitat unit located at the northern edge of the property. This terracing may have resulted from earthworks undertaken during the construction of the N2 and M13 highways.

Vegetation on the south-west corner of the property was also historically cleared to accommodate a telecommunication base station.

Storm water outlets were noted discharging into the delineated wetland area TI Area B and illegal dumping of refuse was noted at the south-west corner of the property during the wetland specialist investigation.

The land use surrounding the site includes residential housing, commercial areas (such as the Westwood Mall to the north) and major road networks such as the N2, N3 and M13 highways.

4.7 Socio-economic Setting This section has been informed by the eThekwini Municipality Integrated Development Plan: 2018/2019 Review.

The eThekwini Municipal Area (EMA) is estimated to have a developing population of approximately 3.85 million people, with high birth and infant mortality rates and a comparatively short life expectancy. In terms of population spread, the greatest population concentrations occur in the Central and North Planning Regions (the project site falls in the Inner West Planning Region). The people who reside within the municipal area consist of individuals from different ethnic backgrounds. The majority of the population come from the African community (74%), followed by the Indian community (17%), White community (7%), Coloured community (2%) and other nationals (0.4%).

The EMA, like all developing world cities, is subject to high rates of in-migration from rural areas and small towns in KZN, other parts of South Africa and other parts of Southern Africa. This has resulted in a rate of urbanisation and population increase that is difficult to project, and a large number of new residents requiring housing and services. The eThekwini City Density Strategy (2013) estimated that “at a growth rate of 1.1% p.a, the population of the EMA will grow to 4.4 million by 2030, an additional 775,000 people. However, global trends indicate that a projection of 1.1% annual growth might be too low. Cities across the world now accommodate 3.5 billion people or fifty percent of the worlds’ population. By 2050 they will accommodate 6.4 billion people or over 70% of the world’s population.” (City of Melbourne, 2010; quoted in the Built Environment Performance Plan, eThekwini 2015).

African Cities are generally dynamic and have fast-growing populations, and eThekwini is no exception with the majority of this growth happening on the urban periphery where it is easier to access land. With such rapid growth, city development will need to be significantly accelerated to adequately address this challenge.

Most jobs in the manufacturing, warehousing and transport industry are located in the centre, south and west of the municipality. Future economic and residential growth in the North of eThekwini has been planned for around the Dube Trade Port. However, it is also critical that growth anticipates and aligns with the needs of the city’s immediate municipal neighbours to the north; Ndwedwe and

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KwaDukuza. A significant component of the northern labour pool exists in the form of migrant labour from these municipalities, and the co-dependencies between Ndwedwe, KwaDukuza and eThekwini should be carefully and cooperatively managed. The same is true of many residents of the city’s southern and western neighbours, many of whom have secondary economic dependencies on the metro or are migrating between a rural home and the City of Durban on a weekly basis.

The EMA accommodates a wide range of land uses including formal and informal, urban and rural settlements and these are complemented by economic, transport, public and social infrastructure. Approximately 32% of the municipal area is urban and dominated by residential, commercial/office and industrial land uses. The economic land uses, located in closer proximity to the N2 and N3, are unevenly distributed throughout the Municipality and separated from the higher density residential uses. The project is located in an urban area within the Municipality that is characterised by middle to upper income residential formal settlements.

4.8 Heritage Resources A heritage impact assessment was undertaken by Mr. Albert van Jaarsveld (refer to Appendix F-3). His findings were that although Stone Age sites have formerly been recorded within the boundaries of the eThekwini Municipality, non were observed on site. Lithic material present is not typical of that being used in the Stone Tool Manufacturing Industry. No Iron Age remains have been observed on site. Early Iron Age sites are in general situated in low-lying areas close to water resources and the Westville Triangle site is not situated within such an area. There are no buildings present and no declared Heritage Sites (i.e. former National Monuments) in close vicinity to the site (van Jaarsveld, 2009).

5 Project Description Woodglaze Trading proposes to develop approximately 300 residential housing units at Westville Triangle, KwaZulu-Natal. The proposed development includes apartments that consist of two- and three-storey walk-up blocks accommodating 2-bedroom apartments on each floor (92 units in total) and 208 semi-detached, double-storey units. The following infrastructure and services will form part of the development:

• Two (2) tarred access roads with internal roads 9 m, 13 m and 18 m wide. • Two (2) community facilities. • Recreation facilities including: a sports field; a basketball court, a tennis court; fifteen (15) play areas and three (3) water features. • Parking areas (1.5 per unit). • Open space areas. • Services to include: electricity, water and sewer connections, and stormwater infrastructure. A copy of the layout plan is included in Figure 5-1 and Appendix B.

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Figure 5-1: Project layout plan (refer to Appendix B)

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5.1 Overview of Layout Plan The planning and design approach to the Westville Triangle housing development is based on the high visibility of the area, its good location in relation to public transport opportunities, amenities and activities, its topographic features, and its contents of substantial natural vegetation. Other aspects which have influenced the proposed planning and design of the area include, the necessity of increased development efficiency, the better utilisation of appropriately located infill areas and the necessity to create an increased level of affordable higher density housing in good urban locations.

Consequently, the proposed development consists of a mixture of three-storey apartment and duplex developments. While the surrounding urban area consists largely of individual freestanding residential dwellings, there is a perceptible trend in the surrounding areas for higher density redevelopment.

The higher density apartment development is proposed to be largely located on the higher elevations of the spurs, while the lower intensity duplex development is proposed to occupy the lower lying areas. The latter leads into the valley that is reserved for the maintenance, rehabilitation and upgrading of the natural environment and associated recreational activities.

While the undulating topography of the area is expected to contribute to a perception of lower than actual development density, this is proposed to be increased by the establishment of additional vegetation to integrate the built and the natural environments. Where appropriate, the interface to the existing low intensity development to the west accommodates duplex development and local amenities serving both the Westville Triangle and the adjacent residential area.

Refer to Plate 5-1 and Plate 5-2 for architects’ impressions of the proposed development.

Plate 5-1: Architects’ impression of the proposed Westville Triangle Project looking west

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Plate 5-2: Architects’ impression of the proposed Westville Triangle Project

5.2 Services There is an existing bulk water main that runs parallel with the north-western boundary of the site. The water for the proposed development will tie-in to this existing pipeline.

A Sewer Management Plan has been compiled for the proposed development (refer to Appendix F- 5). According to the plan, the proposed development falls within a low to middle income group that is expected to yield an average daily flow of 750 l/day. Based on the design requirements, the site was required to be divided into two (2) catchments. The plan concluded that, based on the hydraulic assessment there is sufficient capacity for the proposed 14.6l/s development flow connecting into the local Municipal Sewer.

Confirmation from eThekwini Municipality Water and Sanitation Department is still to be received for both water and sewer connections.

It is noted that the stormwater management plan was not available at the time of the assessment of potential impacts. This has therefore been excluded from this assessment.

5.3 External and Internal Access Although the Westville Triangle abuts directly onto the N2, no access is possible from the National road. The central and southern portion of the site will have two access points, one off Revenge Road and the second off Renown Road. The northern section of the site is not planned to be developed as part of the current application and therefore no access has been provided for.

Internal access is proposed to take place in accordance with prevailing topographic conditions via a series of 16m, 12m and 8m-wide residential access roads. A series of pedestrian walkways provide internal short-cuts, interlinkage and pedestrian access to recreational areas and areas of natural vegetation.

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5.4 Housing Unit Typologies

5.4.1 Apartment Development The apartment development consists of two- and three-storey walk-up blocks accommodating 2- bedroom apartments on each floor. The apartment blocks are primarily located at the higher elevations to utilise the topographic conditions and highlight the unique features of the site. The arrangement of the blocks mirrors the shape of the site. Differences in ground level will contribute to reduce perceived development intensities.

5.4.2 Duplex Development The duplex development, consisting of attached double-storey units, is located on the lower reaches of the site and on the periphery abutting the existing lower density development in the west. Clusters of three attached units are proposed to be located on individual subdivisions. The duplex arrangements located at the lower levels of the site are envisaged to represent a transition between the higher densities at the top of the spurs and the natural vegetation and recreational areas in the valleys. Besides providing lower levels of built volume, this site arrangement is also expected to provide visual and physical permeability between the different development components.

5.5 Amenities and Facilities The proposal accommodates three amenities / facility sites. The sites are located at the entrances of the development potentially suitable for a crèche, worship or a local commercial site. The layout includes the provision of recreational facilities, located in the flatter areas of the most southerly valley, which could potentially accommodate a playing field, a basketball and a tennis court.

5.6 Natural Environment and Vegetation The natural environment forms a significant and integral part of the proposed development. It is the intention of the Developer to rehabilitate and upgrade the natural environment, to protect it appropriately and to integrate it as a positive green component into the built environment.

As indicated above it is envisaged to serve on the one hand as green relief to the built development, while on the other hand it is expected to maintain the stormwater management function of the valleys and to create an amenity buffer to both the N2 and the existing lower intensity development to the west of Westville Triangle.

Landscaping of all streets within the development will be undertaken as indicated in the proposed layout plan (refer to Figure 5-1).

5.7 Parking Parking for the apartment development is generally located in front of the relevant blocks. One parking bay is envisaged to be provided per apartment. Natural vegetation is expected to be established around the parking areas.

Parking for the duplex units will be in front of each individual duplex site.

6 Policy and Legislative Context 6.1 South African Constitution The Constitution of the Republic of South Africa, 1996 (Act No. 108 of 1996) is the supreme law of the land. In terms of environmental management, the Constitution provides the overarching framework for

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sustainable development, including the protection of natural resources while promoting economic and social development.

The environmental clause in Section 24 of the Constitution provides that:

“Everyone has the right –

a) To an environment which is not harmful to their health or wellbeing.

b) To have the environment protected for the benefit of present and future generations through reasonable legislation and other measures that: i. Prevent pollution and ecological degradation; ii. Promotes conservation; iii. Secure ecologically sustainable development and the use of natural resources while promoting justifiable economic and social development.”

6.2 Environmental Management The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) provides for co- operative governance by establishing decision-making principles on matters affecting the environment including: • Sustainable development. • Integrated environmental management. • Polluter pays principle. • Cradle to grave responsibility. • Precautionary principle. • Involvement of stakeholders in decision-making.

The enforcing authority for NEMA is the Department of Environment, Forestry and Fisheries (DEFF) and provincial environmental authorities (for this application, EDTEA is the Competent Authority).

NEMA provides for the management and protection of environmental resources through inter alia the imposition of Environmental Authorisation requirements.

The EIA Regulations, 2014 (as amended), promulgated in terms of NEMA, consist of the following: • Government Notice (GN) 326, which specifies the EIA procedures to be followed. • GN 327, which provides Listing Notice 1 – activities that require a BA process. • GN 325, which provides Listing Notice 2 – activities that require a Scoping an Environmental Impact Reporting (S&EIR) process. • GN 324, which provides Listing Notice 3 – activities in identified geographical areas that require a BA process.

The applicable Listed Activities for the preferred alternative of the Applicant are detailed in Table 6-1. Based on the activities triggered, a Basic Assessment process is required to obtain Environmental Authorisation for the proposed project.

Table 6-1: Applicable NEMA Listed Activities

No. Activity description Applicability to proposed project NEMA EIA Listing Notice 1 (GN 327) – BA process required 27 The clearance of an area of 1 ha The vegetation on site was determined to be largely or more, but less than 20 ha of secondary vegetation (i.e. it was previously cleared and indigenous vegetation. grew back). This is, however, considered to be indigenous vegetation. The site is approximately 20.9 ha in extent,

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No. Activity description Applicability to proposed project however, the area proposed by Woodglaze Trading to be developed is approximately 17.5ha. NEMA EIA Listing Notice 3 (GN 324) – BA process required 4d.viii The development of a road The access roads and internal roads will be 8m, 12m and wider than 4 metres with a 16m-wide. The entire site falls within a Biodiversity Priority reserve less than 13,5 metres Area 1 in terms of the Ezemvelo KZN Wildlife Terrestrial where such occurs in: Systemic Conservation Plan, which is considered to be a d. KwaZulu-Natal systematic biodiversity plan. viii. Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans. 12d.v The clearance of an area of The proposed development involves the removal of 300 m2 or more of indigenous approximately 17.5ha of indigenous vegetation. The entire vegetation, where such occurs site falls within a Biodiversity Priority Area 1 in terms of the in: Ezemvelo KZN Wildlife Terrestrial Systemic Conservation d. KwaZulu-Natal Plan, which is considered to be a systematic biodiversity plan. v. Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans. 14(ii)(a)d.vii The development of- There are two wetlands delineated on site, which have been (ii) infrastructure or structures afforded a 30m buffer. The proposed development, including with a physical footprint of 10m2 all infrastructure, will not cross the wetlands or the 30m 2 or more; where such buffer. At least 10m of the proposed development will be development occurs- within 32m of the edge of the wetland. (c) if no development setback The entire site falls within a Biodiversity Priority Area 1 in has been adopted, within terms of the Ezemvelo KZN Wildlife Terrestrial Systemic 32 metres of a watercourse, Conservation Plan, which is considered to be a systematic measured from the edge of a biodiversity plan. watercourse; and where such occurs within: d. KwaZulu-Natal vii Critical biodiversity areas or ecological support areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans.

6.3 Water Management The National Water Act, 1998 (Act No. 36 of 1998) (NWA) recognises that water is a scarce resource which belongs to all people and therefore the Department of Water and Sanitation (DWS) aims at implementing laws which will promote equal access to water and the use of water resources.

In this regard, all activities that are listed under Section 21 of the NWA require either an application for a Water Use Licence (WUL) or a General Authorisation (GA) to the DWS.

Activities listed under Section 21 include: (a) Taking water from a water resource. (b) Storing water. (c) Impeding or diverting the flow of water in a watercourse. (d) Engaging in a stream flow reduction activity contemplated in Section 36.

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(e) Engaging in a controlled activity identified as such in Section 37(1) or declared under Section 38(1). (f) Discharging waste or water containing waste into a water resource through a pipe, canal, sewer, sea outfall or other conduit. (g) Disposing of waste in a manner which may detrimentally impact on a water resource. (h) Disposing in any manner of water which contains waste from, or which has been heated in, any industrial or power generation process. (i) Altering the bed, banks, course or characteristics of a watercourse. (j) Removing, discharging or disposing of water found underground if it is necessary for the efficient continuation of an activity or for the safety of people. (k) Using water for recreational purposes.

The examination of the National Freshwater Ecosystem Priority Areas (NFEPA) Geographic Information System (GIS) database identified that the proposed site does not fall within a Freshwater Ecosystem Priority Area (FEPA). Furthermore, no NFEPA wetlands are found within a 500m radius of the site. Refer to Figure 4-4.

There are two wetlands on the site (with a 30m buffer) that have been delineated by a specialist. The proposed development does not cross these wetlands, however, it is within 500m of the delineated wetlands and therefore triggers the Section 21(c) and 21(i) water uses. In terms of the GA issued by the DWS in terms of Section 39 of the NWA4 for prescribed water uses in General Notice 509 of 2016, as published in the Government Gazette No. 40229 of 26 August 2016, the proposed development requires a GA.

6.4 Biodiversity Management The following main pieces of legislation relate to the management of biodiversity resources within the eThekwini Municipality: • National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) (NEM: BA). • National Environmental Management: Protected Areas Act, 2003 (Act No. 57 of 2003). • National Forests Act, 1998 (Act No. 84 of 1998). • Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983). • KwaZulu-Natal Conservation Management Act, 1997 (Act No. 9 of 1997). • Natal Nature Conservation Ordinance (No. 15 of 1974). • Durban Metropolitan Open Space System (D’MOSS).

When the physical site findings by the ecological specialist, in relation to vegetation, are considered against relevant legislation and the EKZNW CPLAN, the vegetation within the property is transformed and does not support key biodiversity features that would qualify it as a Critical Biodiversity Area. The only vegetation habitat occurring within the property that is of conservation concern is the wetland habitats (refer to Section 4.5 and Appendix F-2).

No plant species of conservation concern were encountered within the property during the site assessment undertaken by the ecological specialist. (Appendix F-2). The site falls outside of the D’MOSS area (refer to Figure 6-1).

4 A GA in terms of Section 39 of the NWA is an authorisation for water uses as defined in Section 21(c) and Section 21(i) without a license, provided that the water use is within certain limits and complies with conditions as set out in the GA.

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Figure 6-1: Location of proposed site in relation to D’MOSS designated areas

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6.5 Heritage Management

The following applicable pieces of legislation relate to the protection of heritage resources: • National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA). • KwaZulu-Natal Heritage Act, 1997 (Act No. 10 of 1997).

The South African Heritage Resources Agency (SAHRA) and Amafa aKwaZulu-Natali are the responsible heritage resources authorities in KwaZulu-Natal.

In terms of Section 38 of the NHRA, SAHRA must be notified and furnished with details regarding the location, nature and extent of any proposed development categorised as — (l) “The construction of a road, wall, powerline, pipeline, canal or other similar form of linear development or barrier exceeding 300 m in length. (m) The construction of a bridge or similar structure exceeding 50 m in length. (n) Any development or other activity which will change the character of a site— (i) Exceeding 5 000 m2 in extent; or (ii) Involving three or more existing erven or subdivisions thereof; or (iii) Involving three or more erven or divisions thereof which have been consolidated within the past five years; or (iv) The costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources authority. (o) The re-zoning of a site exceeding 10 000 m2 in extent. (p) Any other category of development provided for in regulations by SAHRA or a provincial heritage resources authority.”

A heritage impact assessment (HIA) was undertaken for the development of the Westville Triangle site and no heritage resources were identified within the site boundary (Appendix F-3). Procedures to be followed are, however, included in the HIA report and the EMPr in the unlikely event of heritage resource finds being encountered during construction.

6.6 National Environmental Screening Tool In accordance with Regulation 16(1)(v) of the Environmental Impact Assessment Regulations 2014, as amended, a Screening Report has been generated utilising the National Environmental Screening Tool (refer to Appendix G). The purpose of the Screening Tool is to allow a Proponent who intends submitting an application for Environmental Authorisation to screen the proposed site for any environmental sensitivity. The Screening Tool identifies, at a high level, potential specialist investigations required for the proposed site that are then verified by infield observations and EAP experience.

The results of the screening tool were presented at the pre-application meeting (refer to Section 9.1). Table 6-2 details the specialist studies identified and comments by the EAP with regards to the applicability. These comments were discussed and agreed upon with EDTEA during the pre- application meeting.

Table 6-2: National Environmental Screening tool – identified specialist studies

Specialist study required Comment / reasons not applicable

Landscape/ Visual Impact The type of development proposed (i.e. residential units) is in line with the Assessment surrounding land use and as such should not cause a significant visual intrusion.

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Specialist study required Comment / reasons not applicable

Archaeological and Cultural A heritage impact assessment was undertaken in 2009 for the original Heritage Impact Assessment project. The specialist has provided a letter confirming that the results of the study are still relevant. Palaeontology Impact The heritage assessment did not find any resources of importance on site Assessment and therefore it is not anticipated that palaeontological resources would be on site. The Environmental Management Programme (EMPr) submitted with the BAR will include steps to undertake should bones be unearthed during construction activities. Terrestrial Biodiversity Impact A Vegetation Survey and Wetland Impact Assessment was undertaken. Assessment Aquatic Biodiversity Impact A Vegetation Survey and Wetland Impact Assessment was undertaken. Assessment Hydrology Assessment No rivers or streams were identified on site and therefore it is not anticipated that there will be significant impacts on surface water resources (refer to Section 4.5 for clarity). Socio-Economic Assessment The land use proposed is in line with the current zoning and surrounding land uses and as such it is not anticipated that the proposed development will have a significant impact on socio-economic aspects. Plant Species Assessment A list of plants encountered on site was recorded in the Vegetation Survey and Wetland Impact Assessment. Animal Species Assessment The vegetation specialist did not record any protected species in the vegetation survey undertaken and the site is in an urban environment. It is therefore not anticipated that animal species of importance will be on site and as such no assessment was undertaken.

6.7 Other Legislation, Policies and Guidelines The following is a list of all additional legislation, policies and/or guidelines of relevant spheres of government that may be applicable to this application:

• National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (NEM: WA). • National Environmental Management Act: Air Quality Act (Act 39 0f 2004) (NEM: AQA). • Municipal by-laws. • Health Act, 1977 (Act No. 63 of 1977). • Occupational Health & Safety Act, 1993 (Act No. 85 of 1993). 7 Project Need and Desirability In accordance with Item 3(1)(f) in Appendix 1 of GN 326, this chapter provides a motivation for the need and desirability for the proposed development.

Need and desirability is based on the principle of sustainability, set out in the Constitution and in NEMA, and provided for in various policies and plans, including the National Development Plan 2030. Addressing the need and desirability of a development is a way of ensuring sustainable development – in other words, that a development is ecologically sustainable and socially and economically justifiable – and ensuring the simultaneous achievement of the triple bottom-line.

The proposed development is expected to have a Capital Expenditure (CAPEX) values upon completion of approximately R250 million and an expected annual turnover of approximately R83.3 million. During the construction phase it is anticipated that 50 skilled and 250 unskilled employment opportunities will be created and 50 skilled and 150 unskilled employment opportunities during the operational phase.

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The site is zoned for Intermediate Residential 3 and the proposed development falls within the zone restrictions. Therefore, the proposed development is in keeping with the Municipality’s development plans for the area.

Currently the site is undeveloped and with large areas of dense vegetation. The site also has direct access to three major road networks namely, N2, N3 and M13 King Cetshwayo Highway. In its current state the site is ideal for criminal activity and criminals’ movements as it has relatively quick access to several major escape routes. The development of the site could reduce the potential of criminal activity in the area.

The following planning and design approaches were applied by the Planners for this proposed development: • Integrated development – this involves ensuring that the individual development components of the urban fabric relate appropriately to each other, that they complement each other contributing the creation of functional, comprehensive and attractive living environments. Integration is required at all levels of planning including the local, district and regional levels. • Sustainable development – this involves creating development which can be sustained in the long term both in terms of the green and urban environment, economic, social and institutional development. This would, therefore, include:

o A realistic preservation, protection and integration of the natural environment into the built development. o The creation of efficient and affordable development. o The establishment of a total environment including accommodation, recreation, economic activities etc, ensuring that development allows for social development as well as establishing appropriate local institutions. • Efficient development – this involves making efficient usage of development areas and opportunities. These include: o Creating infill development and densification where appropriate, while at the same time providing adequate relief.

o Creating efficiency from both development and residents’ point of view. o Creating efficient development from a maintenance point of view etc. • Accommodating variety and choices – this involves establishing an environment in which residents are provided with choices of accommodation and living style and an environment which creates a variety of living conditions and approaches. • Inner city accommodation – this involves providing affordable accommodation within close proximity of amenities, activities and opportunities. • Liveable housing environment – creating a housing environment which, besides accommodating people, provides opportunities for a range of activities, needs and preferences, for a range of age groups, which is rich in visual qualities and which balances the built and natural environment. • Applying urban design principles such as permeability, appropriateness, legibility, variety, adaptability, uniqueness etc – this involves creating an urban environment which contains a high level of visual and physical transparency thereby creating an appropriate living environment and is appropriate to its context. This then provides easy orientation that contains a variety of housing opportunities, styles and environments, which is adaptable to changes in demands and requirements and which, through its appropriateness to context and site conditions, allows for the establishment of a unique development.

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• Environmental development principles – this involves preserving and protecting the natural environment of the area, rehabilitating and upgrading green environmental components, ensuring the maintenance of its natural functions and positively integrating the green with the built environment.

8 Project Alternatives Consideration of alternatives is an important element in the EIA process. “Alternatives” are defined in the NEMA EIA Regulations, 2014 (GN 326, as amended in 2017), as:

“In relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to the:

(a) property on which or location where the activity is proposed to be undertaken; (b) type of activity to be undertaken; (c) design or layout of the activity; (d) technology to be used in the activity; or (e) operational aspects of the activity; and includes the option of not implementing the activity.” The role of the EAP is therefore to provide a framework for sound decision-making based on the principles of sustainable development. Potential alternatives that were considered for the proposed development are detailed in the sections that follow.

8.1 Property / Site Location Alternatives The property is owned by the Applicant and as such no alternative sites are available to the Applicant for this project.

8.2 Type of Activity Alternatives The proposed development is in accordance with the current land use zoning for the site (i.e. Intermediate Residential 3) and the surrounding land use. Furthermore, the steep topography of the site restricts the alternative types of activities that can occur on site.

8.3 Design or Layout Alternatives The current Westville Triangle site was previously eThekwini Municipality council land. The municipality identified a need for housing in the city, particularly given the increase in informal settlements in the greater metropolitan area. Westville Triangle, amongst other vacant municipal sites was earmarked for the development of medium to high density housing. In 2009 a Basic Assessment process commenced with a proposed layout including approximately 900 housing units. Through the public participation process of the BA it was determined that the proposed layout was not suitable. In light of this, Woodglaze Trading, the new owners of the land, has proposed a medium income housing development of 300 housing units.

The initial preferred layout plan, now referred to as the alternative layout plan, had housing units in the northern section of the site (refer to Figure 8-1). In order to provide services (i.e. an access road, sewer and water) to this northern section, Wetland HGM B needed to be crossed. The construction and installation of infrastructure within wetland HGM B and the associated 30m buffer did not comply with the ecological specialist recommendation that, “All proposed infrastructure, including stormwater drains, access roads, houses and services must be situated 30m outside the edge of the wetland (i.e. outside of the delineated wetland buffer)”. This alternative layout plan was therefore rejected as it was not an ecologically preferred alternative.

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In order to mitigate the potential negative impacts of the alternative layout plan, the current preferred layout plan was proposed (refer to Figure 5-1). This plan provides for housing units (and associated infrastructure) only to south of wetland HGM B.

The impacts of the preferred layout plan have been further assessed in Section 10.3 of this report.

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Figure 8-1: Alternative layout plan

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8.4 Technology Alternatives The option of installing solar panels to supplement electricity usage was considered.

8.5 Operational Alternatives Not applicable to this proposed project.

8.6 No-go Alternative This alternative would entail there being no development of formalized housing and basic services. There exists a significant housing backlog in South Africa, as well as issues of land scarcity in urban areas. A sectional title type of development such as this, optimises space compared to traditional free standing homes. The development of approximately 300 housing units would mean creating business opportunities in the form of amenities in the adjacent community, thus allowing further opportunity for economic growth through entrepreneurs and subsequent employment creation. Should this development not proceed, there would also be no economic benefits from construction activities with a resultant loss of job opportunities and skills capacity building. Moreover, should the site remain undeveloped it remains susceptible to potential land invasions and /or criminal activities.

Should the development not proceed the potential negative impacts of the proposed development (e.g. vegetation clearing, impact on wetlands, traffic etc.) will not materialise (refer to Section 10 for more details).

9 Public Participation A Public Participation Process (PPP) was undertaken with the intent of informing surrounding landowners and key local communities about the proposed development and the BA process underway. Public participation plays an important role in the compilation of environmental reports as well as the planning, design, and ultimately the implementation of the project. Public participation is a process leading to informed decision-making, through joint effort by the Applicant (Woodglaze Trading), technical experts, governmental authorities, and systematically identified interested and affected parties (I&APs).

Public participation is a vehicle for public input, which achieves the following:

• Facilitates negotiated outcomes. • Creates trust and partnership. • Minimises negative effects. • Maximises positive effects. • Provides an indication of issues, which may: − Prevent the project continuing. − Cause costly delays later. − Result in enhanced and shared benefits. The PPP has been undertaken in accordance with Chapter 6 of the EIA Regulations, 2014 (as amended). The process undertaken is detailed in the sub-sections that follow.

9.1 Pre-application meeting A pre-application meeting was held with the EDTEA on 19 February 2020, where the proposed development was discussed with the Competent Authority. The listed activities in terms of NEMA EIA Regulations, 2014 and the proposed way forward were discussed with EDTEA. The minutes of the pre-application meeting are attached in Appendix E-1.

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9.2 Identification of interested and affected parties The PPP for the project was initiated with the development of a comprehensive I&AP database (refer to Appendix E-2). The I&AP database includes the following:

• Competent Authority – EDTEA. • Commenting Authorities: Ezemvelo KZN Wildlife (EKZNW); Department of Water and Sanitation (DWS); Amafa aKwaZulu-Natali; KZN Department of Transport; eThekwini Municipality; Department of Agriculture, Forestry and Fisheries (DAFF). • Adjacent landowners. • Non-governmental organisations. • eThekwini Municipality Ward 30 Councillor.

9.3 Project Announcement

9.3.1 Background Information Document (BID) An English Background Information Document (BID) was compiled and distributed to potential I&APs on 15 March 2019. The BID provided a description of the proposed project and an explanation of the BA process to be followed. The purpose of this document was to inform I&APs of the project and afford them an opportunity to provide comment. A Quick Response (QR) code with an associated website link was generated and placed on the BID, which allowed the public to register on the I&AP database electronically.

A copy of the BID and proof of distribution is included at Appendix E-3. Comments received from I&APs is provided in Appendix E-4.

9.3.2 Site notices Two (2) English A2 laminated posters informing I&APs of the development application were placed, one on site and another at a major road intersection, on 15 March 2019. Photographs and locations of the site notices are shown in Appendix E-5. The content of the site notice is provided in Figure 9-1.

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WESTVILLE TRIANGLE BA Project No. CONTENT OF SITE NOTICE 496762

Figure 9-1: Contents of site notices placed

9.3.3 Advertisements An English newspaper advertisement was placed in The Rising Sun Overport on the 14 March 2019 (Appendix E-6). The aim of the advertisement was to inform the public in the area of the proposed development in order to canvass the issues and concerns of the broader public. This was done to ensure that all potential I&AP’s were afforded the opportunity to comment on the proposed development.

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9.4 Distribution of Draft Basic Assessment Report The Draft BAR will be circulated for a 30-day comment period from Friday, 13 November 2020 to Monday, 14 December 2020. The following actions will be undertaken (NOTE: these actions comply with COVID-19 protocols):

• The Draft BAR, with a complete set of appendices will be uploaded onto the SRK website. • I&APs on the database will be notified via email, SMS or facsimile of the availability of the Draft BAR for review and comment. The link to the SRK website will be provided and the closing date for comments will be stipulated (i.e. 30 days), together with the forms of communication available to submit comments. • The following commenting authorities will be contacted to determine how they would like to receive copies of the Draft BAR: • EDTEA. • EKZNW. • DWS. • KZN DoT. • eThekwini Municipality. • DAFF. [It is noted that engagement with Amafa aKwaZulu-Natali for comments will be undertaken via the SAHRIS online application system.] • The Draft BAR and Environmental Authorisation (EA) application will be submitted to EDTEA in electronic format via the electronic file transfer mechanism as stipulated in Appendix 4 of GN R.650. • To ensure all health and safety regulations and protocols are adhered to, it is noted that a hard copy of the Draft BAR will not be made available in any public locations (e.g. local library or Ward Councillor’s office). • Where any flashdrive or hard copies of documents are to be submitted to I&APs, the following will be undertaken: − Only one person from SRK will compile the flashdrive and hard copies of the report. − Prior to handling the flashdrive and reports the responsible person will hand sanitize and wear a mask for the duration of the compilation thereof. − The flashdrive and/or hard copy will be placed in a single envelope that will be sprayed with a sanitizer. − In instances where the document will be hand delivered by SRK, the responsible person will hand sanitize prior to handling the document and wear a mask until delivery is made to the respective I&AP. The envelope will be given to the I&AP or a responsible representative. − For delivery of documents via a courier, a reputable courier that follows all required protocols will be used.

9.5 Key Stakeholder Meetings Based on the response to the notification of the project, should the need arise to undertake key stakeholder meetings, these will be undertaken using a virtual meeting platform (e.g. Zoom, Skype, Skype for Business or Microsoft Teams). The most appropriate platform for the stakeholder of interest will be utilised to conduct the meeting. Minutes of the meeting (s) will be included in the Final BA Report.

9.6 Public Meeting During the Project Announcement Phase there was substantial response from local residents to the project. It is, therefore, pertinent to undertake a public meeting. This meeting will be undertaken using the virtual meeting platform Zoom/Skype/Skype for Business/Microsoft Teams. Minutes of the meeting will be included in the Final BA Report. It is noted, should I&APs not have access to the virtual meeting platform these I&APs will be contacted directly to discuss the project and obtain comments and/or concerns, where necessary.

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The public meeting will be held two (2) weeks after the circulation of the Draft BAR, thus enabling I&AP to consider the Draft BAR prior to attending the meeting.

9.7 Summary of I&AP Issues Raised A summary of the comments received from the I&APs at the time of the submission of the Draft BAR are provided in Table 9-1. Copies of correspondence received are included in Appendix E-4.

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Date Commentator Organisation Comment Response 15 March 2019 Mr. Mohamed Berea West 1) Environmental Impact Study. This report constitutes the Environmental Impact Study. Rashid Haffajee Neighbourhood Watch 2) Map of planned housing. The proposed layout plan is provided in Figure 5-1 and Appendix B. 3) Natural flora and fauna. The wetland and vegetation assessment is included in Appendix F- 2. 4) D’MOSS green area designation. The site falls outside of the D’MOSS area (refer to Figure 6-1). 2 April 2019 Mr. Mohamed Berea West I’d like to see: Rashid Haffajee Neighbourhood Watch 1) A comprehensive plan of the development. The description of the proposed development is provided in Section 5 with a layout plan Figure 5-1 and Appendix B. 2) The proposers’ plans. 3) History of past successes and failures. The Developer has confirmed the following: Woodglaze has built over 5000 units since 2005. The Municipality cancelled a contract in the past as this was part of the Supply Chain Management (SCM) policy, whereby a new contract is required every 3 years. The letter of award is, however, in place to continue with the development in question. The letter of award for the proposed Westville Triangle development is not affected by the decision. Moreover, the Developer is currently involved with construction projects for the Municipality in Phoenix and Newlands. 4) Environmental impact studies. This document constitutes the Environmental Impact Study for this proposed development and includes recommendations and 5) Reports and recommendations. specialist reports. 6) Traffic impact studies. The potential traffic impacts are discussed in Section 10.2 of this report and the Traffic Impact Assessment for this proposed development is provided in Appendix F-1. 7) SANRAL approvals. The proposed project does not require SANRAL approval. SANRAL is, however, included on the I&AP database as an I&AP. 8) Surveys of current affected people. In terms of the NEMA legislation, the potential I&AP have been identified and notified of the project and afforded an opportunity to comment. This Report (Draft BAR) has been made available to the public for review and comment. 15 March 2019 Ms. Reena Resident My residence is based on the perimeter of the The socio-economic group targeted for this development is similar Singh proposed project location. We've had criminal to that of the existing residents. Any concerns relating to crime in attacks at home previously that have severely the area are shared by the developer. traumatised my 88-year-old mother. This project

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Date Commentator Organisation Comment Response will aggravate her fears, wellbeing and mental The developer will, however, fence the entire site thereby limiting state. access of criminals from the main roads to the site and adjacent properties. 28 March 2019 Ms. Londie Resident This will have a direct impact to our home safety Sibisi and security. 15 March 2019 Mr. Vers Hecht Homeowner 1) Which social economic group is this project The proposed project is aimed at the affordable gap market (i.e. targeting? people with an income of between R7 500 and R22 000 per month, in line with Government’s Finance Linked Individual Subsidy Programme, FLISP), targeting first time home owners. 2) What is the size of the intended 300 units? Units range in size from 120m2 to 200m2. 3) What will be done to protect the Natal Lourie According to the Roberts’ Birds of Southern Africa (Maclean, 1985) that nest there? there are four species of Loerie found in South Africa, namely the Knysna Loerie, Purplecrested Loerie, Ross’s Loerie and Grey Loerie. The Loeries live in evergreen and riverine forest, dense thickets, parks and gardens. The following actions will be undertaken to minimise the potential impact on the Loeries: • Where possible trees will not be removed from site. • The wetland habitat on site and the northern section of the site will be demarcated as a no-go area during construction. 16 March 2019 Mr. Luke Van Resident 300 homes? What do you intend to do once they The Project is aimed at the affordable gap market (i.e. people with Reenan are built and then the tin houses start forming an income of between R7 500 and R22 000 per month, in line with around them pushing the boundaries and Government’s FLISP), targeting first time homeowners. Moreover, transforming 300 homes into 2000 homes? the proposed development will be fenced and will be managed by a Body Corporate. 3 April 2019 Mr. Lenny Resident When this rich-white/poor-black bridging plan was The current proposed development is in-line with the zoning for the Abrahams first announced in about 2004, this area was properties affected. Moreover, the Project is aimed at the affordable predominantly white. Now it is predominantly non- gap market (i.e. people with an income of between R7 500 and white. We don’t mind helping our fellow non-whites R22 000 per month, in line with Government’s FLISP), targeting first but the original objective will now fail! Please time home owners. research more! 3 April 2019 Mr. Robert Westville Environmental degradation and property The environmental impact assessment section of this report Jamieson Conservancy devaluation assesses the potential impact the proposed development will have and WESSA on the environment. Mitigation measures are proposed and these have been carried through into the EMPr. The EMPr will be a legally binding document which the developer will be required to comply with. Furthermore, the Environmental Authorisation, assuming such, would have further conditions that the developer will need to comply with during the construction and operation phases of the project.

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Date Commentator Organisation Comment Response Regarding property devaluation, the site is currently undeveloped land that has evidence of vagrants passing through. The establishment of houses within this area should improve the property values of the houses. Moreover, the proposed development is aimed at middle income earners. 3 April 2019 Mr. Resident The intended development must not lead to de- Currently the site is undeveloped and with large areas of dense Thandolwethu valuing of properties which has happened vegetation. Furthermore, the site has direct access to three major Manda elsewhere in Durban. road networks namely, N2, N3 and M13 King Cetshwayo Highway. In its current state the site is ideal for criminal activity and criminals’ 3 April 2019 Ms. Yvette Resident Please indicate how this will affect our personal movements as it has relatively quick access to several major Norris security. Thank you escape routes. The development of the site will reduce the potential 3 April 2019 Ms. Malani Resident I am not happy with this development taking place area for criminal activity. Therefore, the formalising of houses within Padayachy in our area, it will further devalue my property. this area should improve the property values of the houses. 28 March 2019 Ms. Londie Sibisi Resident This will have a direct impact to our home safety and security. 3 April 2019 Ms. Thoko Resident To be kept in the loop of the process Noted. I&AP has been registered on the database and will receive Ndaba all notifications sent during the BA process. 3 April 2019 Ms. Pearl Nsele Resident Wish to know of development that happens in my Noted. I&AP has been registered on the database and will receive suburb and surroundings all notifications sent during the BA process. 3 April 2019 Mr. Peter John Resident Not in agreement. Noted. Sinclair 3 April 2019 Mr. Seedat Resident My wife and I reside at 3 Revenge Road and Noted. I&AP has been registered on the database and will receive believe that our property will be affected by the all notifications sent during the BA process. proposed development. We therefore would like to be included as an interested party and to be kept of the proposed housing development and its impact on our property. We will raise our concerns at the appropriate time when plans for the proposed housing development become available for comment. 3 April 2019 Mr. C.G. Morris Resident I write to you to register our interest and concerns Currently the site is undeveloped and with large areas of dense and representing the residents of Warspite Rd vegetation. Furthermore, the site has direct access to three major Westville who will be directly impacted by the road networks namely, N2, N3 and M13 King Cetshwayo Highway. proposed Westville Triangle development. In its current state the site is ideal for criminal activity and criminals’ We personally have built our dream home in movements as it has relatively quick access to several major Warspite Rd and the proposed development would escape routes. The development of the site will reduce the potential severely impact the resale value of our property. area for criminal activity. Therefore, the formalising of houses within this area should improve the property values of the houses.

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Date Commentator Organisation Comment Response Moreover, the proposed development is aimed at middle income earners.

Next to our home is a new duplex No. 18 which was A Traffic Impact Assessment was undertaken for the proposed also built recently. At the beginning of our road is development. The TIA concluded that all interchanges will operate also a new house built less than 10 years ago. At at an acceptable level of service during the forecasted 2024 the end of the road is another small cluster of conditions, as stipulated in the Highway Capacity Manual (2000). homes. These conclusions are drawn based on the assumption that the Our road is very narrow and there is no room to proposed mitigation measures will be implemented. The mitigation widen the road as the verges are very narrow as measures (refer to Section 10.2) have been incorporated into the well. EMPr for the proposed development. The EMPr will become a legally binding document should this proposed development be approved. We have extensive bird and plant life around us The proposed layout plan has excluded sensitive environments (i.e. and often have kingfisher and kite eagles in our wetlands, the northern section of the site and the area surroundings. During summer we have bullfrogs recommended for limited development) from the layout. The croaking away at night. I am afraid all this wildlife exclusion of the wetland and the associated buffer will reduce the will disappear. potential loss of the wildlife associated therewith. Woodglaze Trading (Pty) Ltd have a very bad The environmental impact assessment section of this report reputation and have been implicated in various assesses the potential impact the proposed development will have disaster low cost housing projects in the province. on the environment. Mitigation measures are proposed and these eThekwini Municipality has cancelled their contract have been carried through into the EMPr. The EMPr will be a legally with them in the past and we are shocked to hear binding document which the developer will be required to comply they will be the developers for the Westville with. Furthermore, the Environmental Authorisation, assuming Triangle. such, would have further conditions that the developer will need to comply with during the construction and operation phases of the project. The Developer has confirmed the following: Woodglaze has built over 5000 units since 2005. The Municipality cancelled a contract in the past as this was part of the Supply Chain Management (SCM) policy, whereby a new contract is required every 3 years. The letter of award is, however, in place to continue with the development in question. The letter of award for the proposed Westville Triangle development is not affected by the decision. Moreover, the Developer is currently involved with construction projects for the Municipality in Phoenix and Newlands. I urge you to reconsider this project based on our Comment noted. concerns per above.

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Date Commentator Organisation Comment Response 22 March 2018 Ms. Merissa Resident 1) More information regarding time frames or Construction will commence upon receipt of all the requisite Mudaly construction? approvals and authorisations. This includes, but is not limited to Environmental Authorisation, Planning approval and Water Use Authorisation. 2) Proposed access to the site? Two access roads will be constructed (refer to Figure 5-1 and Appendix B). 3) Drawings of the proposed dwellings? Refer to Plate 5-1 in Section 5.1 of this report. 4) Average cost of each dwelling? The price is still to be determined and will take into consideration of all costs. 1 April 2019 Mr. Kuben eThekwini The documentation does not clarify on what basis Woodglaze Trading are the current landowners of the properties for Samie Municipality and capacity Woodglaze is developing the said the proposed development (refer to attached confirmation of properties. ownership in Appendix D). As the properties in question are in the ownership of the ETHEKWINI MUNICIPALITY, we require the following information before we proceed any further: 1) A copy of the eThekwini Council resolution allowing Woodglaze to develop the site. 2) A copy of the agreement between Woodglaze & eThekwini. 3) Appointment letter from eThekwini for the Westville Triangle Development. Failing which we will not provide comment – alternatively – we will object on the grounds of unlawfulness. 15 March 2019 Ms. Donna Resident This area cannot support another 300 houses in It is understood that the following infrastructure will be affected by Steven terms of infrastructure the proposed development: 1) Road network – the TIA undertaken confirmed that the surrounding road network should be able to accommodate the anticipated additional traffic (refer to Section 10.2). 2) Municipal services – the eThekwini Municipality Water and Sanitation Department is still to confirm that there is sufficient bulk water supply and capacity at the Southern Wastewater Treatment Works to accommodate the proposed development’s requirements. 3 April 2019 Ms. Joan Resident Please register us as interested parties so that we The Town Planner confirmed that the consideration of the capacity Coetzee can OPPOSE the development. The Westville of the local schools will be undertaken in the Town Planning schools are full to capacity and cannot absorb approval process.

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Date Commentator Organisation Comment Response hundreds more children. And furthermore, the With respect to traffic, a TIA was undertaken for the proposed roads in the area are so narrow, especially development. The TIA concluded that all interchanges will operate Konigkramer Ave, and are used like a racetrack!!! at an acceptable level of service during the forecasted 2024 So, NO to any development that is going to lower conditions, as stipulated in the Highway Capacity Manual (2000). the value of our properties.!!!! These conclusions are drawn based on the assumption that the proposed mitigation measures will be implemented. The mitigation measures (refer to Section 10.2) have been incorporated into the EMPr for the proposed development. The EMPr will become a legally binding document should this proposed development be approved. 3 April 2019 Ms. Sumaya Resident I am a resident homeowner at 6 Somerset driver Noted. I&AP has been registered on the database and will receive Berea West. all notifications sent during the BA process. This will allow her to I would like to place on record that I am not in provide further comment/ objection on the proposed development. favour of the development below! “the proposed residential development on the Westville Triangle Land. That is the land which is bounded by the N2 on its eastern side, the N3 on its southern side, and Konigkramer Road and Blythe Place on it western side.”

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10 Identification and assessment of potential environmental impacts This section provides a brief indication of the significant potential positive and negative environmental impacts relating to the proposed development. Once a potential issue and/or potential impact has been identified it is necessary to identify which activity or aspect of the development would result in the impact. By considering the cause of the issue, the probability of the activity resulting in an impact can be determined. The associated impact can then be assessed to determine the significance and to define mitigation or management measures to address the impact.

The following specialist studies were undertaken to inform this chapter: • Traffic Impact Assessment (Appendix F-1). • Wetland and Vegetation Assessment (Appendix F-2). • Heritage Impact Assessment (Appendix F-3). The potential environmental impacts associated with activities during construction are usually short lived and mitigated in an Environmental Management Programme (EMPr) (refer to Appendix C for the EMPr). Once approved the EMPr will be implemented on-site and enforced by regular monitoring with submission of audit reports to the EDTEA Compliance Department.

The impact assessment methodology and the potential issues or impacts identified by the EAP and specialists are detailed in the sub-sections to follow.

This chapter meets various requirements in Items 3(1)(h) to (k) in Appendix 1 of GN 326 relating to:

• A description of the process followed to identify potential impacts and risks of the proposed activities and associated structures and infrastructure on the receiving environment; and • A description of the environmental attributes and assessment of each identified potentially significant impact and risk.

10.1 Impact assessment methodology All specialists are required to assess each identified potential impact according to the following Impact Assessment Methodology as described below.

This methodology has been formalised to comply with Regulation 31(2)(l) of the NEMA, which states the following:

(2) An environmental impact assessment report must contain all information that is necessary for the competent authority to consider the application and to reach a decision …, and must include – (l) an assessment of each identified potentially significant impact, including – (i) cumulative impacts; (ii) the nature of the impact; (iii) the extent and duration of the impact; (iv) the probability of the impact occurring; (v) the degree to which the impact can be reversed; (vi) the degree to which the impact may cause irreplaceable loss of resources; and (vii) the degree to which the impact can be mitigated.

Based on the above, the EIA Methodology will require that each potential impact identified is clearly described (providing the nature of the impact) and be assessed in terms of the following factors:

• Duration (temporal scale) – how long will the impact last?

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• Extent (spatial scale) – will the impact affect the national, regional or local environment, or only that of the site? • Magnitude (severity) – will the impact be of high, moderate or low severity? • Probability (likelihood of occurring) – how likely is it that the impact may occur?

To enable a scientific approach for the determination of the environmental significance (importance) of each identified potential impact, a numerical value has been linked to each factor.

10.1.1 Ranking scales The ranking scales as presented in Table 10-1 are applicable.

Table 10-1: Impact ranking scales

Consequence Probability Duration Extent/Scale Magnitude 5 – Permanent 5 – International 10 – Very high/uncertain 5 – Definite/don’t know 4 – Long-term (ceases with the operational life) 4 – National 8 – High 4 – Highly probable 3 – Medium-term (5-15 years) 3 – Regional 6 – Moderate 3 – Medium probability 2 – Short-term (0-5 years) 2 – Local 4 – Low 2 – Low probability 1 – Immediate 1 – Site only 2 – Minor 1 – Improbable 0 – None 0 – None

Once the above factors have been ranked for each identified potential impact, the environmental significance of each impact can be calculated using the following formula:

Significance = (duration + extent + magnitude) x probability

The maximum value that can be calculated for the environmental significance of any impact is 100.

The environmental significance of any identified potential impact is then rated as either: high, moderate or low on the following basis:

• More than 60 significance value indicates a high (H) environmental significance impact. • Between 30 and 60 significance value indicates a moderate (M) environmental significance impact. • Less than 30 significance value indicates a low (L) environmental significance impact.

10.1.2 Reversibility In order to assess the degree to which the potential impact can be reversed, cause irreplaceable loss of resources and be mitigated, each identified potential impact will need to be assessed twice. • Firstly, the potential impact is assessed and rated prior to implementing any mitigation and management measures. • Secondly, the potential impact is assessed and rated after the proposed mitigation and management measures have been implemented. The purpose of this dual rating of the impact before and after mitigation is to indicate that the significance rating of the initial impact is and should be higher in relation to the significance of the impact after mitigation measures have been implemented.

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10.1.3 Irreplaceable Loss In order to assess the degree to which the potential impact could cause irreplaceable Loss of Resources, one of the following classes (%) is to be selected based on the specialist’s informed decision:

5 100% - permanent loss 4 75% - 99% - significant loss 3 50% - 74% - moderate loss 2 25% - 49% - minor loss 1 0% - 24% - limited loss

The Loss of Resources aspect should not affect the overall significance rating of the impact.

10.2 Traffic This section is informed by:

Traffic Impact Assessment for the Proposed Westville Triangle Multiple Unit Residential Development (NSA Consulting Engineers, November 2020). Refer to Appendix F-1.

10.2.1 Baseline Description The development will be accessed via 2 access points as follows:

• Revenge Road, referred to as Access 1, will cater for 172 Residential Units. • Renown Road, referred to as Access 2, will cater for 128 Residential Units. These roads are accessed via the M13 and Essex Terrace interchange. The Traffic Impact Assessment (TIA) notes that traffic on this interchange has increased significantly due to new developments and is expected to continue to increase based on proposed future development. To support the predicted increased traffic an upgrade to the interchange is currently underway.

Observations during the TIA note that during morning peak traffic there is a consistent flow of traffic along Essex Terrace. Congestion at the interchange was observed and attributed to the construction activities associated with the upgrade to the interchange. It was noted that this congestion is expected to be relieved when construction is completed in 2021. It was noted that taxis traversed Essex Terrace and not the internal roads.

10.2.2 Impact Assessment The TIA notes that traffic impacts of new developments are concentrated on the immediate transportation network with these impacts dissipating rapidly further away from the development as more access opportunities become available and traffic disperses onto the broader road network. As such the assessment focused on the following roads and intersections that will be used to access the site:

• Konigkramer Avenue and Essex Terrace. • Coventry Road and Essex Terrace. • Warspite Road and Essex Terrace. Traffic counts where undertaken on the 13 November 2019. The morning peak period (07:00 – 08:00) and afternoon peak period (16:00 – 17:00) was assessed and it was assumed that most of the commuters will be utilizing private vehicles. The assessment extended for a 5-year period until 2024.

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a) Impact T1 – Impact on the Existing Traffic Conditions Traffic congestion, inconvenience and road safety concerns may occur as a result of increased vehicular and pedestrian movement within the project area during the construction and operation phases of the proposed development.

The construction related impacts are likely to be of short duration with the overall significance of the potential traffic impact Low. With regards to operational phase impacts, the TIA concludes that all interchanges will operate at an acceptable level of service during the forecasted 2024 conditions as stipulated in the Highway Capacity Manual (2000).

The assessment of potential impacts is presented in Table 10-2 and Table 10-3, respectively.

Table 10-2: Impact T1-1: Impact on Existing Traffic Conditions during Construction

Impact T1-1: Additional traffic will be generated on the existing road network and may affect the level of service Timing: During the construction activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 50 Management 2 2 6 10 5 1 (moderate) Management measures: • Existing roads to be used where possible, avoiding the creation of new routes. • Disturbance to surrounding areas will be minimised by allowing sufficient space for turning areas. • Where construction will obstruct existing access, alternative temporary access routes will be allowed for. • Safe pedestrian crossings will be provided where necessary. • Speed limits (30 km/hr on dirt roads) will be enforced at all times, and traffic control provided both on public roads and onsite roads. • Only authorised roads and access routes will be used. • All access routes and roads will be adequately maintained in order to minimise erosion and undue surface damage. Rutting and potholing will be repaired and storm water control mechanisms will be maintained. • Any damage to public or private roads caused by the Contractor during the construction phase will be repaired. • The conditions of the EMPr (refer to Appendix C) must be implemented and monitored. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 12 Management 2 2 2 6 2 1 (low)

Table 10-3: Impact T1-2: Impact on Existing Traffic Conditions during Operation

Impact T1-2: Additional traffic will be generated on the existing road network and may affect the level of service Timing: During the operational activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 24 Management 4 2 2 8 3 1 (low) Management measures: • All accesses will need to be a minimum of 6.0 meters wide to accommodate two-way vehicle movements. • The access will be designed in accordance with the eThekwini Transport Authority’s standards and specifications. • All driveway ramps are to have a maximum gradient of 15% with a minimum 30m vertical curve radius. • The proposed development will require 600 parking bays based on the development of 300 residential units. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 24 Management 4 2 2 8 3 1 (low)

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b) Impact T2 – Impact on Existing Public Transport Despite most commuters using private vehicles, the site offers access to public transport via Essex Terrace and the M13 and that the impact of the development on public transport during construction and operation will be negligible.

Given the low overall rating of this impact, no mitigation measures are required as the project will not adversely impact on the existing levels of service on the surrounding road network.

The assessment of potential impacts is presented in Table 10-4.

Table 10-4: Impact T2-1: Impact on Existing Public Transport

Impact T2-1: Additional traffic will be generated that may affect the space available for pedestrian and cyclist movement Timing: During the construction and operation activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 5 Management 1 2 2 5 1 1 (low) Management measures: Pre-mitigation impact significance is low, therefore current designs and measures are to continue to be implemented. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 5 Management 1 2 2 5 1 1 (low)

10.3 Biodiversity It is noted that during 2009 the following specialist studies were undertaken:

• Assessment of Vegetation on Property Proposed for the Westville Triangle Housing Development (David Styles Vegetation Surveys, Advice and Consulting, October 2009). • Wetland Study: Westville Triangle (GroundTruth Biomonitoring Services and Environmental Consultants, October 2009). Due to the dynamic nature of the natural environment on site these reports were updated. This section of the report is therefore informed by the updated report: • Proposed Westville Triangle Housing Development, eThekwini Municipality, KwaZulu-Natal: Vegetation Survey and Wetland Impact Assessment Report (SRK Consulting, July 2019). Refer to Appendix F-2.

10.3.1 Baseline Description a) Vegetation The main vegetative habitat units across the site include (refer to Figure 4-2):

• Dense woody vegetation: The extent of the property to be developed predominantly consists of densely clustered woody vegetation. Woody trees are very dominant in this vegetation habitat; composition is approximately 80-90%. Basal cover is inundated by dense ruderal forbs and interspersed by secondary grasses. This habitat unit extends from the centre of the property towards the M13. • Open scrublands: Open scrublands having an affinity to the woody vegetation are encountered on site with the short, interspersed trees within being generally alien in nature; composition is approximately 40-60%. Basal cover is dominated by secondary grasses and weeds. • Secondary grasslands: Secondary grasslands comprising of moribund and tufted perennials are encountered within the site. The hardy xerophytic grasses are mostly encountered in open areas with poor soil quality (mostly shallow derivatives of sandstone). • Wetland habitat: Hydrophytes indicative of saturated areas are encountered along drainage lines and within the identified wetlands.

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A summary of the Ecological Importance and Sensitivity (EIS) of the vegetation habitats assessed in the project area is presented in Table 10-5.

Table 10-5: Summary of the Ecological Importance and Sensitivity of vegetation

Vegetation habitat Condition Threat Status Sensitivity Dense woody vegetation Very Poor Low Concern Low Open scrublands Poor Low Concern Low Secondary grassland Poor Critically Endangered Moderate

Wetland habitat Good Critically Endangered High

When the physical site findings, in relation to vegetation, are considered against relevant legislation and the EKZNW CPLAN, the vegetation within the property is transformed and does not support key biodiversity features that would qualify it as a Critical Biodiversity Area.

No plant species of conservation concern were encountered within the property during the site assessment by the vegetation specialist. The only vegetation habitat occurring within the property that is of conservation concern is the wetland habitats. b) Wetlands The wetlands on site were delineated based on three indicators, namely terrain, wetland vegetation and soil. The Terrain Indicator (TI) Areas identified (refer to Figure 4-4) were categorised according to the National Wetland Classification System for South Africa (SANBI, 2009). For this, each TI Area had to be classified as a particular hydrogeomorphic (HGM) unit5. The three TI Areas being assessed in this section were classified as follows:

• TI Area A – HGM: Hillslope seepage (seep) (HGM A). • TI Area B – HGM: Channelled valley bottom (HGM B). • TI Area C: Since wetland vegetation and wetland soil indicators are not representative of wetland habitat, TI Area C did not qualify as a wetland and therefore no HGM unit has been assigned to it. [Note: Although TI Area C is not characterised as a wetland or a watercourse, it is identified as an area where stormwater management and control interventions could potentially be incorporated into the design layout of the proposed development.]

In line with the SANBI national classifications system, water inputs for both HGM Units are primarily due to flows emanating from up-slope discharge. Water movement through the seep is mainly in the form of diffuse sub-surface flow, often during the rainy season whereas the channelled valley bottom primarily receives inflows from a channel near the site and gentle slopes.

Each wetland’s ability to contribute to ecosystem services within the study area is further dependent on the particular wetland’s Present Ecological State (PES) in relation to a benchmark or reference condition. A Level 1 Wetland Health Assessment was conducted on the wetlands identified (i.e. HGM A and B) as per the procedures described in ‘Wet-Health: A technique for rapidly assessing wetland health’ (MacFarlane et al., 2008)6. Both HGM units were categorised as PES category D7, which is

5 An HGM unit is a recognizable physiographic wetland-unit based on the geomorphic setting, water inputs of the wetland, and water flow patterns (Macfarlane et al., 2008). 6 The WET-Health tool evaluates the extent to which anthropogenic changes have impacted upon wetland functioning or condition through assessment of the above-mentioned three factors. 7 Refer to Section 6.3 of the Vegetation and Wetland Assessment (Appendix F-2) for more detail.

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associated with a largely modified wetland system. Changes to the functionality (hydrology, geomorphology and vegetation) and integrity of the wetlands include:

• Obstruction of the flow by the existing road (M13). • Pollution (plastic, cardboard, tins) within the permanent zone of saturation of the wetland. • Infestation of alien invasive vegetation. A Level 2 WET-EcoServices assessment was undertaken for the HGM A and B wetlands occurring on site. A Level 2 assessment is the highest WET-EcoServices assessment that can be undertaken and involves an on-site assessment as well as desktop work. the results of the Level 2 assessment are provided in Table 10-6.

Table 10-6: Results of the Level 2 WET-EcoServices assessment on HGM A and B

HGM Main eco-services provided HGM A (seep wetland) • Sediment trapping. • Streamflow regulation. • Erosion control. • Phosphate, nitrate and toxicant trapping. • Carbon storage. HGM B (channelled valley bottom wetland) • Flood attenuation. • Streamflow regulation. • Phosphate, nitrate and toxicant trapping. • Erosion control (to a larger extent). • Carbon sequestration. • Maintenance of biodiversity. • Water supply for humans. The Ecological Importance and Sensitivity of both the wetland units were recorded as being Low. This is due to the largely degraded nature of the wetland systems sedimentation, presence of alien invasive species, and pollution. Despite this, some natural vegetation was observed in clumps around the wetland and this provides natural habitat for varying faunal species (reptiles, amphibians and birds). Surface water was also observed in the permanent zones of saturation of both wetlands increasing the likelihood of these wetlands being used by faunal species for breeding, feeding and protection.

Wetland Buffers The Preliminary Guideline for the Determination of Buffer Zones for Rivers, Wetlands and Estuaries (WRC, 2015) was used for the determination of buffer zones associated with the channelled valley bottom wetland and seep, in relation to the proposed development. The buffer width serves to protect the ecosystem services provided by the two wetlands.

The results showed that a 30m buffer is appropriate for the protection of the channelled valley bottom wetland (HGM B), as well as the seep wetland (HGM A). Results took into consideration the basal cover of vegetation, the natural slope and the susceptibility to erosion.

10.3.2 Impact Assessment a) Impact B1 – Vegetation Alien plants outcompete the indigenous plants by easily establishing a lateral root system thereby causing a reduction in the indigenous vegetation and resultant decrease in biodiversity. The removal of existing indigenous vegetation in order to construct the houses will have negative impacts on the functionality of the vegetation habitats. Disturbed areas will quickly become colonized by alien invasive species if no management plan is implemented along the footprint of the disturbed wetland areas. The result will be a knock-on effect on the processes governing the functionality of the wetland.

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During the operational phase, alien infestation rates of the vegetation within the wetland and associated buffers could increase if control measures are not implemented correctly during the construction phase of the project.

The assessment of potential construction and operation related impacts are presented in Table 10-7 and Table 10-8 respectively.

Table 10-7: Impact B1-1: Disturbance of vegetation during Construction

Impact B1-1: Construction activities involve removal of indigenous vegetation, which provides an area for alien plant establishment and infestation with a resultant loss of biodiversity and potential reduction in the functionality of the wetland Timing: During the construction activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 70 Management 5 1 8 14 5 1 (high) Management measures: • All proposed infrastructure, including stormwater drains, access roads, houses and services must be situated outside of the delineated wetland and associated 30m buffer. • Vegetation clearing must only be undertaken as and when necessary. The entire construction area must not be stripped of vegetation prior to commencing construction activities. • No stockpiling of any materials may take place within the wetlands or associated buffer zone. • Disturbed sites must be rehabilitated as soon as construction in an area is complete or near complete and not left until the end of the project. • Indigenous vegetation should be protected as far possible. • A mixture of locally sourced grasses and trees must be used during rehabilitation. • The delineated wetlands and associated buffer zones must be cordoned off with a physical barrier and established as no-go zones for the duration of the construction phase. • Monitor all sites disturbed by construction activities for colonisation by exotics or alien invasive plants and control these as they emerge. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 36 Management 2 1 6 9 4 1 (moderate)

Table 10-8: Impact B1-2: Disturbance of vegetation during Operation

Impact B1-2: Disturbance linked to the human presence and activities in the wetland area is likely to result in opportunities for alien plants to recolonise any rehabilitated areas with the resultant increase in competition and potential replacement of indigenous species causing the alteration of indigenous species composition across the site and vegetation structure of the wetland Timing: During the operational activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 70 Management 5 1 8 14 5 1 (high) Management measures: • Ongoing alien plant control must be undertaken. An ongoing management plan must be implemented for the clearing of alien species. • The operational phase EMPr must incorporate recommendations provided in this report. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 24 Management 3 1 4 8 4 1 (low)

b) Impact B2 – Hydrology Construction activities (i.e. stockpiling and bulk earth layer works) temporarily alter the nature of surface flows feeding the wetland. This could either be through impounding or increasing the velocity of surface flows (flood peaks) by reducing surface roughness and promoting the concentration of flows.

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As a result of the gently sloping topography and nature of the soils onsite, the removal of the rich organic topsoil from the wetlands will expose the subsoil to erosion factors leading to the formation of gullies which concentrate flow through the wetland. Furthermore, sedimentation of the deposited soil poses a risk to the functional integrity of this system in terms of its hydrology. If storm water is poorly managed onsite during construction, the wetland hydrological condition could deteriorate temporarily with the resultant loss in wetland functioning.

An increase in post-development runoff as a result of increased hardened surfaces is expected due to the nature of the project (i.e. building of roofs, pavements and driveways). Increased hardened surfaces could result in decreased infiltration capacity and an increase in stormwater runoff which may cause erosion and sedimentation of the wetlands. An increase in hardened surfaces could also cause a decrease in interflow (shallow subsurface flow) and base flow from the developed site, with changes in the volume of interflow typically influencing the hydroperiod of the wetland that is fed by shallow subsurface flow. This could then cause a reduction in the functionality and extent of the wetland.

The assessment of potential construction and operation related impacts are presented in Table 10-9 and Table 10-10 respectively.

Table 10-9: Impact B2-1: Surface flow disruption during Construction

Impact B2-1: Disruption of surface flows feeding the wetlands on site could cause erosion and the resultant sedimentation of the wetlands Timing: During the construction activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 85 Management 5 2 10 17 5 1 (high) Management measures: • All proposed infrastructure, including stormwater drains, access roads, houses and services must be situated outside of the delineated wetland and associated 30m buffer. • Stormwater management and infrastructure design must be undertaken to cater for intermittent run-off associated with the ephemeral drainage lines located within TI Area C. Incorporation of Sustainable Urban Drainage Systems (SUDS) as part of “soft-engineering” methods for managing the run-off is recommended. • A Stormwater Management Plan (SWMP) for the whole project area is to be prepared by an appropriately qualified and experienced engineer. Careful consideration is to be given to protection of the wetlands and TI Area C. The SWMP must be approved by EDTEA and DWS prior to commencement of construction. • Vegetation clearing must only be undertaken as and when necessary. The entire construction area must not be stripped of vegetation prior to commencing construction activities. • No stockpiling of any materials may take place within the wetlands or associated buffer zone. • Erosion control measures must be implemented in areas sensitive to erosion such as edges of slopes, exposed soil etc. These measures include but are not limited to - the use of sandbags, hessian sheets, silt fences and retention or replacement of indigenous vegetation. • Surface water or storm water should not be allowed to be concentrated, or to flow down cut or fill slopes without erosion protection measures being in place. • Disturbed sites must be rehabilitated as soon as construction in an area is complete or near complete and not left until the end of the project. • The delineated wetlands and associated buffer zones must be cordoned off with a physical barrier and established as no-go zones for the duration of the construction phase. Should infrastructure be constructed within the wetland area and/or the associated buffer the disturbed wetland vegetation must be rehabilitated as soon as construction in this area has ended. Rehabilitation of the wetlands and associated buffer must form part of the EMPr. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 40 Management 3 1 6 10 4 1 (moderate)

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Table 10-10: Impact B2-2: Disturbance of hydrological processes during operation

Impact B2-2: An increase in post-development runoff as a result of increased hardened surfaces could result in decreased infiltration capacity and an increase in stormwater runoff, which may cause erosion and sedimentation of the wetlands on site Timing: During the operation activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 85 Management 5 2 10 17 5 1 (high) Management measures: • During the operational phase of the project the drainage of the access roads must be regularly inspected for signs of erosion and corrective measures taken if erosion becomes a problem. • The operational phase EMPr must incorporate recommendations provided in this report. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 36 Management 5 1 6 12 3 1 (moderate)

c) Impact B3 – Geomorphology impacts Alteration of the hydrology, as a result of construction related impacts, could exacerbate the rate of erosion within the wetland system, and consequently lead to a change in the sediment regime within the wetland system. Prolonged stockpiles upslope of the wetland can easily become a source of sediment input, leading to the accumulation of fan-like plumes at the tail of the wetland. This accumulation of sediment in the wetland could eventually lead to the alteration of the geomorphological integrity of the wetland.

Prolonged increases in flood peaks generated by concreted surfaces, which result in increased discharge and flow velocities, could increase the intensity and frequency of erosive flows. Increased erosion and sediment loss is likely to affect the geomorphological condition and processes over increased time periods, and the risk of impact could be significant if unmitigated.

The assessment of potential construction and operation related impacts are presented in Table 10-11 and Table 10-12 respectively.

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Table 10-11: Impact B3-1: Alteration of geomorphological integrity of wetland during Construction

Impact B3-1: Accumulation of sediment in the wetland as a result of construction activities could eventually lead to the alteration of the geomorphological integrity of the wetlands Timing: During the construction activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 70 Management 5 1 8 14 5 1 (high) Management measures: • All proposed infrastructure, including stormwater drains, access roads, houses and services must be situated outside of the delineated wetland and associated 30m buffer. • Stormwater management and infrastructure design must be undertaken to cater for intermittent run-off associated with the ephemeral drainage lines located within Recommended Limited Development Zone8 (0). Incorporation of Sustainable Urban Drainage Systems (SUDS) as part of “soft-engineering” methods for managing the run-off is recommended. • A Stormwater Management Plan (SWMP) for the whole project area is to be prepared by an appropriately qualified and experienced engineer. Careful consideration is to be given to protection of the wetlands and Recommended Limited Development Zone. the SWMP must be approved by the EDTEA and DWS prior to commencement of construction. • Vegetation clearing must only be undertaken as and when necessary. The entire construction area must not be stripped of vegetation prior to commencing construction activities. • No stockpiling of any materials may take place within the wetlands or associated buffer zone. • Erosion control measures must be implemented in areas sensitive to erosion such as edges of slopes, exposed soil etc. These measures include but are not limited to - the use of sandbags, hessian sheets, silt fences and retention or replacement of indigenous vegetation. • Surface water or storm water should not be allowed to be concentrated, or to flow down cut or fill slopes without erosion protection measures being in place. • Disturbed sites must be rehabilitated as soon as construction in an area is complete or near complete and not left until the end of the project. • The delineated wetlands and associated buffer zones must be cordoned off with a physical barrier and established as no-go zones for the duration of the construction phase. Should infrastructure be constructed within the wetland area and/or the associated buffer the disturbed wetland vegetation must be rehabilitated as soon as construction in this area has ended. Rehabilitation of the wetlands and associated buffer must form part of the EMPr. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 27 Management 2 1 6 9 3 1 (low)

Table 10-12: Impact B3-2: Alteration of geomorphological integrity of wetland during operation

Impact B3-2: Accumulation of sediment in the wetland as a result of uncontrolled run-off could eventually lead to the alteration of the geomorphological integrity of the wetlands Timing: During the operation activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 85 Management 5 2 10 17 5 1 (high) Management measures: • During the operational phase of the project the drainage of the access roads must be regularly inspected for signs of erosion and corrective measures taken if erosion becomes a problem. • The operational phase EMPr must incorporate recommendations provided in this report. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 36 Management 5 1 6 12 3 1 (moderate)

8 Referred to as TI Area C in the wetland specialist report.

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d) Impact B4 – Water quality impacts Mismanagement of waste and pollutants like hydrocarbons, cement, construction waste and hazardous chemicals could result in these substances entering and polluting sensitive natural environments either directly through surface runoff during rainfall events, or subsurface water movement. An increase in pollutants will lead to changes in the water quality of the wetland affecting its ability to act as an ecological habitat for faunal species found within the wetland system (e.g. stream clicking frogs, Strongylopus grayii, were identified onsite).

Household contaminants such as detergents, soaps and organic waste could potentially be discharged into the wetlands. Gardens/lawns can be a source of nutrification from of fertiliser application. Oils and greases are likely to pollute the wetland due to first flush effects associated with the adjacent roads.

[Note: An impact assessment for onsite sewage treatment has not been undertaken as the design suggests the developer will connect sewage disposal facilities to the existing municipal sewer reticulation system.]

The assessment of potential construction and operation related impacts are presented in Table 10-13 and Table 10-14 respectively.

Table 10-13: Impact B4-1: Pollution of water resources during Construction

Impact B4-1: Pollution of water resources on site through mismanagement of waste and pollutants during construction activities Timing: During the construction activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 75 Management 5 2 8 15 5 1 (high) Management measures: • All proposed infrastructure, including stormwater drains, access roads, houses and services must be situated outside of the delineated wetland and associated 30m buffer. • Stormwater management and infrastructure design must be undertaken to cater for intermittent run-off associated with the ephemeral drainage lines located within TI Area C. Incorporation of Sustainable Urban Drainage Systems (SUDS) as part of “soft-engineering” methods for managing the run-off is recommended. • A Stormwater Management Plan (SWMP) for the whole project area is to be prepared by an appropriately qualified and experienced engineer. Careful consideration is to be given to protection of the wetlands and TI Area C. the SWMP must be approved by the EDTEA and DHSWS prior to commencement of construction. • No stockpiling of any materials may take place within the wetlands or associated buffer zone. • The delineated wetlands and associated buffer zones must be cordoned off with a physical barrier and established as no-go zones for the duration of the construction phase. Should infrastructure be constructed within the wetland area and/or the associated buffer the disturbed wetland vegetation must be rehabilitated as soon as construction in this area has ended. Rehabilitation of the wetlands and associated buffer must form part of the EMPr. • All waste generated during construction is to be disposed of at a registered facility and no washing of paint brushes, containers, wheelbarrows, spades, picks or any other equipment adjacent to or within the wetland is permitted. • Release of any hazardous substance i.e. cement, oil, that could be toxic to fauna or faunal habitats within the wetland and associated buffer must be avoided. • Portable toilets must be placed 50m away from the wetland and associated buffer. • Do not locate the construction camp or any depot for any substance which causes or is likely to cause pollution within a distance of 50m of the wetland and the associated buffer. • Spillages of fuels, oils and other potentially harmful chemicals must be cleaned up immediately and contaminants properly drained and disposed of using proper solid/hazardous waste facilities (not to be disposed of within the natural environment). Any contaminated soil must be removed, and the affected area rehabilitated immediately. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 36 Management 2 1 6 9 4 1 (moderate)

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Table 10-14: Impact B4-2: Pollution of water resources during operation

Impact B4-2: Pollution of water resources Timing: During the operation activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 75 Management 5 2 8 15 5 1 (high) Management measures: • During the operational phase of the project the drainage of the access roads must be regularly inspected for signs of erosion and corrective measures taken if erosion becomes a problem. • The operational phase EMPr must incorporate recommendations provided in this report. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 30 Management 3 1 6 10 3 1 (moderate)

10.4 Heritage This section is informed by: • Heritage Impact Assessment: Proposed Westville Triangle Housing Development, eThekwini Municipality, KZN Report (Albert van Jaarsveld Heritage Resources Manager, September 2009). Refer to Appendix F-3. • Heritage Impact Assessment: Proposed Westville Triangle Housing Development, eThekwini Municipality, KZN Letter (Albert van Jaarsveld Heritage Resources Manager, April 2019). Refer to Appendix F-4.

10.4.1 Baseline Description Following a desktop survey of existing literature on the general History and Archaeology of the area, a field survey was carried out on 21 September 2009. Ground visibility was relatively clear, although in some places restricted as the result of dense overgrowth, mainly due to alien invaders.

The results of the specialist investigation concluded that no remains of the Stone or Iron Ages were observed, no declared Heritage Sites (former National Monuments) are in close vicinity to the site and no buildings occur on the site.

In April 2019 the heritage specialist provided a letter (refer to Appendix F-4) confirming that it is not anticipated that the development will have any influence on cultural heritage resources in the area. Archaeological deposits are most unlikely.

10.4.2 Impact Assessment It is not anticipated that the development will have any influence on cultural heritage resources. The risk of archaeological sites being accidentally unearthed during the construction phase is minimal, although it always remains a possibility.

The assessment of potential impacts is presented in Table 10-15.

.

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Table 10-15: Impact H1: Disturbance of archaeological sites during Construction

Impact H1: Construction activities involve earth moving that may unearth archaeological sites Timing: During the construction activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 5 Management 2 1 2 5 1 1 (low) Management measures: • The construction teams should be made aware that archaeological material (e.g. pottery, graves, remains of dwellings, etc.) that often occur underground. • Should any archaeological material be unearthed during the construction process, all construction activities are to be halted immediately and Amafa alerted. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 5 Management 2 1 2 5 1 1 (low)

10.5 Socio-economic The socio-economic environment may be described as that part of the environment which has its origin or being in human activities i.e. social, economic, cultural and political objects and processes (DEAT, 1992).

10.5.1 Baseline Description The key socio-economic impacts will be experienced during the construction phase of the project as a result of the activities being undertaken. The activities undertaken will potentially cause a nuisance to the surrounding landowners as they will generate noise, dust and an increase in vehicle and pedestrian movement (refer to Section 10.2). The construction activities might also affect the health and safety of the workers on site and the surrounding residents.

The potential operational phase impacts are related to crime and an increase in traffic (refer to Section 10.2).

10.5.2 Impact Assessment a) Impact SE1 – Employment opportunities The construction phase of the project is scheduled to last approximately twenty-four (24) months and in this time, skilled and un-skilled labour will be required for construction activities. Local labour will be sourced, where possible, for the construction phase. The result of temporary employment opportunities is an improved quality of life.

During the operational phase skilled and un-skilled labour will be required in the form of domestic workers, personal security, garden maintenance, building maintenance etc. The result of employment opportunities during the operation phase is an improved quality of life.

The assessment of potential construction and operation related impacts are presented in Table 10-16 and Table 10-17 respectively.

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Table 10-16: Impact SE1-1: Employment opportunities during Construction

Impact SE1-1: Employment opportunities created during construction activities potentially result in improvement in quality of life (NOTE: this is a positive impact) Timing: During the construction activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before & After 55 (moderate) Management 2 3 6 11 5 1 (positive impact) Management measures: No Mitigation measures are proposed.

Table 10-17: Impact SE1-2: Employment opportunities during Operation

Impact SE1-2: Improved quality of life through temporary employment opportunities (NOTE: this is a positive impact) Timing: During the operation activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 52 (moderate) Management 4 3 6 13 4 1 (positive impact) Management measures: No Mitigation measures are proposed.

b) Impact SE2 – Health and safety During construction, health and safety impacts can affect not only those working on the site, but they can also affect those residing in close proximity, as well as those passing through/by the site. Health and safety impacts must be assessed before construction workers commence work, as well as during their work activities so as to prevent harm to themselves, either via machinery operation, construction materials or through improper ergonomics.

The safety of residents and construction workers is of great importance as people can be injured and in extreme circumstances death may even result. For these reasons it is very important that mitigation measures are strictly adhered to and enforced. Injury and loss of life is considered highly significant and once it has occurred cannot be reversed.

The assessment of potential impacts is presented in Table 10-18.

Table 10-18: Impact SE2: Health and safety during Construction

Impact SE2: Injury and/or loss of life to people working on the site, people residing in close proximity and people passing through/by the site as a result of construction activities Timing: During the construction activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 65 Management 2 1 10 13 5 1 (high) Management measures: • All relevant Health and Safety legislation as required in South Africa should be strictly adhered to including the Occupational Health & Safety Act, 1993 (Act No. 85 of 1993). • Potentially hazardous areas (i.e. trenches) will be demarcated and clearly marked. • The conditions of the EMPr (refer to Appendix C) must be implemented and monitored. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 14 Management 2 1 4 7 2 1 (low)

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c) Impact SE3 – Noise The establishment of the Westville Triangle Housing Development is within a residential area. As such the noise from construction activities could potentially cause a nuisance to the surrounding residents residing in the area. Noise impacts are likely to be of short duration occurring only during the construction phase and they may be adequately mitigated via strict control and monitoring.

The assessment of potential impacts is presented in Table 10-19.

Table 10-19: Impact SE3: Noise during Construction

Impact SE3: Noise from construction activities could potentially cause a nuisance to the surrounding residents residing in the area Timing: During the construction activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 50 Management 2 2 6 10 5 1 (moderate) Management measures: • Construction vehicles will be fitted with standard silencers prior to the beginning of construction. • Equipment that is fitted with noise reduction facilities (e.g. Side flaps, silencers and mufflers etc.) will be used as per operating instructions and maintained properly during site operations. • Noise impacts will be reduced by maintaining normal working hours (07h00 to 17h00, Mondays to Fridays) and should after hours construction work be required adjacent landowners will be notified 24 hours prior to the activity. • The conditions of the EMPr (refer to Appendix C) must be implemented and monitored. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 22 Management 2 2 4 11 2 1 (low)

d) Impact SE4 – Air quality Dust may be created through the construction process and fires on-site, as utilised by construction workers during the construction phase, may pose a risk and reduce the air quality on site and the surrounding area.

The assessment of potential impacts is presented in Table 10-20.

Table 10-20: Impact SE4: Air quality during Construction

Impact SE4: Deterioration in air quality from dust that may be created through the construction process and fires on-site Timing: During the construction activities Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss Before 50 Management 2 2 6 10 5 1 (moderate) Management measures: • No fires will be permitted for any purposes whatsoever. • The production of dust and damage caused by dust will be limited through regular watering of the work areas. Where dust is unavoidable in residential or commercial areas, screening will be required utilising wooden supports and shade cloth. • Stripping of vegetation and existing material will be limited to necessary working areas. • Vehicles and machinery will be kept in good working order and to meet manufacturer’s specifications for safety, fuel consumption etc. Should excessive emissions be observed, the Contractor will have the equipment seen to as soon as possible. This will include emissions from the equipment and any load it may be carrying. • Lime, concrete and other powders must not be mixed during excessively windy conditions. • The conditions of the EMPr (refer to Appendix C) must be implemented and monitored. Duration Extent Magnitude Consequence Probability Significance Irreplaceable Loss After 22 Management 2 2 4 11 2 1 (low)

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10.6 Cumulative Impacts Cumulative impacts are those that result from the successive, incremental, and /or combined effects of an action, project, or activity when added to other existing, planned, and /or reasonably anticipated future ones (IFC, 2013).

Impacts cannot be assessed in isolation. An integrated approach to impact assessment requires that cumulative impacts be included in the assessment of individual impacts. Cumulative impacts are therefore assessed de facto.

This section describes the cumulative nature of the environmental aspects and impacts identified for the project within the context of the receiving environment in the broader Westville area.

10.6.1 Traffic The TIA has considered the potential impact the proposed development will potentially have on the existing traffic situation. This assessment considered the three major intersections potentially affected by the development and the potential cumulative effect on traffic in the suburb. The TIA concluded that for all three intersections the intersection will operate at an acceptable level of service during the forecasted 2024 conditions as stipulated in the Highway Capacity Manual 2000.

10.6.2 Biodiversity The loss of biodiversity across the EMA is a matter of concern as more and more undeveloped areas are being developed. Whilst this development is establishing the housing project on a Greenfields site, the sensitive wetland areas, and associated buffers have been largely untouched and excluded from the development footprint in an attempt to maintain the biodiversity on site.

11 Environmental Management Programme An EMPr has been prepared for the construction and operational phases of the proposed development, in accordance with the requirements in Appendix 4 of GN 326, and is included in Appendix C. The EMPr specifies the methods and procedures for managing the environmental aspects of the proposed development, as informed by the specialist studies and good practice. Monitoring requirements are also stipulated. The EMPr must be implemented (along with the requirements of the Environmental Authorisation) and auditing is to be undertaken on a regular basis to ensure compliance with the EMPr.

12 Environmental Impact Statement In accordance with Item 3(1)(p) in Appendix 1 of GN 326, this chapter provides a reasoned opinion as to whether the proposed activity should or should not be authorised, and recommended conditions that should be made in respect of that authorisation.

Although SRK is not an elected entity mandated to make decisions on behalf of society, we hereby provide a qualified opinion. In this regard, SRK is of the opinion that this BA Report, EMPr and the attached specialist reports comply with the relevant guidelines and contain all the information required in terms of GN 326 to enable EDTEA to take a decision.

The fundamental decision is whether to allow development that brings socio-economic advantages and is consistent with planning and development policies, given the potential environmental impacts. In this case, identified potential negative impacts arising from the proposed Westville Triangle Housing Project can be managed to remain within acceptable environmental limits so long as measures set out in the EMPr are implemented.

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It is noted that the stormwater management plan was not available at the time of the assessment of potential impacts. This has therefore been excluded from this assessment. Based on the specialist input, however, it is recommended that the final stormwater management plan is submitted to, and approved by the EDTEA and the DHSWS prior to commencement of construction.

SRK believes that the specialist studies have confirmed that the preferred layout alternative (as presented in Figure 5-1) is environmentally acceptable. The EMPr stipulates the mitigation measures identified that will mitigate the potential impacts identified to within acceptable limits. In conclusion, SRK is of the opinion that on purely ‘environmental’ grounds (i.e. the project’s potential socio-economic and biophysical implications) the application, as it is currently articulated in this BA Report, should be approved (i.e. for the development footprint as indicated in Figure 5-1). This statement is conditional on implementation of the mitigation measures stipulated in the EMPr. These measures include undertaking further investigations and monitoring during the remaining project phases and the operational phase. The results of the investigations and monitoring may result in refinement of certain environmental measures and provisions.

12.1 Impact Summary A summary of the positive and negative impacts and risks of the proposed activity is provided in Table 12-1.

Table 12-1: Impact Assessment Summary

Impact Before/After Consequence Probability Significance mitigation T1-1: Additional traffic will be generated Before 50 10 5 on the existing road network and may mitigation: (moderate) affect the level of service After mitigation: 6 2 12 (low) T1-2: Additional traffic will be generated Before 8 3 24 (low) on the existing road network and may mitigation: affect the level of service After mitigation: 8 3 24 (low) T2-1: Additional traffic will be generated Before 5 1 5 (low) that may affect the space available for mitigation: pedestrian and cyclist movement After mitigation: 5 1 5 (low) B1-1: Construction activities involve Before 14 5 70 (high) removal of indigenous vegetation, which mitigation: provides an area for alien plant establishment and infestation with a After mitigation: 36 resultant loss of biodiversity and potential 9 4 reduction in the functionality of the (moderate) wetland B1-2: Disturbance linked to the human Before 14 5 70 (high) presence and activities in the wetland mitigation: area is likely to result in opportunities for alien plants to recolonise any rehabilitated After mitigation: areas with the resultant increase in competition and potential replacement of 8 4 24 (low) indigenous species causing the alteration of indigenous species composition across

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Impact Before/After Consequence Probability Significance mitigation the site and vegetation structure of the wetland B2-1: Disruption of surface flows feeding Before 17 5 85 (high) the wetlands on site could cause erosion mitigation: and the resultant sedimentation of the After mitigation: 40 wetlands 10 4 (moderate) B2-2: An increase in post-development Before 17 5 85 (high) runoff as a result of increased hardened mitigation: surfaces could result in decreased infiltration capacity and an increase in After mitigation: 36 stormwater runoff, which may cause 12 3 erosion and sedimentation of the wetlands (moderate) on site B3-1: Accumulation of sediment in the Before 14 5 70 (high) wetland as a result of construction mitigation: activities could eventually lead to the After mitigation: alteration of the geomorphological 9 3 27 (low) integrity of the wetlands B3-2: Accumulation of sediment in the Before 17 5 85 (high) wetland as a result of uncontrolled run-off mitigation: could eventually lead to the alteration of After mitigation: 36 the geomorphological integrity of the 12 3 wetlands (moderate) B4-1: Pollution of water resources on site Before 15 5 75 (high) through mismanagement of waste and mitigation: pollutants during construction activities After mitigation: 36 9 4 (moderate) B4-2: Pollution of water resources Before 15 5 75 (high) mitigation: After mitigation: 30 10 3 (moderate) Before H1: Construction activities involve earth 5 1 5 (low) moving that may unearth archaeological mitigation: sites After mitigation: 5 1 5 (low) SE1-1: Employment opportunities created Before & after during construction activities potentially mitigation: 55 11 5 result in improvement in quality of life (moderate) (NOTE: this is a positive impact) SE2: Injury and/or loss of life to people Before 13 5 65 (high) working on the site, people residing in mitigation: close proximity and people passing After mitigation: through/by the site as a result of 7 2 14 (low) construction activities SE3: Noise from construction activities Before 50 10 5 could potentially cause a nuisance to the mitigation: (moderate) surrounding residents residing in the area After mitigation: 11 2 22 (low) SE4: Deterioration in air quality from dust Before 50 10 5 that may be created through the mitigation: (moderate) construction process and fires on-site After mitigation: 11 2 22 (low)

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12.2 Recommended Conditions of Authorisation If EDTEA authorises this NEMA application, the following project specific conditions (as included in the EMPr) are also recommended for inclusion in the Environmental Authorisation: • A Stormwater Management Plan (SWMP) for the whole project area is to be prepared by an appropriately qualified and experienced engineer. Careful consideration is to be given to protection of the wetlands and TI Area C. The SWMP must be approved by EDTEA and DWS prior to commencement of construction • The mitigation measures stipulated in Tables 10-2 to 10-20 must be implemented. • The EMPr and Environmental Authorisation, assuming such, must be complied with. 13 Assumptions, Limitations and Deviations In accordance with Item 3(1)(o) in Appendix 1 of GN 326, this chapter describes the assumptions, uncertainties and gaps in knowledge which relate to the assessment and mitigation measures proposed.

As is standard practice, the report is based on a number of assumptions and is subject to certain limitations. These are as follows:

• Information provided by Woodglaze Trading and its affiliates is assumed to be accurate and correct. • SRK’s assessment of the significance of impacts of the proposed development on the affected environment has been based on the assumption that the activities will be confined to those described in Chapter 5. If there are any substantial changes to the project description, impacts may need to be reassessed. • It is assumed that the public participation process undertaken during the BA process has identified all relevant concerns of stakeholders. • Woodglaze Trading and its affiliates will in good faith implement the agreed mitigation measures identified in this report and the attached EMPr. To this end, it is assumed that Woodglaze Trading and its affiliates will commit sufficient resources and employ suitably qualified personnel. Notwithstanding the above, SRK is confident that these assumptions and limitations do not compromise the overall findings of the report.

14 EAP Affirmation Section 16 (1) (b) (iv) and Appendix 1 Section 3 (1) (r) of the EIA Regulations, 2014 (promulgated in terms of the NEMA), require an undertaking under oath or affirmation by the EAP in relation to:

• The correctness of the information provided in the report. • The inclusion of comments and inputs from stakeholders and interested and affected parties. • Any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested or affected parties. • The level of agreement between the EAP and interested and affected parties on the Plan of Study for undertaking the environmental impact assessment. SRK and the EAPs managing this project hereby affirm that:

• To the best of our knowledge the information provided in the report is correct, and no attempt has been made to manipulate information to achieve a particular outcome. Some information, especially pertaining to the project description, was provided by the applicant and/or their sub- contractors. In this respect, SRK’s standard disclaimer (inserted in this report) pertaining to information provided by third parties applies. • Comments and inputs from interested and affected parties from the announcement phase of the process have been captured in Table 9-1. Comments on the Draft BAR will be captured in the Final BAR. No attempt to manipulate such comments or inputs to achieve a particular outcome

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have or will be made. Written submissions are included in Appendix E-4. For the sake of brevity, not all comments have been recorded verbatim. • If applicable, information and responses provided by the EAP to interested and affected parties are clearly presented in the report. Where responses are provided by the applicant (not the EAP), these are clearly indicated.

Prepared by

______

Mrs. Tamaryn Hale (Cert EAP; Pr. Sci. Nat.)

Senior Environmental Scientist

Project Partner

______

Mr. Marius van Huyssteen

Partner

All data used as source material plus the text, tables, figures, and attachments of this document have been reviewed and prepared in accordance with generally accepted professional engineering and environmental practices.

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Appendices

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Appendix A: Environmental Assessment Practitioner Curriculum Vitae and Declaration of Interest

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Appendix B: Maps

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Appendix C: Construction Environmental Management Programme (EMPr)

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Appendix D: Letter Confirming Ownership

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Appendix E: Public Participation Record 1) Minutes of the Pre-application Meeting 2) Register of Interested and Affected Parties 3) Background Information Document & Proof of Circulation 4) Comments Received from Interested and Affected Parities 5) Site Notices 6) Advertisement Tear Sheet

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Appendix F: Specialist Investigations 1) Traffic Impact Assessment 2) Vegetation and Wetland Assessment 3) Heritage Impact Assessment – 2009 4) Heritage Impact Assessment – 2019 5) Sewer Management Plan

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Appendix G: National Environmental Screening Tool

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SRK Report Distribution Record

Report No. 496762/DBAR-01

Name/Title Company Copy File Type Date Authorised by Ms. Natasha Brijlal / EDTEA 1 Electronic November T. Hale Mr. Ntuthuko Mbewana 2020 Mr. Deepak Rampaul Zimanga Urban 2 Electronic November T. Hale and Rural Design 2020 Durban Library Copy SRK 3 Electronic November T. Hale 2020

Approval Signature:

This report is protected by copyright vested in SRK Consulting (South Africa) (Pty) Ltd. It may not be reproduced or transmitted in any form or by any means whatsoever to any person without the written permission of the copyright holder, SRK.

HALT//VHUY 496762_WestTriBA_Draft BAR_Final_20201113_Comp November 2020