Botanical Assessment of Proposed Upgrade of Section 3 of N7, Piketberg – Piekenierskloof Pass, Western Cape

______NICK HELME BOTANICAL SURVEYS PO Box 22652 Scarborough 7975 Ph: 021 780 1420 cell: 082 82 38350 email: [email protected] Pri.Sci.Nat # 400045/08

BOTANICAL ASSESSMENT OF PROPOSED UPGRADE OF SECTION 3 OF N7, PIKETBERG – PIEKENIERSKLOOF PASS, WESTERN CAPE.

Prepared for: SLR Consulting (South Africa) Pty Ltd, Cape Town

Client: SANRAL and JG Afrika (Pty) Ltd.

09 September 2019

DECLARATION OF INDEPENDENCE In terms of Chapter 5 of the National Environmental Management Act of 1998 specialists involved in Impact Assessment processes must declare their independence and include an abbreviated Curriculum Vitae.

I, N.A. Helme, do hereby declare that I am financially and otherwise independent of the client and their consultants, and that all opinions expressed in this document are substantially my own.

NA Helme

Abridged CV: Contact details as per letterhead. Surname : HELME First names : NICHOLAS ALEXANDER Date of birth : 29 January 1969 University of Cape Town, South Africa. BSc (Honours) – Botany (Ecology & Systematics). 1990. SACNASP Registration No: 400045/08 (Pri.Sci.Nat) BEE Level Four Contributor BE # 1915.

Since 1997 I have been based in Cape Town, and have been working as a specialist botanical consultant, specialising in the diverse flora of the southwestern Cape. Since the end of 2001 I have been working on my own and trade as Nick Helme Botanical Surveys.

A selection of work undertaken over the last few years is as follows:  Botanical assessment of Portion 15 of Bottelfontein 11, Redelinghuys (Cederberg Environmental 2018)  Botanical assessment of Ptn of Wittewater, Piketberg (Footprint Environmental 2018)  Botanical assessment of Rietvlei, Koue Bokkeveld (Footprint Environmental 2018)  Botanical assessment of Sebulon farm, Redelinghuys (Footprint Environmental 2018)  Botanical assessment of Draaihoek farm, Leipoldtville (Footprint Environmental 2018)  Botanical assessment of Highlands Estate, Hartenbos (Sharples Environmental 2017)

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 Conservation management plan for Hartenbos Heuwels (CapeEAPRac, 2017)  Botanical baseline assessment of Aalwyndal erven 176 & 177, Mossel Bay (Sharples Environmental 2017)  Botanical assessment of proposed expansion of De Keyser Bentonite Mine, Heidelberg (Eco Impact Legal Consulting 2016)  Botanical assessment of proposed development of Erf 3122, Hartenbos Heuwels (Strategic Environmental Focus 2016)  Botanical assessment of Klipfontein farm, Stilbaai (Wild Rescue 2016)  Botanical assessment of proposed dam on Portion 1 of Farm Kampshoogte 138, Riversdale (Cederberg Environmental Assessment Practise 2015)  Ecological assessment of proposed Arcelor Mittal power station, Saldanha (ERM 2015)  Ecological assessment of proposed Globeleq power station, Saldanha (ERM 2015)  Botanical assessment of proposed iGas pipeline Saldanha – Ankerlig (CES/ EOH 2015)  Botanical baseline of Communicare land, Morningstar (mlh architects 2015)  Ecological assessment of proposed refurbishment of 11kV powerline from Kleinmond to Arabella, Western Cape (Landscape Dynamics 2015)  Botanical walkdown study of new Eskom 132kV powerline Ankerlig – Sterrekus (EIMSA 2015)  Botanical assessment of Remainder of Farm Rietfontein 244, Piketberg (Cederberg Environmental Assessment Practise 2014)  Botanical assessment of Remainder of Farm Draaihoek 293, Vredendal (Cederberg Environmental Assessment Practise 2013)  Botanical assessment of Farm Gideonsooord 303, Klawer (Cederberg Environmental Assessment Practise 2013)  Botanical assessment of Farm Patrysberg 344/1, Citrusdal (Cederberg Environmental Assessment Practise 2013)  Scoping study of Proposed Wind and Solar Energy Facility near Laingsburg (CSIR 2011)

TABLE OF CONTENTS

Introduction 1 Terms of Reference 1 Limitations, Assumptions & Methodology 1 Study Area & Regional Context 2 Overview of the Vegetation 4 Impact Assessment 13 The No Go Alternative 18 Required Mitigation 19 Conclusions & Recommendations 21 References 22 Annexures 23

1. INTRODUCTION AND STUDY AREA This botanical assessment was commissioned to inform the environmental authorisation process (Basic Assessment) being undertaken for the proposed upgrade of section 3 of the N7 highway between Piketberg (Km 31.35) and Piekenierskloof Pass (Km 65.30), in the Western Cape (see Figure 1). Additional climbing/passing lanes are proposed, generally on the west side only, and various structures will need to be widened. No borrow pits were assessed.

2. TERMS OF REFERENCE The terms of reference for this study were as follows:  undertake a site visit to assess the vegetation in the study area;  compile a report which describes the vegetation in the study area and places it in a regional context, including its status in terms of regional and national conservation planning literature;  identify and locate any plant Species of Conservation Concern in the study area;  provide an overview and map of the botanical significance (sensitivity) of the proposed project area, indicating any areas of potential concern;  compile an impact assessment that identifies likely botanical impacts of the proposed development and assesses the significance of the botanical impacts, as per standard Impact Assessment methodology; and  provide recommendations to avoid, minimise and mitigate the botanical impacts of the proposed project.

3. LIMITATIONS, ASSUMPTIONS AND METHODOLOGY The survey area was visited on 6 February 2019, and again (briefly) in July 2019. For the initial site survey the entire route was driven in both directions, and the vehicle was stopped wherever any remnant natural habitat was noted within the road reserve or within 20m of the current edge of the road reserve. The relevant patches were then surveyed and the chainage distances were recorded, reading off a hardcopy of the proposed plans. Although the survey was within the summer dry season in this winter rainfall area it was not a bad time to undertake the survey, as some of the potential threatened species along the route were in flower (thanks to good summer rains) and thus identifiable, although none of the spring flowering geophytes and annuals were evident or identifiable – but many of these were noted in the subsequent drive by follow-ups in July 2019. A fairly accurate idea of the priority conservation areas was gained, due to the use of a

combined habitat and species based approach, and confidence in the accuracy of the findings is fairly high.

Reference was also made to published information on the occurrence of threatened plant species along this route, as noted in the text.

No borrow pits were assessed. It is assumed that the road layout provided is relatively accurate in terms of positioning and scale, but it is acknowledged that it may be out by up to 1m in the case of alignments and positioning. Freshwater and faunal aspects are not considered in this report. Standard Impact Assessment methodology was used, and the rating scales and definitions used are as provided by SLR Consulting (see Annexure 1).

Very High sensitivity areas support nationally irreplaceable plant populations or unique botanical features. High sensitivity areas support better quality habitat fragments with large, significant populations of at least one (often two or more) plant Species of Conservation Concern. Medium sensitivity areas support poorer quality habitat remnants and small, regionally insignificant populations of one plant Species of Conservation Concern.

Due to the identification of a Very High sensitivity area on the east side of the route between Km 64.2 and Km 65.3 a revised layout was requested in order to avoid impacts on these No Go areas, and was subsequently provided, and is shown in Figure 7.

4. STUDY AREA & REGIONAL CONTEXT The study area is part of the Fynbos biome and falls within the Greater Cape Floristic Region (GCFR). The GCFR is one of only six Floristic Regions in the world and is the only one largely confined to a single country (the Succulent Karoo component extends into southern Namibia). It is also by far the smallest floristic region, occupying only 0.2% of the world’s land surface, and supporting about 11500 plant species, over half of all the plant species in South Africa (on 12% of the land area). At least 70% of all the species in the Cape region do not occur elsewhere, and many have very small home ranges (these are known as narrow endemics). Many of the lowland habitats are under pressure from agriculture, urbanisation and alien plants, and thus many of the range restricted species are also under severe threat of extinction, as habitat is reduced to extremely small fragments. Data from the nationwide plant Red Listing process undertaken is that

67% of the threatened plant species in the country occur only in the southwestern Cape, and these total over 1800 species (Raimondo et al 2009)! It should thus be clear that the southwestern Cape is a major national and global conservation priority and is quite unlike anywhere else in the country in terms of the number of threatened plant species.

Most of the study area is part of the West Coast Renosterveld bioregion (Mucina & Rutherford 2006) and is in the northern part of what is known as the Swartland. This bioregion has a fairly distinct flora and is particularly rich in locally and regionally endemic plant species, as well as exceptionally rich in plant Species of Conservation Concern, largely due to the large scale habitat loss that has taken place, due mainly to agriculture.

Because of the restricted distribution of many rare plant species within the region, detailed botanical assessments of individual sites are an essential element in the implementation of NEMA legislation which states that “landowners should attempt to avoid or minimise damage to the environment” when undertaking developments.

The CapeNature Spatial Biodiversity Plan 2017 (Pence 2017) has mapped priority conservation areas throughout the province, using best available data, and the resultant maps display Critical Biodiversity Areas (CBAs) and Ecological Support Areas (ESAs). The relevant extract for the northern part of the study area is shown in Figure 2. Other parts of the route are not shown as the habitat remnants within and adjacent to the study area are very small and isolated and are not particularly accurately mapped. Essentially all the undisturbed natural vegetation in the study area can be considered a terrestrial Critical Biodiversity Area (CBA1), as the underlying vegetation type (Swartland Shale Renosterveld) is Critically Endangered on a national basis (DEA 2011). CBA1 is the highest conservation status according to this plan.

Figure 2: Extract of the CapeNature Spatial Biodiversity Plan (2017) for the northern section of the route between Km62.5 and Km65.3 (chainage indicated), showing terrestrial vegetation CBAs (Critical Biodiversity Areas) along this section.

The primary reasons for the mapping of CBAs in this area are that the underlying vegetation type is Critically Endangered, in moderate to good condition, supports threatened plant species, and is needed for achieving national conservation targets, with an additional reason being watercourse or wetland protection (Pence 2017). The CBA mapping along the route is generally supported by my observations.

5. THE VEGETATION ON SITE There is very little remaining natural vegetation along the route, due mainly to intensive agriculture, and often the only remaining natural vegetation is within the road reserve – typically on steep cuttings. It is estimated that a total linear distance of only 8000 – 9000m (26%) of the 34 000m route supports any significant natural vegetation, with negligible or no natural vegetation in the remainder of the study area. Brushcutting (roadside maintenance) continues to negatively impact many of the indigenous vegetation remnants, and about 70% of the road reserve is cut with bossieslaners and tractors, the rest by weedeaters.

The SA Vegetation map indicates that 95% of the original vegetation along the route is classified as Swartland Shale Renosterveld, with 3% being Leipoldtville Sand Fynbos

and 2% being Swartland Silcrete Renosterveld. No extract of this map is included here as it adds little value, as practically the entire study area is a single vegetation type.

Swartland Shale Renosterveld is listed as a Critically Endangered vegetation type on a national basis (DEA 2011). Less than 8% of this vegetation type remains, less than 1% is conserved and the national conservation target is an unreachable 26% (Rouget et al 2004). As noted the primary driver of habitat loss has been agriculture. Given the Critically Endangered status of this vegetation type all remaining example of this habitat, even where fairly degraded, should ideally be conserved.

The following description of the remnant vegetation patches along the route (Medium, High or Very High sensitivity) is arranged according to chainage distances. All other areas are of Low botanical sensitivity and are not described.

Km 33.40 – Km 33.75 High sensitivity vegetation both sides of road, in road reserve only. Natural vegetation occurs mostly in areas not regularly brushcut, although in some cases some of the shrubs have survived the brushcutting. Various bulbs and succulents seen here, some of which likely to be plant Species of Conservation Concern, plus about 20 plants of the shrub Aspalathus wurmbeana (see Plate 1) which is Redlisted as Endangered. This is the most common Species of Conservation Concern within the road reserve, with at least 60 plants recorded along the route. This Aspalathus is a Swartland endemic and is known from about six localities between here and Malmesbury.

Km 33.75 – Km 34.320 Medium sensitivity vegetation in road reserve, both sides of road. Scattered plants of Aspalathus wurmbeana (Endangered), but more disturbed than previous section.

Plate 1: Aspalathus wurmbeana (Endangered) growing in the road reserve at Km33.4. This is the most common plant Species of Conservation Concern within the road reserve, with at least 60 plants recorded along the route.

Km 36.80 – Km 37.31 Medium sensitivity on both sides of road, in road reserve. Scattered indigenous shrubs such as Searsia glauca, Searsia incisa, Pteronia sp., Asparagus rubicundus, Elytropappus rhinocerotis, Aspalathus spinescens, and with alien Maireana brevifolia.

Km 37.60 - Km 37.70 Medium sensitivity on both sides of road, in road reserve. Scattered indigenous shrubs such as Searsia glauca, Searsia incisa, Pteronia sp., Asparagus rubicundus, Elytropappus rhinocerotis, Aspalathus spinescens, some succulents, and with alien Maireana brevifolia.

Km 39.360 – Km 39.680 High sensitivity in road reserve, both sides of road. A few succulents such as Psilocaulon utile, Mesembryanthemum sp., the alien Maireana brevifolia, and about 20 shrubs of Aspalathus wurmbeana (Endangered).

Km 40.50 – Km 40.60 About 5 shrubs of Aspalathus wurmbeana (Endangered) on west side only. Medium sensitivity.

Km 42.090-Km 42.180 Stream crossing with Medium sensitivity natural vegetation both within road reserve and east and west of road, including Calobota cytisoides and Juncus effusus.

Km 42.60 – Km 42.770 High sensitivity with scattered plants of about 10 shrubs of Aspalathus wurmbeana (Endangered), in road reserve both sides.

Km 43.20 – Km 43.420 High sensitivity with scattered plants of about 10 shrubs of Aspalathus wurmbeana (Endangered), in road reserve both sides, plus Tetragonia rosea.

Km 48.00 – Km 48.190 Eastern road reserve is within a Cape Vernal Pool, which is a seasonal wetland, and which is an Endangered habitat (DEA 2011). Five years ago there used to be lots of the wetland bulb Lachenalia bachmanii (Endangered) in this road reserve (see photo on Redlist website for this species at this locality), but it is possible that this has been eliminated by brushcutting. Heavy grazing and drought has impacted on the population of this species east of the road reserve fence. High sensitivity.

Km 55.00 – Km 55.20 High sensitivity remnants in road reserve on east side for whole section, and from Km 55.10 to Km 55.20 on west side.

Km 57.850 Single large plant of Leucadendron brunioides var. flumenlupinum within eastern road reserve, along fence. This species is Redlisted as Critically Endangered. High sensitivity point.

Km 59.60 – Km 59.90 High sensitivity with scattered plants of about 20 shrubs of Aspalathus wurmbeana (Endangered), in road reserve both sides.

Km 60.90 - Km 61.00 Very High sensitivity clay cutting in road reserve on west side only, with Limonium sp. nov. (see Plate 2). This was the only place where this species was

recorded on site, and the plant has been confirmed as an undescribed species known only from clays in the northern Swartland around Eendekuil (Prof. L. Mucina – pers. comm.). Although the habitat (sloping shale bank) it arguably re- creatable it is not known if the species will survive translocation and the site should thus be considered Irreplaceable and consequently a No Go section.

Plate 2: Undescribed Limonium sp. flowering on a clay cutting at Km 61.0. This is the only place where this species was recorded in the study area, and it is locally common here, with at least 300 plants in a 30m long cutting. This is only the second known locality for this new species.

Km 62.90 - Km 63.40 Wetland and drainage line on and within west side of western road reserve. Juncus sp. dominant. Some wetland elements are also present east of the road in the road reserve, with the same species, although ina shorter section. Medium sensitivity.

Km 64.20 – Km 64.50 east side Very High sensitivity section on east side of road, both in road reserve and outside road reserve (see Figure 6). This is the most critical section of the entire route in terms of botanical sensitivity, as the area is known to support at least five threatened plant species and is consequently considered a No Go area. Generally Medium sensitivity in western road reserve.

Plant Species of Conservation Concern (SoCC) in this area include Marasmodes oubinae (Plate 3), Oxalis pallens, Oedera viscosa, Lampranthus aduncus and Annesorhiza refracta.

Marasmodes oubinae is Redlisted as Critically Endangered and is only known from four patches. Six plants were found within the eastern road reserve, five of which are within 1m of the edge of the road verge or pulloff area.

Oxalis pallens is Redlisted as Endangered and is only known from six localities between Clanwilliam and Tygerberg. About 20 plants were previously found within the eastern road reserve, as well as just upslope of the road reserve (pers. obs.; flowers May - June).

Oedera viscosa is Redlisted as Near Threatened and is known from about 15 localities between Piketberg and Tygerberg. About 30 plants of the shrub were found within the eastern road reserve, many within 1m of the road verge or pulloff edge.

Annesorhiza refracta is a cryptic geophyte Redlisted as Endangered and is only known from six localities between here and Tulbagh. About 20 plants were found within the eastern road reserve.

Lampranthus aduncus is a vygie and is the only one of the five not of major concern, as it is more widespread and common (more than 20 known localities) and is Redlisted as Data Deficient. Only 5 plants were found within the eastern road reserve.

Plate 3: The Critically Endangered shrub Marasmodes oubinae in flower (March 2019) within 1m of the road verge edge on east side of the N7 in the area Km 64.30 – 64.50. This patch of about six plants constitutes one of only four known patches of this ultra-rare and threatened plant.

Km 64.50 – Km 65.30 east side This entire section is of Very High sensitivity inside the road reserve. Although Marasmodes oubinae was not recorded here the other four SoCC noted above also occur here in low numbers, plus potentially other threatened species, most of which are geophytes and were consequently not seen during the summer site visit – but include Babiana spp., Oxalis spp, and Hesperantha pallescens (Critically Endangered). Tetragonia nigrescens is common in the brushcut areas (as it is all along the survey route in suitable habitat), with a few patches of alien annual grasses common in the more disturbed parts, such as around some of the telephone poles.

Km 64.20 – Km 65.30 west side Mostly Medium sensitivity, with disturbed remnants of Renosterveld, including Searsia incisa and S. glauca. No recorded SoCC.

Figure 3: Satellite image of Section 3 from start to Km 41.10 showing just the Medium and High botanical sensitivity sections within the road reserves. All unmapped areas deemed to be of Low sensitivity.

Figure 4: Satellite image of Section 3 from Km 41.10 to Km 49.0 showing just the Medium and High botanical sensitivity sections within the road reserves. All unmapped areas deemed to be of Low sensitivity.

Figure 5: Satellite image of Section 3 from Km 49.0 to Km 63.5 showing just the Medium, High and Very High botanical sensitivity sections within the road reserves. All unmapped areas deemed to be of Low sensitivity.

Figure 6: Detail of satellite image of Section 3 from Km 64.2 to Km 65.3 showing the Medium and Very High botanical sensitivity sections within the road reserves. All unmapped areas deemed to be of Low sensitivity.

6. IMPACT ASSESSMENT Impacts may be both direct and indirect. Direct impacts typically occur at the construction phase, and are primarily loss of Critically Endangered vegetation remnants (often including Species of Conservation Concern) and loss of habitat, and this is the primary impact of concern for the vegetation in the study area.

Indirect impacts are harder to identify, quantify and assess, and typically occur at the operational phase, and concern things such as disruption of ecological processes such as fire and pollination, fragmentation of habitat and loss of current ecological connectivity, and introduction of alien species (often associated with soil disturbance). Operational phase impacts of the proposed developments are likely to be Low negative, and are not further assessed, although standard mitigation is given to help minimise the possible indirect (operational phase) impacts.

In terms of direct impacts the duration of the impact for the proposed development is mostly permanent. For annuals most disturbance can be regarded as temporary (as the seeds are highly mobile), but for shrubs, succulents and bulbs it will be permanent. Intensity (severity) can be regarded as High, and the status is negative. Extent can be regarded as mostly local (immediate site), but with the qualifier that the vegetation type concerned is Critically Endangered on a national basis (DEA 2011), and many of the threatened plant species are found nowhere else in the world.

Indirect impacts of the road upgrades are likely to be much less significant and much harder to measure or even observe than the direct impacts, and are hence not considered here in any detail. The most important indirect impacts will be loss of linear ecological connectivity via the road reserve habitat remnants, and possible negative impacts on metapopulation reproductive success of some of the ultra-rare species (e.g. Marasmodes oubinae).

6.1 Impacts on Very High Sensitivity Areas A linear total of 1220m of Very High sensitivity vegetation (all Critically Endangered) is likely to be lost or impacted by the proposed construction (prior to mitigation), in two stretches. The actual total area of the loss is likely to be at least three times this (3m lateral expansion of road and cuttings), and thus might be about 0.4ha. This would directly impact on an undescribed Limonium sp. at Km 61.0 and at least five other plant Species of Conservation Concern (SoCC) in

the eastern road reserve in the area Km 64.20 – Km 63.5, including at least one Critically Endangered species known from here (approx. 20% of known total population) and only 3 other subpopulations (Marasmodes oubinae).

Nobody has ever tried to grow rooted cuttings of any of the shrubby SoCC from this area (Marasmodes oubinae, Aspalathus wurmbeana, Oedera viscosa, Limonium sp. nov.) nor any of these species from collected seed, but this should be tried and tested as possible mitigation prior to any development authorisation. If these experiments prove successful a suitable secure receiving area will have to be identified and set aside as required mitigation. Whether or not this mitigation would work is not known, and avoidance is the strongly recommended first step in the mitigation hierarchy. As there is so little remaining natural habitat in the northern Swartland region securing a suitable conservation area for these transplants is likely to be very difficult or even impossible.

Consequence is Very High (High intensity at a Regional scale but Permanent and probability is Definite), and hence Significance is Very High negative (without mitigation), according to the scale provided.

Loss of Very High sensitivity vegetation (and at least 5 SoCC) in Section 3 development footprint:

Without Mitigation Assuming Mitigation*

Regional: vegetation type Regional: vegetation type Extent concerned and the SoCC are concerned and the SoCC are found only within this region found only within this region

Duration Permanent Medium term

Intensity High Medium

Significance Very High Medium

Status Negative Negative

Probability Definite Definite

Consequence Very High Medium

Confidence High High

Reversibility Irreversible

Loss of resource High

Mitigation Preferred primary mitigation would be avoidance of most of the Very High sensitivity areas (see Figure 7), in which case potential Mitigation potential would be High. Successful Search and Rescue at Km 61.0 for Limonium sp nov. would mean mitigation potential here is High.

Table 1: Impact table for botanical impacts of loss of Very High sensitivity areas within development footprint of Section 3. *The only acceptable mitigation here would be avoidance, which has largely been achieved by modifying the layout for the section Km 64.2 – Km 65.3 (see Figure 7), with Search and Rescue to be undertaken at Km 61.0 for Limonium sp nov., as avoidance is evidently not possible.

Figure 7: Revised layout for the section from Km 64.2 – Km 65.3, showing avoidance of the Very High sensitivity areas east of the current roadway.

6.2 Impacts on High Sensitivity Areas A linear total of 3338m of High sensitivity vegetation (all Critically Endangered) is within the study area, but only about 2375m is likely to be lost or impacted by the proposed construction as not all portions will be impacted. The actual total

area of the loss is likely to be at least three times this (3m lateral expansion of road and cuttings), and thus might be about 0.7ha.

The only plant Species of Conservation Concern (SoCC) known to occur within the High sensitivity sections to be impacted is Aspalathus wurmbeana (Endangered; see Plate 1), and it is estimated that about 50 plants occur in this area, which constitutes about 75% of the population along this section of the N7. This species is unlikely to survive translocation as it is a deep rooted woody shrub, but could potentially be replanted from rooted cuttings and germinated seed, provided suitable secure habitat could be identified and secured in perpetuity. Whether or not this mitigation would work is not known, and avoidance is the recommended first step in the mitigation hierarchy.

Loss of High sensitivity vegetation (and individuals of a single SoCC) in Section 3 development footprint:

Without Mitigation Assuming Mitigation *

Regional: vegetation type Regional: vegetation type Extent concerned and the SoCC are concerned and the SoCC are found only within this region found only within this region

Duration Permanent Medium term

Intensity High Medium

Significance Very High Medium

Status Negative Negative

Probability Definite Definite

Consequence High Medium

Confidence High High

Reversibility Irreversible

Loss of resource High

Mitigation Preferred primary mitigation would be avoidance of 50% of the High sensitivity areas, in which case Mitigation potential would be potential High, and some of the identified areas will indeed be avoided as development will be only one side of the road; Medium if Search and Rescue of Aspalathus wurmbeana is successful.

Table 2: Impact table for botanical impacts of loss of High sensitivity areas within development footprint of Section 3. *The only acceptable mitigation here would be avoidance of at least 50% all High sensitivity areas identified, plus Search and Rescue of Aspalathus wurmbeana in all areas to be impacted.

6.3 Impacts on Medium Sensitivity Areas A linear total of about 4120m of Medium sensitivity vegetation (all Critically Endangered) is within the study area, but only about 3420m is likely to be lost or impacted by the proposed construction as not all portions will be impacted. The actual total area of the loss is likely to be at least three times this (3m lateral expansion of road and cuttings), and thus might be about 1.0ha.

No plant Species of Conservation Concern (SoCC) are known or likely to occur in viable or significant numbers within the Medium sensitivity sections to be impacted, although in some of these areas limited numbers (generally five plants or less) of Aspalathus wurmbeana (Endangered) are present.

Consequence is Medium (Medium intensity at a Local scale but Permanent and probability is Definite), and hence Significance is Medium negative (without mitigation), according to the scale provided.

Loss of Medium sensitivity vegetation (and low numbers of a single SoCC) in Section 3 development footprint:

Without Mitigation Assuming Mitigation*

Local: limited to the immediate Local: limited to the Extent vicinity of the site immediate vicinity of the site

Duration Permanent Medium term

Intensity Medium Medium

Significance Medium - High Medium

Status Negative Negative

Probability Definite Probable

Consequence Medium - High Medium

Confidence High Medium

Reversibility Partly reversible

Loss of resource Medium

Mitigation Moderate, but would require avoidance of 50% of Medium sensitivity areas and rehabilitation of road reserve and replanting potential of as many locally indigenous species as possible, including at least 60 plants of the Endangered Aspalathus wurmbeana (from rooted cuttings and seed).

Table 3: Impact table for botanical impacts of loss of Medium sensitivity areas within development footprint of Section 3. *Mitigation includes avoidance of 50% of Medium sensitivity areas and rehabilitation of road reserve and replanting of as many locally indigenous species as possible, including at least 60 plants of the Endangered Aspalathus wurmbeana (from rooted cuttings and seed).

7. THE NO GO ALTERNATIVE The No Development option would be the preferred scenario from a botanical perspective, as it would mean that the direct and indirect negative botanical impacts would not take place. The No Go is not without some botanical impact, as there is continual gradual attrition of the habitat and species within the road reserve, due to vehicle crashes, maintenance activities and agricultural impacts (deliberate herbicide spraying and spray drift from adjacent fields, etc.), but on balance the botanical impact is Low negative.

8. REQUIRED MITIGATION The remaining natural vegetation in the study area is mostly Swartland Shale Renosterveld, which is recognised as a Critically Endangered habitat on a national basis (DEA 2011), which means that less of this habitat remains than the national conservation target. In an intensively cultivated landscape like this many of the most important habitat remnants are those within the road reserves, and road upgrades need to take this into account. At least six threatened plant species (Species of Conservation Concern – SoCC) were recorded within the habitat remnants within the study area. No further loss of any viable remnants of such threatened habitats should be considered, and certainly not where there are viable construction alternatives (i.e. extensive areas of Low sensitivity), such as within the study area. Redesign of the layout in the main identified sensitive areas was required, in order to demonstrate avoidance of the identified impacts – the first element of the mitigation hierarchy (which is “avoid, minimise and mitigate”). This has been achieved for the primary Very High sensitivity section from Km 64.2 – Km 65.3, and the revised layout is shown in Figure 7.  The revised layout for Km 64.2 – Km 65.3, as shown in Figure 7, must be implemented.  Care should be taken to permanently demarcate and protect the eastern edge of the existing informal pulloff east of the road at Km 64.340 – Km 64.460 as Critically Endangered plants occur very close to the hardened surface. It is suggested that a standard crash barrier be placed along this eastern edge to limit vehicular access, but exact placement of this must be done in consultation with the botanist. Note: The author has observed that this was done by SANRAL in August 2019, and this pulloff area is now safely behind a barrier.  Extensive plant Search and Rescue programs must be implemented well prior to disturbance or loss of any of the mapped Medium and High sensitivity areas. This should be undertaken by a recognised specialist in this field, supervised by the botanical specialist. The primary targets for this work will be Aspalathus wurmbeana and Limonium sp. nov. Seed, cuttings and whole plant removal and cultivation will be required ex situ (in a nursery), with replanting into identified suitable habitats either in new road reserves (after completion of construction) or nearby areas of secure, similar habitat. These translocation areas must be identified by the botanist, ideally within 10km of the study area, and ideally within already formally protected areas, or a process carried out whereby the identified landowners agree to conserve the receiving area in perpetuity (by means

of a signed Contract Reserve status with CapeNature). The receiving areas may need to be fenced off and clearly demarcated as conservation areas to prevent accidental future loss of these areas. The entire process must be funded by SANRAL and should be completed within three years of formal construction project commencement.  10% of the cuttings and seedlings, if rooted successfully, should be replanted into any suitable road cuttings once construction has been completed. Replanting should be undertaken in early winter, after good rains.  The sensitive pan area (and the Endangered Lachenalia bachmanii) east of the road at Km 47.980 – Km 48.190 will be impacted by fill and consequently the road reserve must be widened to the east by 20m at this point to include more of the sensitive pan habitat for conservation within the new road reserve. The eastern road reserve fence should be positioned as indicated in Figure 8, and the 0.4ha thus contained here will mitigate the damage to the pan caused by the proposed project, as sheep will be prevented from grazing here and the rare Lachenalia bachmanii wetland bulbs will be able to flourish in this area.

Figure 8: Image showing proposed new road reserve fence (in pink) in the section Km 47.980 – Km 48.190. Current road reserve fence show in blue.

9. CONCLUSIONS AND RECOMMENDATIONS  The original development proposal was considered unacceptable from a botanical point of view, as it would have had a Very High negative botanical impact, driven mainly by the loss of Very High sensitivity sections of the route, notably at the southern base of the Piekenierskloof Pass. Extensive redesign of the largest and most important Very High sensitivity section was thus undertaken in consultation with the botanical specialist in order to avoid impact on this area, and the result is shown in Figure 7, which successfully avoids the most sensitive areas in this portion.  No significant botanical constraints are present in the bulk of the route, mapped as being of Low botanical sensitivity.  Not all the identified Medium and High sensitivity areas will be impacted by the proposed development, as most of the impact is only on the western side of the road. Plant species diversity is very low or low in all identified areas except the areas shown in Figure 7, and Search and Rescue of the identified species, plus the proposed formal conservation of the additional receiving areas, plus the widening of the road reserve at Km 48.00, will adequately mitigate the impacts of the loss of these areas and individuals.  It is essential that all mitigation outlined in Section 8 be included in any Environmental Authorisation, and that they all be timeously implemented, as all are key to reducing the identified botanical impacts, some of which would be Very High negative without mitigation.  Provided that all required mitigation is implemented then the overall botanical impact of the project will be an acceptable Medium negative.

10. REFERENCES Helme, N., P. Holmes & A. Rebelo. 2016. Coastal Ecosystems – Lowland Fynbos. In: Cadman, A (ed.). Ecosystem Guidelines for Environmental Assessment in the Western Cape, Ed.2. Fynbos Forum, Fish Hoek, South Africa.

Mucina, L. and M. Rutherford. Eds. 2012 online update. Vegetation map of South Africa, Lesotho, and Swaziland. Strelitzia 19. South African National Biodiversity Institute, Pretoria.

Pence, G. 2017. Western Cape Biodiversity Spatial Plan. CapeNature, Cape Town, South Africa.

Raimondo, D., Von Staden, L., Foden, W., Victor, J.E., Helme, N.A., Turner, R.C., Kamundi, D.A., and Manyama, P.A. (eds.) 2009. Red List of South African Plants 2009, and regular online updates at redlist.sanbi.org. Strelitzia 25. South African National Biodiversity Institute, Pretoria.

Rouget, M., Reyers, B., Jonas, Z., Desmet, P., Driver, A., Maze, K., Egoh, B. & Cowling, R.M. 2004. South African National Spatial Biodiversity Assessment 2004: Technical Report. Volume 1: Terrestrial Component. Pretoria: South African National Biodiversity Institute.

ANNEXURES

Annexure 1: SLR METHOD OF ASSESSING IMPACT SIGNIFICANCE

The identification and assessment of environmental impacts is a multi-faceted process, using a combination of quantitative and qualitative descriptions and evaluations. It involves applying scientific measurements and professional judgement to determine the significance of environmental impacts associated with the proposed project. The process involves consideration of, inter alia: the purpose and need for the project; views and concerns of interested and affected parties (I&APs); social and political norms, and general public interest.

IDENTIFICATION AND DESCRIPTION OF IMPACTS Identified impacts are described in terms of the nature of the impact, compliance with legislation and accepted standards, receptor sensitivity and the significance of the predicted environmental change (before and after mitigation). Mitigation measures may be existing measures or additional measures that were identified through the impact assessment and associated specialist input. The impact rating system considers the confidence level that can be placed on the successful implementation of mitigation.

EVALUATION OF IMPACTS AND MITIGATION MEASURES

INTRODUCTION Impacts are assessed using SLR’s standard convention for assessing the significance of impacts, a summary of which is provided below.

In assigning significance ratings to potential impacts before and after mitigation the approach presented below is to be followed.

1. Determine the impact consequence rating: This is a function of the “intensity”, “duration” and “extent” of the impact (see Section 0). The consequence ratings for combinations of these three criteria are given in Section 0.

2. Determine impact significance rating: The significance of an impact is a function of the consequence of the impact occurring and the probability of occurrence (see Section 0). Significance is determined using the table in Section 0.

3. Modify significance rating (if necessary): Significance ratings are based on largely professional judgement and transparent defined criteria. In some instances, therefore, whilst the significance rating of potential impacts might be “low”, the importance of these impacts to local communities or individuals might be extremely high. The importance/value which interested and affected parties attach to impacts will be highlighted, and recommendations should be made as to ways of avoiding or

minimising these perceived negative impacts through project design, selection of appropriate alternatives and / or management.

4. Determine degree of confidence of the significance assessment: Once the significance of the impact has been determined, the degree of confidence in the assessment will be qualified (see Section 0). Confidence in the prediction is associated with any uncertainties, for example, where information is insufficient to assess the impact.

CRITERIA FOR IMPACT ASSESSMENT The criteria for impact assessment are provided below.

Criteria Rating Description Criteria for ranking of the Negligible change, disturbance or nuisance. The impact affects the INTENSITY (SEVERITY) of ZERO TO VERY environment in such a way that natural functions and processes are environmental impacts LOW not affected. People / communities are able to adapt with relative ease and maintain pre-impact livelihoods. Minor (Slight) change, disturbance or nuisance. The impact on the LOW environment is not detectable or there is no perceptible change to people’s livelihood. Moderate change, disturbance or discomfort. Where the affected environment is altered, but natural functions and processes continue, MEDIUM albeit in a modified way. People/communities are able to adapt with some difficulty and maintain pre-impact livelihoods but only with a degree of support. Prominent change, disturbance or degradation. Where natural functions or processes are altered to the extent that they will HIGH temporarily or permanently cease. Affected people/communities will not be able to adapt to changes or continue to maintain-pre impact livelihoods. Criteria for ranking the SHORT TERM < 5 years. DURATION of impacts MEDIUM TERM 5 to < 15 years. > 15 years, but where the impact will eventually cease either because LONG TERM of natural processes or by human intervention. Where mitigation either by natural processes or by human PERMANENT intervention will not occur in such a way or in such time span that the impact can be considered transient. Criteria for ranking the Impact is confined to project or study area or part thereof, e.g. limited LOCAL EXTENT / SPATIAL SCALE to the area of interest and its immediate surroundings. of impacts Impact is confined to the region, e.g. coast, basin, catchment, REGIONAL municipal region, etc. NATIONAL Impact is confined to the country as a whole, e.g. South Africa, etc. Impact extends beyond the national scale. INTERNATIONAL

Criteria for determining Where the possibility of the impact to materialise is very low either the PROBABILITY of IMPROBABLE because of design or historic experience, i.e. ≤ 30% chance of impacts occurring.

Criteria Rating Description Where there is a distinct possibility that the impact would occur, i.e. > POSSIBLE 30 to ≤ 60% chance of occurring. Where it is most likely that the impact would occur, i.e. > 60 to ≤ 80% PROBABLE chance of occurring. Where the impact would occur regardless of any prevention DEFINITE measures, i.e. > 80% chance of occurring. Criteria for determining LOW ≤ 35% sure of impact prediction. the DEGREE OF MEDIUM > 35% and ≤ 70% sure of impact prediction. CONFIDENCE of the assessment HIGH > 70% sure of impact prediction. Criteria for the DEGREE NONE No change in impact after mitigation. TO WHICH IMPACT CAN Where the significance rating stays the same, but where mitigation BE MITIGATED - the VERY LOW will reduce the intensity of the impact. degree to which an impact Where the significance rating drops by one level, after mitigation. can be reduced / LOW enhanced Where the significance rating drops by two to three levels, after MEDIUM mitigation. Where the significance rating drops by more than three levels, after HIGH mitigation. Criteria for LOSS OF Where the activity results in a loss of a particular resource but where RESOURCES - the degree LOW the natural, cultural and social functions and processes are not to which a resource is affected. permanently affected by Where the loss of a resource occurs, but natural, cultural and social MEDIUM the activity, i.e. the degree functions and processes continue, albeit in a modified way. to which a resource is Where the activity results in an irreplaceable loss of a resource. HIGH irreplaceable

DETERMINING CONSEQUENCE Consequence attempts to evaluate the importance of a particular impact, and in doing so incorporates extent, duration and intensity. The ratings and description for determining consequence are provided below.

Rating Description Impacts could be EITHER: of high intensity at a regional level and endure in the long term; VERY HIGH OR of high intensity at a national level in the medium term; OR of medium intensity at a national level in the long term. Impacts could be EITHER: of high intensity at a regional level and endure in the medium term; OR of high intensity at a national level in the short term; HIGH OR of medium intensity at a national level in the medium term; OR of low intensity at a national level in the long term; OR of high intensity at a local level in the long term; OR of medium intensity at a regional level in the long term. Impacts could be EITHER: MEDIUM of high intensity at a local level and endure in the medium term;

Rating Description OR of medium intensity at a regional level in the medium term; OR of high intensity at a regional level in the short term; OR of medium intensity at a national level in the short term; OR of medium intensity at a local level in the long term; OR of low intensity at a national level in the medium term; OR of low intensity at a regional level in the long term. Impacts could be EITHER of low intensity at a regional level and endure in the medium term; OR of low intensity at a national level in the short term; LOW OR of high intensity at a local level and endure in the short term; OR of medium intensity at a regional level in the short term; OR of low intensity at a local level in the long term; OR of medium intensity at a local level and endure in the medium term. Impacts could be EITHER of low intensity at a local level and endure in the medium term; VERY LOW OR of low intensity at a regional level and endure in the short term; OR of low to medium intensity at a local level and endure in the short term. OR Zero to very low intensity with any combination of extent and duration.

DETERMINING SIGNIFICANCE The consequence rating is considered together with the probability of occurrence in order to determine the overall significance using the table below.

PROBABILITY

IMPROBABLE POSSIBLE PROBABLE DEFINITE

VERY LOW INSIGNIFICANT INSIGNIFICANT VERY LOW VERY LOW

LOW VERY LOW VERY LOW LOW LOW MEDIUM LOW LOW MEDIUM MEDIUM

HIGH MEDIUM MEDIUM HIGH HIGH CONSEQUENCE VERY HIGH HIGH HIGH VERY HIGH VERY HIGH

In certain cases it may not be possible to determine the significance of an impact. In these instances the significance is UNKNOWN.

Annexure 2: Specialist Reports Requirements, as prescribed by Appendix 6 of GN R326.

Regulation Content as required by NEMA Specialist Report Section/Annexure Reference 1 (1) (a) Details of- Page ii (i) The specialist who prepared the report; and (ii) The expertise of that specialist to Page ii compile a specialist report, including a CV. 1 (1) (b) A declaration that the specialist is independent Page ii in a form as may be specified by the competent authority. 1 (1) (c) An indication of the scope of, and purpose for Page 1 which, the report is prepared. 1 (1)(cA) An indication of the quality and age of base data used for the specialist report. Page 1

1 (1)(cB) A description of existing impacts on the site, cumulative impacts of the proposed Pages 4-12 & 13 development and levels of acceptable change. 1 (1) (d) The duration, date and season of the site investigation and the relevance of the season Page 1 to the outcome of the assessment. 1 (1) (e) A description of the methodology adopted in preparing the report or carrying out the Page 1 specialised process inclusive of equipment and modelling used. 1 (1) (f) Details of an assessment of the specifically identified sensitivity of the site related to the Pages 12-18 proposed activity or activities and its associated structures and infrastructure, inclusive of a site plan identifying site alternatives. 1 (1) (g) An identification of any areas to be avoided, Page 18-21 including buffers. 1 (1) (h) A map superimposing the activity including the associated structures and infrastructure on the Pages 4-12 environmental sensitivities of the site including areas to be avoided, including buffers. 1 (1) (i) A description of any assumptions made and Page 1 any uncertainties or gaps in knowledge. 1 (1) (j) A description of the findings and potential implications of such findings on the impact of Pages 4-12 the proposed activity or activities. 1 (1) (k) Any mitigation measures for inclusion in the Page 18-21 EMPr. 1 (1) (l) Any conditions for inclusion in the Page 21 environmental authorisation.

Regulation Content as required by NEMA Specialist Report Section/Annexure Reference 1 (1) (m) Any monitoring requirements for inclusion in N/A the EMPr or environmental authorisation 1 (1) (n) A reasoned opinion- Pages 20-21 (i) whether the proposed activity, activities or portions thereof should be authorised; and (iA) regarding the acceptability of the proposed Pages 20-21 activity or activities; and (ii) If the opinion is that the proposed activity, activities or portions thereof should be authorised, any Pages 20-21 avoidance, management and mitigation measures that should be included in the EMPr, and where applicable, the closure plan 1 (1) (o) A description of any consultation process that N/A was undertaken during the course of preparing the specialist report 1 (1) (p) A summary and copies of any comments received during any consultation process and N/A where applicable, all responses thereto 1 (1) (q) Any other information requested by the N/A competent authority