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Scoping Report – April 2014

PROPOSED GREAT KEI WIND ENERGY FACILITY, EASTERN CAPE PROVINCE OF SOUTH AFRICA

FINAL SCOPING REPORT

REFERENCE NUMBER: 14/12/16/3/3/2/613

Prepared for:

GREAT KEI WIND POWER (PTY) LTD

Prepared by:

Coastal & Environmental Services EAST LONDON 2 Marine Terrace, Hampton Court East London, 5201 043 742 3302 Also in Grahamstown www.cesnet.co.za

February 2014

Coastal & Environmental Services i Great Kei Wind Energy Facility

COPYRIGHT INFORMATION This document contains intellectual property and proprietary information that is protected by copyright in favour of Coastal & Environmental Services and the specialist consultants. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of Coastal & Environmental Services. This document is prepared exclusively for submission to GREAT KEI WIND POWER (Pty) Ltd and is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of South Africa.

Scoping Report – April 2014 CES Report Revision

Document Title Proposed Great Kei Wind Energy Project, Great Kei Local Municipality, Eastern Cape Province of South Africa Client Name & GREAT KEI WIND POWER (Pty) Ltd Address P.O. Box 1116, Port Elizabeth, 6000

Document Reference DEA Ref: 14/12/16/3/3/2/613

Status Draft

Issue Date February 2014

Author C Mack CES East London

Reviewer A Carter CES East London

This document has been prepared in accordance with the scope of Coastal & Environmental Services (CES) appointment and contains intellectual property and proprietary information that is protected by copyright in favour of CES. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of Coastal & Environmental Services. This document is prepared Coastal & Environmental Services exclusively for use by CES‘s client. CES accepts no liability for East London any use of this document other than by its client and only for 16 Tyrell Road the purposes for which it was prepared. No person other than Berea, East London the client may copy (in whole or in part) use or rely on the 5200 contents of this document, without the prior written permission +27 47 726 7809 of CES. The document is subject to all confidentiality, [email protected] copyright and trade secrets rules, intellectual property law and www.cesnet.co.za practices of South Africa. Also in Grahamstown, Port Elizabeth & Maputo

Coastal & Environmental Services i Great Kei Wind Energy Facility Scoping Report – April 2014 THE PROJECT TEAM

Dr Alan Carter, Project Leader Dr Cherie-Lynn Mack, Project management, Ms Nande Suka, Environmental Consultant

Mr Roy de Kock, Agriculture and Visual Mr Gavin Anderson, Archaeology Mr Jon Smallie, Avifauna Mr Werner Marais, Bats Dr Greer Hawley, Ecology, Mr Brett Williams, Noise Dr Rose Prevec, Palaeontology

Coastal & Environmental Services ii Great Kei Wind Energy Facility Scoping Report – April 2014

TABLE OF CONTENTS

1 INTRODUCTION ...... 1 1.1 BACKGROUND TO THE STUDY ...... 1 1.2 Environmental authorisation in South Africa ...... 1 1.3 Environmental Impact Assessment Process ...... 1 1.4 Project Need & desirability ...... 4 1.5 Scoping Phase ...... 5 1.6 Nature and Structure of this Report ...... 5 1.7 Assumptions and Limitations ...... 5 1.8 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER ...... 6 2 PROJECT DESCRIPTION ...... 8 2.1 LOCATION OF THE PROPOSED SITE ...... 8 2.2 Description of the Great Kei WIND Energy Project ...... 8 2.2.1 Ancilliary Infrastructure ...... 17 3 ALTERNATIVES ...... 18 3.1 Reasonable and feasible alternatives ...... 18 3.2 Fundamental, incremental and no-go alternatives ...... 18 3.2.1 Wind turbines ...... 23 3.3 NO-GO OPTION...... 23 4 RELEVANT LEGISLATION ...... 24 4.1 INTERNATIONAL ...... 24 4.1.1 The 1992 United Nations Framework Convention on Climate Change (FCCC) ...... 24 4.2 NATIONAL ...... 24 4.2.1 The Constitution Act (108 of 1996) ...... 24 4.2.2 The National Environmental Management Act (NEMA) (107 of 1998) ...... 25 4.2.3 The National Environment Management: Biodiversity Act (10 of 2004) ...... 26 4.2.4 The National Forests Act (84 of 1998) ...... 27 4.2.5 National Heritage Resources Act (25 of 1999) ...... 27 4.2.6 Atmospheric Pollution Prevention Act 45 of 1965 ...... 27 4.2.7 Electricity Regulation Act (Act No. 4 of 2006) ...... 27 4.2.8 Aviation Act (Act No. 74 of 1962): 13th Amendment of the Civil Aviation Regulations 1997 28 4.2.9 Occupational Health and Safety Act (85 of 1993) ...... 30 4.3 National Policy ...... 31 4.3.1 The White Paper on Energy Policy for South Africa (Energy White Paper, 1998) ...... 31 4.3.2 The White Paper on Renewable Energy Policy (Renewable Energy White Paper, 2003) 32 4.3.3 Integrated Energy Plan for the Republic of South Africa, March 2003 ...... 32 4.3.4 Integrated Resources Plan 2010 ...... 33 1.1.1 ...... 35 4.3.5 Other relevant national legislation ...... 36 4.4 MUNICIPAL BY-LAWS ...... 37 5 DESCRIPTION OF THE ENVIRONMENT ...... 38 5.1 THE BIO-PHYSICAL ENVIRONMENT ...... 38 5.1.1 Current Land Use ...... 38 5.1.2 Climate ...... 38 5.1.3 Topography ...... 38 5.1.4 Geology and Soils...... 38 5.1.5 Vegetation and floristics ...... 39 5.2 Site description ...... 44 5.3 SOCIO-ECONOMIC PROFILE ...... 46 5.3.1 Demographics ...... 46 5.3.2 Employment ...... 47 6 MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED ...... 50

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6.1 Possible Environmental Issues & Impacts ...... 50 6.2 Impact Rating ...... 50 6.3 Preliminary sensitivity assessment ...... 53 6.4 Long-term bird and bat monitoring programmes ...... 55 6.4.1 Bird Monitoring Preliminary Report Summary ...... 55 6.4.2 Bat Monitoring Preliminary Report Summary ...... 56 7 PUBLIC PARTICIPATION ...... 58 8 RECOMMENDATIONS ...... 106 8.1 Activity Description ...... 106 8.2 Fatal Flaws ...... 106 8.3 EIR phase...... 106 9 PLAN OF STUDY FOR THE EIA ...... 107 9.1 EIA PHASE ...... 107 9.2 Specialist studies ...... 108 9.2.1 Visual and Landscape Impact Assessment ...... 108 9.2.1 Ecological Impact Assessment ...... 109 9.3 Methodology for assessing the significance of impacts ...... 113 9.4 Environmental Impact Report ...... 117 9.4.1 Proposed structure of EIR ...... 117 9.5 CONSIDERATION BY THE COMPETENT AUTHORITY FOR ENVIRONMENTAL AUTHORISATION AND APPEALS PROCESS ...... 119 10 REFERENCES...... 120

LIST OF FIGURES

Figure 1-1: The EIA process flow chart ...... 3 Figure 2-1: Locality of the Great Kei Wind Energy Facility...... 8 Figure 2-2: Wind turbine components ...... 11 Figure 2-3: Illustration of the main components of a typical wind turbine. Note that the transformer in the figure above would normally be inside the tower (probably at the base).Source: www.powernaturally.org ...... 11 Figure 2-4: Typical temporary platform (indicating the dimensions) that needs to be laid down during the preliminary phase of a typical wind farm for access to the site during the construction phase by machines (bulldozers, trucks, cranes etc.)...... 13 Figure 2-5: Minimal requirements for access road turnings required during the preliminary works of a typical wind farm...... 14 Figure 2-6: Indicative dimensions for the foundation of a 3MW/100m high wind turbine...... 15 Figure 2-7: Concrete pouring of a turbine foundation (note the tower base collar in the foreground)...... 16 Figure 3-1: Great Kei Wind Energy Facility locality map with 35 turbines (3 MW)...... 9 Figure 5.3: Vegetation map showing the vegetation type into which the turbines fall as Bhisho Thornveld, Buffels Thicket and Eastern Valley Bushveld...... 40 Figure 5.4: Map taken from the Eastern Cape Biodiversity Conservation Plan showing the location of the turbines on land classified as ―maintain near natural state‖ and ―functional landscape‖...... 41 Figure 5.5: Map taken from the ECBCP showing the Aquatic Critical Biodiversity Areas...... 42 Subtropical Thicket Ecosystem Plan ...... 42 Figure 5-6: Subtropical Thicket Ecosystem Planning (STEP) map indicating the site of the Great Kei Wind Energy Facility in relation to areas of critically endangered vegetation...... 43 Figure 5-7: Grassland in the vicinity of WTG 04 ...... 44 Figure 5-8: A small farm dam near WTG 18 ...... 44 Figure 5-9: Thorn veld in the vicinity of WTG 19 ...... 45 Figure 5-10: Alien vegetation in the vicinity of WTG 25...... 45 Figure 5-11: An uninhabited old farm house in the vicinity of WTG 26...... 46 Figure 5-12: View south from WTG 26...... 46 Figure 5-10: A graph indicating the monthly household income spread of the population of the Great Kei municipality (GKLM IDP, 2009)...... 47 Figure 5-11: A graph indicating the major areas of employment in the Great Kei municipality (GKLM IDP, 2009)...... 47 Figure A-2: On-site notice board...... Error! Bookmark not defined.

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LIST OF TABLES

Table 1-1: Listed activities triggered by the proposed Great Kei Wind Energy Project ...... 1 Table 3-1: Preliminary WTG coordinates for the proposed Great Kei wind energy project ...... 9 Table 6-1. Significance rating table ...... 51 No Significance ...... 51 Table 6-2. Significance of identified possible impacts...... 52 Table 9-1: Criterion used to rate the significance of an impact ...... 115 Table 9-2: The severity rating scale ...... 116 Table 9-3: The rating of overall significance ...... 116 Table 9-4: Reports that will be generated in the EIA phase for the proposed Great Kei Wind Energy Project ...... 117

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GENERAL SITE INFORMATION

Description of affected farm portions

Farm Name Farm number 21 digit SG Code Size (ha) Lilyvale RE/56 C04000000000005600000 446.82 Home Park RE/203 C04000000000020300000 561.85 Annexation RE/202 C04000000000020200000 659.25 RE/195 C04000000000019500000 73.25 Amberdene RE/163 C04000000000016300000 603.08 RE/1/203 C04000000000020300001 117.72 Grootfontein RE/1/163 C04000000000016300001 600.86 Merino 3/56 C04000000000005600003 250.63 201 C04000000000020100000 67.14 Walmer 2/56 C04000000000005600002 249.40 Waterfall 2/164 C04000000000016400002 550.08 Barlinga 2/162 C04000000000016200002 278.92 199 C04000000000019900000 32.69 198 C04000000000019800000 120.11 197 C04000000000019700000 66.76 196 C04000000000019600000 113.89 193 C04000000000019300000 17.80 1/195 C04000000000019500001 35.33 Westbury 1/162 C04000000000016200001 268.99

Great Kei Wind Energy Facility

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Photographs of the site

Photographs from sensitive visual receptors Please see the Visual Impact Assessment submitted as part the EIR documentation. Turbine design specifications Nacelle height/Hub height 120 m Blade Diameter 126 m Turbine shaft dimensions 5 m Ø (120 m high) Foundation dimensions 20 m x 20 m (underground) 5 m x 5 m (above ground) Laydown area dimensions 22 m x 35 m Blade rotation direction Horizontal Generation Capacity 3300kW (3.3MW)

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Onsite measured wind parameters This information is considered, by the developer, to be confidential because of its commercial sensitivity. Generation capacity of the facility at delivery point Delivery point Layout 1 (35 x 3.3MW) Eskom Chaba Substation 115.5 MW

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1 INTRODUCTION

1.1 BACKGROUND TO THE STUDY

Great Kei Wind Power (Pty) Ltd is a special purpose vehicle (SPV) created by InnoWind (Pty) Ltd a South Africa based renewable energy generator that develops, finances, builds, operates and maintains commercial wind powered generation facilities. InnoWind‘s development and operating expertise has been acquired through its French parent company EDF Energies Nouvelles, which is the renewable energy arm of the French power utility EDF.

EDF EN currently owns and operates over 3000 MW of wind energy power plants worldwide.

Great Kei Wind Power plans to develop a wind powered generation facility on farmland outside of Komga, in the Eastern Cape Province of South Africa. The proposed project is planned to host up to 35 wind turbines, each with an expected nominal power output of between 2 and 3.3 Mega Watts (MW). The potential total output of the renewable energy facility is anticipated to be a maximum of 115.5 MW.

Coastal & Environmental Services (CES) have been appointed by Great Kei Wind Power (Pty) Ltd as Environmental Assessment Practitioner (EAP) to conduct the EIA.

1.2 ENVIRONMENTAL AUTHORISATION IN SOUTH AFRICA

The regulation and protection of the environment within South Africa, occurs mainly through the application of various items of legislation, within the regulatory framework of the Constitution (Act 108 of 1996).

The primary legislation regulating Environmental Impact Assessment (EIA) within South Africa is the National Environmental Management Act (―NEMA‖ Act 107 of 1998). NEMA makes provision for the Minister of Environmental Affairs (―the Minister‖) to identify activities which may not commence prior to authorisation from either the Minister or the provincial Member of the Executive Council (―the MEC‖). In addition to this, NEMA also provided for the formulation of regulations in respect of such authorisations.

The EIA Regulations (2010) allow for a basic assessment process for activities with limited environmental impact (listed in GN R.544, 2010) and a more rigorous two tiered approach to activities with greater environmental impact (listed in GN R.545, 2010). This two tiered approach includes both a Scoping and EIA processes.

1.3 ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

The listed activities that trigger the need for an EIA under the Environmental Impact Assessment Regulations of 2010 in Listing Notices 1, 2 and 3 and published in Government Notices No. R.544, R.545 and R.546 respectively are shown in Table 1-1 below.

Table 1-1: Listed activities triggered by the proposed Great Kei Wind Energy Facility Government Notice Activity Activity Description No(s): R.544 10 BA The construction of facilities or infrastructure for the transmission and distribution of electricity – Outside urban areas or industrial complexes with a capacity of more than 33 but less than 275 kilovolts R.544 11 BA The construction of infrastructure covering 50 square meters or more where (xi) such construction occurs within a watercourse or within 32 meters of a watercourse. R.544 13 BA The construction of facilities or infrastructure for the storage, of the storage and

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handling, of dangerous good, where such storage occurs in containers with a capacity of 80 but not exceeding 500 cubic meters. R.544 18 BA The infilling or depositing of any material of more than 5 cubic meters into, or (i) the dredging, excavation, removal, or moving of soil from a watercourse. R.544 23 BA The transformation of undeveloped land to residential, retail, commercial, or industrial use, outside of an urban area and where the total area to be transformed is bigger than 1 hectare but less than 20 hectares. R.545 1 EIA The construction of facilities or infrastructure for the generation of electricity where the electricity output is 20 megawatts or more.

R.545 15 EIA Physical alteration of undeveloped, vacant or derelict land for residential, retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more. R.546 4 BA The construction of a road wider than 4 meters with a reserve less than 13.5 (ii)(ee) meters outside an urban area in a critical biodiversity area as identified in systematic biodiversity plans. R.546 13 BA The clearance of an area of 5 hectares or more of vegetation where 75% or (a)(ii) more of the vegetation cover constitutes indigenous vegetation outside an urban area. R.546 19 BA The widening of a road by more than 4 meters, or the lengthening of a road by (ii)(ee) more than kilometre outside an urban area in a critical biodiversity area as identified in systematic biodiversity plans.

Applications for activities listed within GN R544 and GN R546 require a Basic Assessment, while applications for activities listed within GN R545 require a Scoping and EIR process. However, in terms of section 20(2) (c) of the EIA Regulations (2010), scoping must be applied to an application if the application is for two or more activities that are part of the same development and one of the two activities requires scoping and EIA. Because the proposed development triggers a listed activity from GNR.545, it will require a full Scoping and EIA. This process, shown in Figure 1-1, is regulated by Chapter 3, Part 3 of the EIA regulations.

The proponent is therefore initially required to submit a report detailing the scoping phase (Scoping Report), and set out the terms of reference for the EIA process (Plan of Study for EIA). This is then followed by a report detailing the EIA phase (EIR). The competent authority will issue a final decision subsequent to their review of the EIR.

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Contextualise Proposed Development

Pre-Application Planning (Determine assessment process using NEMA, 1998 and G/N 386 and 387 of 2006)

Adopt the Scoping & Environmental Impact Assessment Process Submit Application to Relevant Authority

Conduct Public Participation Process

Scoping Report and Plan of Study for the EIA

Public Review of Scoping Report and Plan of Study of the EIA

Authority Review of Scoping Request Report and Plan of Study of the EIA Amendment s

Conduct Environmental Impact Assessment. Compile EIR and EMP

Public Review of EIR and EMP

Authority Review of EIR and Request EMP Amendments

Issue Environmental Authorisation and notify applicant of conditions and appeal provisions

Notify I&APs of Environmental Authorisation and appeal provisions

Consider Appeals if any

Figure 1-1: The EIA process flow chart

The competent authority that must consider and decide on the application for authorisation in respect of the activities listed in Table 1-1 is the Department Environmental Affairs (DEA) as the Department has recently reached an agreement with all Provinces, except Gauteng, that all electricity-related projects, including generation, transmission and distribution, are to be submitted to DEA, irrespective of the nature of the applicant. This decision has been made in terms of Section 24(C) (3) of the National Environmental Management Act (Act No 107 of 1998). The decision is effective for all projects until approximately 2015.

It is important to note that in addition to the requirements for an authorisation in terms of the

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NEMA, there may be additional legislative requirements which need to be considered prior to commencing with the activity, for example:  National Heritage Resources Act (Act No 25 of 1999),  Aviation Act (Act No 74 of 1962) as amended,  NEM: Biodiversity Act (Act 10 of 2004)  National Water Act (Act 36 of 1998)

1.4 PROJECT NEED & DESIRABILITY

The South African Government has recognised the country‘s high level of renewable energy potential and presently has in place targets of 17.8 GW of renewable energy by 2030 (to be produced mainly from wind and solar). This amounts to ~42% share of the new electricity generation capacity to be brought online by 2030.

Based on consultations with Great Kei Wind Power (Pty) Ltd, the proposed project is needed and deemed desirable for the following reasons:-

 Electricity supply Over the last few years, South Africa has been adversely impacted by interruptions in the supply of electricity. The creation of a ‗decentralized‘ power generation facility (i.e. not located in the traditionally centralized power producing regions of the Republic of South Africa) in the vicinity of the loads it proposes to supply, will secure a supplementary energy source for the area, especially during cold fronts and during the winter season when consumption is higher and wind yields are higher. Moreover, the project will contribute towards meeting the national energy target as set by the Department of Energy (DoE) in its 2010 Integrated Resource Plan, of a 42% share of all new power generation being derived from Renewable Energy produced by independent power producers (IPPs) by 2030.

 Green energy Growing concerns such as climate change and the on-going exploitation of non-renewable resources have prompted increased international pressure on countries to increase their share of renewable energy generation. The South African government has recognized the country‘s high level of renewable energy potential and has placed targets of 17.8 GW of renewable energy capacity on line by 2030. The proposed renewable energy facility is therefore considered to be of national importance in anticipation of its contribution to electricity supply and reduced reliance on fossil energy sources.

 Eastern Cape Renewable Energy Strategy The Eastern Cape Government is exploring alternative energy supply such as wind, solar and hydroelectricity. The province is committed to a minimum of 2% of energy supply from renewable sources by 2025.

 Climate change The electricity generated by the wind farm will displace some fossil fuel based forms of electricity generation. Throughout its life span, the wind farm is expected to contribute positively towards climate change mitigation.

 Employment and skills transfer With the collaboration of the ECDC (Eastern Cape Development Corporation), the Amathole District Municipality, the Economic Development Department (EDD) and the Industrial

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Development Corporation of South Africa (IDC), the proposed project will help with the creation of employment and transfer of skills to the residents of the Great Kei Local Municipality during both the development and operational phases of the project. The project is also consistent with the Provincial Growth and Development Plan (PGDP).

 Social upliftment Great Kei Wind Power will set up a BBBEE community trust that will be structured to own a significant minority stake in the project on behalf of the local communities. The community trust will spend the dividends it receives in order to provide social upliftment and economic development opportunities to the local communities. The institutional arrangements and structural requirements to establish such a community trust are already in place with the IDC. The proposed community trust will only be registered once and if the project has been selected by the Department of Energy to sell renewable energy to the designated power purchaser.

1.5 SCOPING PHASE

The scoping phase is designed to determine the ―scope‖ of the subsequent Environmental Impact Assessment (EIA), conducted in fulfilment of the application for authorisation. The overall aim of the Scoping Phase is to determine those environmental issues and impacts associated with the proposed development that require further investigation in an EIA. The purpose of scoping is therefore to identify:

1. Issues 2. Impacts 3. Alternatives

An integral part of the scoping phase is the initial public participation process (PPP). This process ensures that all possible interested and affected parties (I&APs) are informed of the proposed activity and are provided with an opportunity to comment.

1.6 NATURE AND STRUCTURE OF THIS REPORT

This report fulfils the requirement of the EIA Regulations (2010) for the documentation of the scoping phase.

The structure of this report is based on section 28 of GN No.543, of the Environmental Impact Assessment Regulations (2010), which clearly specifies the required content of a scoping report.

1.7 ASSUMPTIONS AND LIMITATIONS

This report is based on currently available information and, as a result, the following limitations and assumptions are implicit– • The report is based on a project description taken from design specifications for the proposed wind farm that have not yet been finalised, and which are likely to undergo a number of iterations and refinements before they can be regarded as definitive. A project description based on the final design will be provided in the EIA Phase; • Descriptions of the natural and social environments are based on limited fieldwork and available literature. More information will be provided in the EIA phase based on the outcomes of the specialist studies.

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1.8 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER

In fulfilment of the above-mentioned legislative requirement the details of the Environmental Assessment Practitioner (EAP) that prepared this draft scoping report as well as the expertise of the individual members of the study team are provided below.

Coastal & Environmental Services (CES), established in 1990, is a specialist environmental consulting company based in Grahamstown, with a branch in East London (Eastern Cape Province). We believe that a balance between development and environmental protection can be achieved by skilful, considerate and careful planning.

CES has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, and state of environment reporting (SOER), Integrated Waste Management Plans (IWMP), Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) processes. CES has been active in all of the above fields, and in so doing have made a positive contribution to towards environmental management and sustainable development in the Eastern Cape, South Africa and many other African countries.

Dr Alan Carter holds a PhD in Plant Sciences and is a Certified Public Accountant, with extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He has 15 years‘ experience in environmental management and has specialist skills in sanitation, coastal environments and industrial waste. Dr Carter is registered as a Professional Natural Scientist under the South African Council for Natural Scientific Professions and is a certified ISO14001 Environmental Management Systems Auditor.

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Dr Greer Hawley, Principal Environmental Consultant has a BSc degree in Botany and Zoology and a BSc Honours in Botany from the University of Cape Town. She completed her PhD thesis (Microbiology) at Rhodes University. The core academic focus has been directed in the field of taxonomy both in the plant and fungal kingdom, but she has been involved in a diverse range of research activities. Her research ranges from studying fresh and marine algae, estuarine diatoms, species classification in the fynbos and forest vegetation and fungal species identification and ecology. Greer‘s study of fungi have also contributed towards an understanding of soil and ―below ground‖ ecology. She is currently working on numerous impact assessments at the East London branch.

Dr Cherie-Lynn Mack, holds a PhD and MSc (with distinction) degrees in Environmental Biotechnology, with a BSc degree in Microbiology and Biochemistry. She has postgraduate research experience in industrial and domestic wastewater treatment technologies, with particular emphasis on the coal and platinum mining industries. Her interests lie in the water sector, with experience in ecological reserve determination and water quality monitoring and analysis. She has experience in water quality analysis and industrial wastewater treatment research. She is currently employed in the East London office of CES as a senior environmental consultant.

Ms Nande Suka, Environmental Consultant, holds a B.Sc. degree with majors in Botany and Zoology (2010) and B.Sc. Honours in Terrestrial Botany (2011), both obtained at the Nelson Mandela Metropolitan University in Port Elizabeth. Her academic focus was in the broad field of Environmental Management and with great interest on impact assessments, environmental planning and conservation.

Coastal & Environmental Services 7 Great Kei Wind Energy Facility Scoping Report – April 2014 2 PROJECT DESCRIPTION

In terms of the EIA Regulations (2010), a Scoping Report must contain: (1) A scoping report must contain all the information that is necessary for a proper understanding of the nature of issues identified during scoping, and must include – (b) a description of the proposed activity (d) a description of the property on which the activity is to be undertaken and the location of the activity on the property

2.1 LOCATION OF THE PROPOSED SITE

The proposed wind energy project will be constructed on rural communal land in the vicinity of the town of Komga. Komga is a small farming town in South Africa's Eastern Cape Province that lies 60km north of the town of East London. The Great Kei project falls within the Great Kei Local Municipality which in turn falls within the Amathole District Municipality (ADM). This is indicated in Figure 3-1.

Great Kei Wind Energy Facility

Figure 2-1: Locality of the Great Kei Wind Energy Facility.

2.2 DESCRIPTION OF THE GREAT KEI WIND ENERGY PROJECT

The Great Kei WEF is proposed to comprise up to 35 turbines (3.3 MW output each), for a total maximum output capacity of 115.5 MW. Figure 2.2 and Table 3.1 indicate the location of the turbines within the site boundaries.

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Great Kei Wind Energy Facility

Figure 2-2: Great Kei Wind Energy Facility locality map with 35 turbines (3.3 MW).

The specific coordinates for each turbine is shown in Table 3-1 below.

Table 2-1: Preliminary wind turbine coordinates for the proposed Great Kei wind energy project

35 x 3.3 MW Wind Turbine Latitude (S) Longitude (E) Number WTGO1 32°35'41.95" 27°57'50.23" WTGO2 32°35'31.29" 27°58'23.35" WTGO3 32°39'59.76" 27°58'38.49" WTGO4 32°35'51.78" 27°58'32.72" WTGO5 32°36'13.34" 27°58'44.01" WTGO6 32°36'25.88" 27°58'22.78" WTGO7 32°36'29.67" 27°57'38.80" WTGO8 32°36'9.00" 27°57'30.28" WTGO9 32°37'25.40" 27°56'42.10" WTGO10 32°37'30.62" 27°57'31.29" WTGO11 32°37'9.10" 27°58'14.00" WTGO12 32°37'0.70" 27°58'36.10" WTGO13 32°36'54.00" 27°58'56.40" WTGO14 32°37'21.90" 27°59'4.90" WTGO15 32°37'59.30" 27°56'35.20" WTGO16 32°38'27.90" 32°38'27.90" WTGO17 32°38'45.88" 27°56'7.54" WTGO18 32°39'6.69" 27°56'11.75" WTGO19 32°39'6.90" 27°56'36.70" WTGO20 32°38'59.19" 27°57'1.33"

Coastal & Environmental Services 9 Great Kei Wind Energy Facility Scoping Report – April 2014 WTGO21 32°38'44.40" 27°57'21.44" WTGO22 32°39'11.10" 27°57'32.30" WTGO23 32°39'31.75" 27°57'40.65" WTGO24 32°39'57.20" 27°56'56.50" WTGO25 32°40'35.75" 27°56'43.72" WTGO26 32°40'31.20" 27°57'45.30" WTGO27 32°39'38.87" 27°58'45.22" WTGO28 32°40'20.30" 27°58'46.30" WTGO29 32°39'55.62" 27°59'1.17" WTGO30 32°39'36.53" 27°59'52.32" WTGO31 32°38'56.30" 27°59'18.00" WTGO32 32°38'14.87" 27°58'44.67" WTGO33 32°38'28.70" 27°59'4.60" WTGO34 32°38'32.17" 27°58'26.80" WTGO35 32°38'12.62" 27°58'10.82"

Wind energy is a form of solar energy. Winds are caused by the uneven heating of the atmosphere by the sun, the irregularities of the earth's surface, and rotation of the earth. Wind flow patterns are modified by the earth's terrain, bodies of water, and vegetation. This wind flow or motion energy (kinetic energy) can be used for generating electricity. The term ―wind energy‖ describes the process by which wind is used to generate mechanical power or electricity. Wind turbines convert the kinetic energy in the wind into mechanical power and a generator can then be used to convert this mechanical power into electricity. The components of a typical wind turbine subsystem are shown in Figure 2-2 and Figure 2-3 below:

 A rotor, or blades, which are the portion of the wind turbine that collect energy from the wind and convert the wind's energy into rotational shaft energy to turn the generator. The speed of rotation of the blades is controlled by the nacelle, which can turn the blades to face into the wind (‗yaw control), and change the angle of the blades (‗pitch control‘) to make the most use of the available wind;  A nacelle (enclosure) containing a drive train, usually including a gearbox (some turbines do not require a gearbox) and a generator. The generator is what converts the turning motion of a wind turbine‘s blades (mechanical energy) into electricity. Inside this component, coils of wire are rotated in a magnetic field to produce electricity. The nacelle is also fitted with brakes, so that the turbine can be switched off during very high winds, such as during storm events. This prevents the turbine from being damaged. All this information is recorded by computers and is transmitted to a control centre, which means that operators don't have to visit the turbine very often, but only occasionally for a mechanical check;  A tower, to support the rotor and drive train; The tower on which a wind turbine is mounted is not only a support structure, but it also raises the wind turbine so that its blades safely clear the ground and so can reach the stronger winds at higher elevations. The tower must also be strong enough to support the wind turbine and to sustain vibration, wind loading, and the overall weather elements for the life time of the turbine, and;  Electronic equipment such as controls, electrical cables, ground support equipment, and interconnection equipment.

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Figure 2-2: Wind turbine components

Figure 2-3: Illustration of the main components of a typical wind turbine. Note that the transformer in the figure above would normally be inside the tower (probably at the base).Source: www.powernaturally.org

The following section provides a detailed discussion of the various components of the proposed Great Kei wind energy project.

Coastal & Environmental Services 11 Great Kei Wind Energy Facility Scoping Report – April 2014 A TYPICAL WIND FARM

Typically, building a wind farm is divided into four phases namely:-  Preliminary civil works  Construction  Operation  Decommission

Preliminary civil works

Prior to the commencement of the main construction works, the Contractor may undertake vegetation clearance (if required) and site establishment works. The site establishment works may include the construction of one, or more, temporary construction compounds and laydown areas and the connection of services such as power and water to these compounds.

Construction

The construction footprint will include the platforms, or ―crane pads‖ required to construct the wind turbines, new or upgraded access roads, lay-bys, component storage areas, turning heads and a substation to evacuate the electricity generated to the municipal or national grid.

A typical platform for the assembly of the crane and construction of the turbine is shown in Figure 2-4. These platforms will be connected by access roads (if none existing) with the following requirements:-  min. 7m width (5m running width and 1m verge either side) on straight sections with widening required on corners.  Should a ―crawler‖ type crane be used, then road widths of up to 11m on straight sections may be required, of which 5m would be retained for the life of the wind farm.  Typical 300mm deep road section  Maximum 10% vertical gradient on gravel roads  Turning heads provided within 200m of each crane pad (refer to Figure 2-5).  Passing places of c. 50m length and 5m width located approximately every 1km

The construction footprint required will be greater than the dimensions specified above to allow for construction of the wind farm infrastructure. These areas used temporarily over the construction period – including temporary construction compound and road verges – will be rehabilitated at the end of construction works to reduce the footprint on the land.

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Figure 2-4: Typical temporary platform (indicating the dimensions) that needs to be laid down during the preliminary phase of a typical wind farm for access to the site during the construction phase by machines (bulldozers, trucks, cranes etc.).

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R= 40,0

R= 60,0

5,0

Figure 2-5: Minimal requirements for access road turnings required during the preliminary works of a typical wind farm.

Other works during the construction phase include:

(a) Geotechnical studies and foundation works A geotechnical study of the area is undertaken for safety purposes. This comprises of drilling, penetration and pressure assessments. For the purpose of the foundations, approximately 1500m3 of soil would need to be excavated for each turbine. These excavations are then filled with steel- reinforced concrete (typically 45 tons of steel reinforcement per turbine including a ―bolt ring‖ to connect the turbine foundation to the turbine tower). Foundation design will vary according to the type and quality of the soil. The typical dimensions of a foundation for a 3MW/100m high wind turbine are shown in the Figure 2-6 and Figure 2-7 with the underground foundation and tower connection at ground level.

(b) Electrical cabling Electrical and communication cables are laid approximately 1m deep in trenches which run alongside the access roads as much as possible. All previous farming activities can continue unhindered on the ground above the cables during the operational phase.

(c) Establishment of hard standing surfaces and laydown areas Laydown and storage areas will be required for the contractor‘s construction equipment and turbine components on site.

(d) Site preparation If not carried out in the preliminary works phase, this will include clearance of vegetation over the access roads, platforms, lay-bys, substation and any other laydown or hard-standing areas. These activities will require the stripping of topsoil which will be stock-piled, back-filled and/or spread on site.

(e) Establishment of substation and ancillary infrastructure The establishment of these facilities/buildings will require the clearing of vegetation and levelling of the development site and the excavation of foundations prior to construction. A laydown area for building materials and equipment associated with these buildings will also be required.

Coastal & Environmental Services 14 Great Kei Wind Energy Facility Scoping Report – April 2014 (f) Turbine erection Weather permitting; the erection of the turbines can be completed swiftly and erection rates generally average 1-2 turbines per week. This phase is the most complex and costly.

(g) Undertake site remediation Once construction is completed and all construction equipment is removed, the site must be rehabilitated where practical and reasonable. On full commissioning of the facility, any access points to the site which are not required during the operational phase must be closed and rehabilitated.

Tower Base Ground level

Underground Foundation

Figure 2-6: Indicative dimensions for the foundation of a 3MW/100m high wind turbine.

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Figure 2-7: Concrete pouring of a turbine foundation (note the tower base collar in the foreground).

Electrical connection

Each turbine is fitted with its own transformer that steps up the voltage usually to 22 or 33kv. The entire wind farm is then connected to the ―point of interconnection‖ which is the electrical boundary between the wind farm and the municipal or national grid. Most of these works will be carried out by Eskom or an Eskom-approved sub-contractor (line upgrade, connection to the sub-station, burial of the cables etc.)

Operational phase

During the period when the turbines are up and running, on-site human activity drops to a minimum, and includes routine maintenance requiring only light vehicles to access the site. Only major breakdowns would necessitate the use of cranes and trucks.

Facility re-powering

The Wind turbines are expected to have a lifespan of approximately 25 years (with appropriate maintenance). The infrastructure would only be decommissioned once it has reached the end of its economic or technological life. If economically feasible, the disassembly and replacement of the individual components with more appropriate technology/infrastructure available at the time will take place.

Decommissioning of the Wind farm

The infrastructure would only be decommissioned once it has reached the end of its economic or technological life. If economically feasible, the decommissioning activities would comprise the disassembly and replacement of the individual components with more appropriate technology/infrastructure available at the time. This operation is referred to as ‗facility re-powering‘. However, if not deemed so, then the facility would be completely decommissioned which would include the following decommissioning activities.

Coastal & Environmental Services 16 Great Kei Wind Energy Facility Scoping Report – April 2014 (a) Site preparation Activities would include confirming the integrity of the access to the site to accommodate the required equipment and the mobilisation of decommissioning equipment.

(b) Disassemble all individual components The components would be disassembled and reused and recycled or disposed of in accordance with regulatory requirements.

2.2.1 Ancilliary Infrastructure

Additional infrastructure such as internal access roads, underground and overhead power lines, electrical switching stations and/or small substations and control buildings will also form part of the development. At this stage the location and routing of such infrastructure is not fully defined. This layout design will be completed once accurate information regarding the site-specific environmental and engineering constraints is collected.

Figure 2.8 indicates a preliminary routing for the internal turbine access roads, under which the power cables will be buried. In one case, an underground 22 kV power cable may be installed without the associated road. The function of this cable will be to connect the turbines east of the N2 with those on the west, and to the substation.

Electrical energy generated by the Great Kei WEF will be transmitted to the Eskom Chaba substation, located within the boundary of the site, from whence it will be distributed along the Eskom distribution infrastructure.

Coastal & Environmental Services 17 Great Kei Wind Energy Facility Scoping Report – April 2014 3 ALTERNATIVES

In terms of the EIA Regulations (2010), a Scoping Report must contain: (1) A scoping report must contain all the information that is necessary for a proper understanding of the nature of issues identified during scoping, and must include – (a) a description of any feasible and reasonable alternatives that have been identified (j) a description of identified potential alternatives to the proposed activity, including advantages and disadvantages that the proposed activity or alternatives may have on the environment and the community that may be affected by the activity;

One of the objectives of an EIA is to investigate alternatives to the proposed project. There are two types of alternatives - Fundamental Alternatives and Incremental Alternatives.

3.1 REASONABLE AND FEASIBLE ALTERNATIVES

The current section describes the alternatives that are considered in the current application.

Alternatives should include consideration of all possible means by which the purpose and need of the proposed activity could be accomplished in the specific instance taking account of the interest of the applicant in the activity. The no-go alternative must in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed.

The determination of whether site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment.

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

3.2 FUNDAMENTAL, INCREMENTAL AND NO-GO ALTERNATIVES

Fundamental alternatives Fundamental alternatives are developments that are totally different from the proposed project and usually include the following: • Alternative property or location where it is proposed to undertake the activity; • Alternative type of activity to be undertaken; and • Alternative technology to be used in the activity;

Incremental alternatives Incremental alternatives relate to modifications or variations to the design of a project that provide different options to reduce or minimise environmental impacts. There are several incremental alternatives that can be considered with respect to the current wind farm project, including: • Alternative design or layout of the activity; and • Alternative operational aspects of the activity.

No-go alternative It is mandatory to consider the ―no-go‖ option in the EIA process. The ―no-go‖ alternative refers to the current status quo and the risks and impacts associated to it. Some existing activities may Coastal & Environmental Services 18 Great Kei Wind Energy Facility Scoping Report – April 2014 carry risks and may be undesirable (e.g. an existing contaminated site earmarked for a development). In the case of the current proposed wind energy facility, the main ―no-go‖ activity is:

- Site remains as private farm land for grazing and commercial agriculture

Coastal & Environmental Services 19 Great Kei Wind Energy Facility Scoping Report – April 2014 Alternative level Alternatives Advantages Disadvantages Reasonable Further Comment and feasible assessment Property or location Alternative location 1 Located close to existing Potential visual YES YES The main determining This refers to the - Current proposed necessary electrical intrusion to factors for selecting fundamental site (Preferred infrastructure ESKOM. surrounding the proposed location location options, alternative) Suitable wind speed. landowners and were:- such as Greenfield Land availability (Great users of the N2. Proximity to a grid vs. a Brownfield site, Kei Wind Power and the Potential impacts on connection point; etc. and the landowners involved avifauna and bats. Available land. environmental risks have come to an and impacts agreement). Preliminary associated with such investigations have options. identified that the proposed project site meets the above land specifications. Alternative location 2 NA NA NA NA Alternative locations - None identified as for the current project rights to private land will be limited and must be sought from probably not local residents. reasonable and Location 1 has been feasible. The agreed to. connectivity to the grid is a critical factor to the overall feasibility of the project. Therefore, alternative locations were not assessed. Type of activity Alternative activity 1 Contribute to alleviating None identified YES YES Site is suitable for This refers to the - Energy generation electrical energy unless electricity is renewable energy fundamental land (Preferred shortages in South Africa generated by generation based on use options, such as alternative) Site located close to burning of fossil location to electrical industrial, residential, electrical grid fuels and creating air infrastructure, wind infrastructure, The potential to stimulate pollution availability, etc. farming, economic activity and conservation, etc. and jobs in the area

Coastal & Environmental Services Great Kei20 Wind Energy Facility Scoping Report – April 2014 Alternative level Alternatives Advantages Disadvantages Reasonable Further Comment and feasible assessment the environmental Alternative activity 2 The area will remain as it YES YES This alternative risks and impacts – Intensive currently is. represents the NO- associated with such agriculture GO options Type of technology Alternative energy Clean and renewable Visually intrusive YES YES This refers to the technology 1 – Wind energy fundamental turbines (Preferred Mitigate climate change technology options, alternative) Does not requires large such as energy areas of land generation from wind Alternative energy Clean and renewable Visually intrusive YES NO The area is actively vs. coal fired power technology 2 – Solar energy Requires large area farmed, and as such, plant, etc. and the PV Mitigate climate change of land large areas of land environmental risks are not available for and impacts installation of PV associated with such infrastructure. options. Alternative energy Clean and renewable Visually intrusive NO NO technology 3 – energy Requires large area Concentrated Solar Mitigate climate change of land Power (CSP) Water probably a limiting factor Reflectivity of mirrors probably a significant issue Alternative energy None identified Air pollution from NO NO technology 4 – Coal coal dust and smoke fired power plant stack emissions (SO2) Contribution to climate change Ground contamination from coal dust Alternative energy Clean and renewable Expensive source of NO NO technology 5 – energy energy biomass Mitigate climate change

Coastal & Environmental Services Great Kei21 Wind Energy Facility Scoping Report – April 2014 Alternative level Alternatives Advantages Disadvantages Reasonable Further Comment and feasible assessment Alternative energy Greater electricity Raw material highly NO NO technology – nuclear generation with little raw radioactive power material required Design or layout Alternative layout 1 These are incremental NA NA NA This relates mostly to (Preferred impacts that have been alternative ways in alternative) informed by the EIA which the proposed process. Thus the final development or proposed layout included activity can be in the EIR is the optimal physically laid out on layout from an the ground to environmental minimise or reduce perspective, where all environmental risks or environmentally sensitive impacts areas have been designated as NO-GO areas. Alternative layout 2 NA NA NA NA NA Operational aspects Alternative As with layout, NA NA NA NA This relates mostly to operational activity 1 operational aspects are alternative ways in (Preferred incremental impacts that which the alternative) will be informed by the development or EIA process. Thus the activity can operate in operation of the facility order to reduce will be informed by the environmental risks or operational mitigation impacts measures identified in the EIR. No-go option Existing activities on This refers to the site include: current status quo and the risks and Farmland with Will remain relatively YES YES Assessed in the impacts associated to grazing, irrigated undisturbed impact assessment it. crops and dryland process crops

Coastal & Environmental Services Great Kei22 Wind Energy Facility Scoping Report – April 2014 3.2.1 Wind turbines

The report proposes a preliminary turbine layout which will be further refined in response to the specialist assessments. In total 35 Wind turbines x 3.3 MW output (each) = 115.5MW Total.

All assessments conducted in the EIR phase will ensure that the maximum thresholds of the alternative are addressed.

3.3 NO-GO OPTION

The EIA will examine factors and assess impacts that may result from the ―No Go‖ option.

Coastal & Environmental Services 23 Great Kei Wind Energy Facility Scoping Report – April 2014 4 RELEVANT LEGISLATION

In terms of the EIA Regulations (2010): (1) A scoping report must contain all the information that is necessary for a proper understanding of the nature of issues identified during scoping, and must include – (f) an identification of all legislation and guidelines that have been considered in the preparation of the scoping report

The development of the proposed Great Kei Wind Energy Facility will be subject to the requirements of a number of laws, conventions and policies, both international and national. These include international conventions to which SA is a signatory and national policy and legislation.

4.1 INTERNATIONAL

4.1.1 The 1992 United Nations Framework Convention on Climate Change (FCCC)

The UNFCCC is a framework convention which was adopted at the 1992 Rio Earth Summit. South Africa signed the UNFCCC in 1993 and ratified it in August 1997 (Glazwesky, 2005). The stated purpose of the UNFCCC is to, ―achieve….stabilisation of greenhouse gas concentrations in the atmosphere at concentrations at a level that would prevent dangerous anthropogenic interference with the climate system‖, and to thereby prevent human-induced climate change by reducing the production of greenhouse gases defined as, ―those gaseous constituents of the atmosphere both natural and anthropogenic, that absorb and re-emit infrared radiation‖.

Relevance to the proposed Great Kei Wind Energy Facility:

 The UNFCCC is relevant in that the proposed project will contribute to a reduction in the production of greenhouse gases by providing an alternative to fossil fuel-derived electricity, and will assist South Africa to begin demonstrating its commitment to meeting international obligations.

4.2 NATIONAL

4.2.1 The Constitution Act (108 of 1996) This is the supreme law of the land. As a result, all laws, including those pertaining to the proposed development, must conform to the Constitution. The Bill of Rights - Chapter 2 of the Constitution, includes an environmental right (Section 24) according to which, everyone has the right: a) To an environment that is not harmful to their health or well-being; and b) To have the environment protected for the benefit of present and future generations, through reasonable legislative and other measures that: (i) Prevent pollution and ecological degradation; (ii) Promote conservation; and (iii) Secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.

Relevance to the proposed Great Kei Wind Energy Facility:

 Obligation to ensure that the proposed development will not result in pollution and ecological degradation; and  Obligation to ensure that the proposed development is ecologically sustainable, while demonstrating economic and social development.

Coastal & Environmental Services 24 Great Kei Wind Energy Facility Scoping Report – April 2014 4.2.2 The National Environmental Management Act (NEMA) (107 of 1998)

The objective of NEMA is: ―To provide for co-operative environmental governance by establishing principles for decision-making on matters affecting the environment, institutions that will promote co-operative governance and procedures for coordinating environmental functions exercised by organs of state; and to provide for matters connected therewith.‖

A key aspect of NEMA is that it provides a set of environmental management principles that apply throughout the Republic to the actions of all organs of state that may significantly affect the environment. The proposed development has been assessed in terms of possible conflicts or compliance with these principles. Section 2 of NEMA contains principles (see Box 1) relevant to the proposed project, and likely to be utilised in the process of decision making by DEA.

BOX 1: NEMA ENVIRONMENTAL MANAGEMENT PRINCIPLES Environmental management must place people and their needs at the forefront of its concern, and (2) serve their physical, psychological, developmental, cultural and social interests equitably. (3) Development must be socially, environmentally and economically sustainable. Sustainable development requires the consideration of all relevant factors including the following: i. That the disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied; (4)(a) ii. That pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied; iii. That waste is avoided, or where it cannot be altogether avoided, minimised and reused or recycled where possible and otherwise disposed of in a responsible manner. Responsibility for the environmental health and safety consequences of a policy, programme, (4)(e) project, product, process, service or activity exists throughout its life cycle. The social, economic and environmental impacts of activities, including disadvantages and benefits, (4)(i) must be considered, assessed and evaluated, and decisions must be appropriate in the light of such consideration and assessment. The right of workers to refuse work that is harmful to human health or the environment and to be (4)(j) informed of dangers must be respected and protected. The costs of remedying pollution, environmental degradation and consequent adverse health effects (4)(p) and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment. Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal shores, estuaries, (4)(r) wetlands, and similar systems require specific attention in management and planning procedures, especially where they are subject to significant human resource usage and development pressure.

As these principles are utilised as a guideline by the competent authority in ensuring the protection of the environment, the proposed development should, where possible, be in accordance with these principles. Where this is not possible, deviation from these principles would have to be very strongly motivated.

NEMA introduces the duty of care concept, which is based on the policy of strict liability. This duty of care extends to the prevention, control and rehabilitation of significant pollution and environmental degradation. It also dictates a duty of care to address emergency incidents of pollution. A failure to perform this duty of care may lead to criminal prosecution, and may lead to the prosecution of managers or directors of companies for the conduct of the legal persons.

Employees who refuse to perform environmentally hazardous work, or whistle blowers, are protected in terms of NEMA.

In addition NEMA introduces a new framework for environmental impact assessments, the EIA Regulations (2010) discussed previously.

Relevance to the proposed Great Kei Wind Energy Facility:

 The developer must be mindful of the principles, broad liability and implications associated with NEMA and must eliminate or mitigate any potential impacts.

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 The developer must be mindful of the principles, broad liability and implications of causing damage to the environment.

4.2.3 The National Environment Management: Biodiversity Act (10 of 2004)

This Act provides for the management and conservation of South Africa‘s biodiversity within the framework of the National Environmental Management Act 107 of 1998 (see Box 2). In terms of the Biodiversity Act, the developer has a responsibility for:

1. The conservation of endangered ecosystems and restriction of activities according to the categorisation of the area (not just by listed activity as specified in the EIA regulations). 2. Application of appropriate environmental management tools in order to ensure integrated environmental management of activities thereby ensuring that all developments within the area are in line with ecological sustainable development and protection of biodiversity. 3. Limit further loss of biodiversity and conserve endangered ecosystems.

The objectives of this Act are –  To provide, within the framework of the National Environmental Management Act, for – o The management and conservation of biological diversity within the Republic; o The use of indigenous biological resources in a sustainable manner.

The Act‘s permit system is further regulated in the Act‘s Threatened or Protected Species Regulations, which were promulgated in February 2007.

Relevance to the proposed Great Kei Wind Energy Facility:

 The proposed development must conserve endangered ecosystems and protect and promote biodiversity;  Must assess the impacts of the proposed development on endangered ecosystems;  No protected species may be removed or damaged without a permit;  The proposed site must be cleared of alien vegetation using appropriate means

BOX 2: MANAGEMENT AND CONSERVATION OF SOUTH AFRICA’S BIODIVERSITY WITHIN THE FRAMEWORK OF NEMA CHAPTER 4 Provides for the protection of species that are threatened or in need of national protection to ensure their survival in the wild; o to give effect to the Republic‘s obligations under international agreements regulating international trade in specimens of endangered species; and o ensure that the commercial utilization of biodiversity is managed in an ecologically sustainable way. CHAPTER 5 (Part 2) Section A person who is the owner of land on which a listed invasive species occurs must: 73 a) notify any relevant competent authority, in writing, of the listed invasive species occurring on that land; b) take steps to control and eradicate the listed invasive species and to prevent it from spreading; and c) take all required steps to prevent or minimise harm to biodiversity. Section  Control and eradication of a listed invasive species must be carried out by means of 75 methods that are appropriate for the species concerned and the environment in which it occurs.  Any action taken to control and eradicate a listed invasive species must be executed with caution and in a manner that may cause the least possible harm to biodiversity and damage to the environment.  The methods employed to control and eradicate a listed invasive species must also be directed at the offspring, propagating material and re-growth of such invasive species in order to prevent such species from producing offspring, forming seed,

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regenerating or re-establishing itself in any manner.

4.2.4 The National Forests Act (84 of 1998)

The objective of this Act is to monitor and manage the sustainable use of forests. In terms of Section 12 (1) (d) of this Act and GN No. 1012 (promulgated under the National Forests Act), no person may, except under licence:  Cut, disturb, damage or destroy a protected tree; or  Possess, collect, remove, transport, export, purchase, sell, donate or in any other manner acquire or dispose of any protected tree or any forest product derived from a protected tree.

Relevance to the proposed Great Kei Wind Energy Facility:

 If any protected trees in terms of this Act occur on site, the developer will require a licence from the DAFF to perform any of the above-listed activities.

4.2.5 National Heritage Resources Act (25 of 1999)

The protection of archaeological and paleontological resources is the responsibility of a provincial heritage resources authority and all archaeological objects, paleontological material and meteorites are the property of the State. ―Any person who discovers archaeological or paleontological objects or material or a meteorite in the course of development must immediately report the find to the responsible heritage resources authority, or to the nearest local authority offices or museum, which must immediately notify such heritage resources authority‖.

Relevance to the proposed Great Kei Wind Energy Facility:

 An archaeological impact assessment must be undertaken during the detailed EIR phase of the proposed project.  No person may alter or demolish any structure or part of a structure, which is older than 60 years or disturb any archaeological or paleontological site or grave older than 60 years without a permit issued by the relevant provincial heritage resources authority.  No person may, without a permit issued by the responsible heritage resources authority destroy, damage, excavate, alter or deface archaeological or historically significant sites.

4.2.6 Atmospheric Pollution Prevention Act 45 of 1965

This Act is currently the central legislation for the prevention of air pollution. Part IV deals with dust control – ―Whenever dust originating on any land in a dust controlled area is causing a nuisance to persons residing or present in the vicinity of that land, the owner or occupier may be required to take the prescribed steps or adopt the “best practicable means” for the abatement of the dust‖. This Act will apply until the more recent National Environmental Management: Air Quality Act (see section 2.2.7 below) comes into force.

Relevance to the proposed Great Kei Wind Energy Facility:

 The ―best practicable means‖ for the abatement of dust during construction if approved have to be taken.  All appliances used for preventing or reducing to a minimum the escape into the atmosphere of noxious or offensive gases have to be properly operated and maintained and the best practice means for achieving this implemented.

4.2.7 Electricity Regulation Act (Act No. 4 of 2006)

The Electricity Regulation Act (Act No. 4 of 2006) came into effect on 1 August 2006 and the objectives of this Act are to:-

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 Facilitate universal access to electricity;  Promote the use of diverse energy sources and energy efficiencies, and;  Promote competitiveness and customer and end user choice.

Relevance to the proposed Great Kei Wind Energy Facility:

 The proposed Wind Farm project is in line with the call of the Electricity Regulation Act No. 4 of 2006 as it is has the potential to improve energy security of supply through diversification.

4.2.8 Aviation Act (Act No. 74 of 1962): 13th Amendment of the Civil Aviation Regulations 1997

Section 14 of obstacle limitations and marking outside aerodrome or heliport (CAR Part 139.01.33) under this Act specifically deals with wind turbine generators (wind farms). According to this section, ―A wind turbine generator is a special type of aviation obstruction due to the fact that at least the top third of the generator is continuously variable and offers a peculiar problem in as much marking by night is concerned. The Act emphasizes that, when wind turbine generators are grouped in numbers of three or more they will be referred to as ―wind farms‖.

Of particular importance to the proposed project are the following:-

 Wind farm placement: Due to the potential of wind turbine generators to interfere on radio navigation equipment, no wind farm should be built closer than 35km from an aerodrome. In addition, much care should be taken to consider visual flight rules routes, proximity of known recreational flight activity such as hang gliders, en route navigational facilities etc.  Wind farm Markings: Wind turbines shall be painted bright white to provide the maximum daytime conspicuousness. The colours grey, blue and darker shades of white should be avoided altogether. If such colours have been used, the wind turbines shall be supplemented with daytime lighting, as required.  Wind farm Lighting: o Wind farm (3 or more units) lighting: In determining the required lighting of a wind farm, it is important to identify the layout of the wind farm first. This will allow the proper approach to be taken when identifying which turbines need to be lit. Any special consideration to the site‘s location in proximity to aerodromes or known corridors, as well as any special terrain considerations, must be identified and addressed at this time. Details are as follows: . Not all wind turbine units within an installation or wind farm need to be lit. Definition of the periphery of the installation is essential. Lighting of interior wind turbines is of lesser importance unless they project above the peripheral units. This can be the case when higher ridges or plateaus are present within the wind farm area. . Obstruction lights within a group of wind turbines should have unlighted separations or gaps of no more than 800m if the integrity of the group appearance is to be maintained. This is especially critical if the arrangement of objects is essentially linear, as is the case with most wind turbine groups. . Any array of flashing or pulsed obstruction lighting, intended to warn of a group of wind turbines forming an entity (i.e., a line, string, or series of units), shall be synchronized to flash simultaneously. If an installation consists of a number of widespread, but obviously separated areas or entities more than 1500m from each other, it is not necessary that all such areas flash synchronously. . Night time wind turbine obstruction lighting should consist of medium intensity type B aviation red flashing lights. Minimum intensities of 2000 candela for night-time red flashing or strobe lights are required. Note: Steady-burning obstruction lights shall not be used.

Coastal & Environmental Services 28 Great Kei Wind Energy Facility Scoping Report – April 2014 . White medium intensity type A strobe lights may be used in lieu of the preferred medium intensity type B strobe lights, but must be used alone without any red lights, and must be positioned in the same manner as the red flashing lights. . Since the hub of the wind turbine unit is frequently as large as the nacelle (body) itself, a top-mounted obstruction light should be raised well above the surface of the nacelle so that it may be easily seen from directly in front of the turbine. Placement of the light fixtures on the turbine nacelle should be accomplished to ensure that they are visible from 360 degrees, with particular attention being made to ensure that the hub of the turbine rotor in no way blocks the light from an aircraft approaching the windward side of the turbine at the same elevation as the turbine hub. . When possible, antennas or towers of heights over 45m that are within the turbine farm area should be incorporated into the lighting plan for the site, as they offer tall, unobstructed platforms on which lighting fixtures can be mounted and should be included in the synchronization and spacing calculations. . Each turbine should only require one fixture if the site is monitored, and that a failed light fixture can be replaced within the next working day. Failure to replace a failed fixture, which is essential to maintaining the 800m- separation requirement, will result in an unsafe gap in the lighting configuration. If the facility does not possess the capability to replace fixtures within the next working day, each turbine shall be fitted with two separate fixtures. A well-balanced lighting plan has all the light fixtures within the wind farm flash at the same time, thus delineating the farm as one large obstruction and navigation between the turbines should be discouraged. The synchronisation function can be accomplished through various means, either by radio frequency devices, hard-wired control cables, or independently mounted global positioning system synchroniser units. The site developer can decide the selection of the units, as long as the end result is that all lights flash perceivably at the same time. If the developer fails to synchronise the fixtures, the developer will be required to add additional fixtures at closer spacing. The very basis of the lighting standards for wind farms is centered on the synchronous flashing of the perimeter lighting.  Turbine Lighting Assignment: The following guidelines should be followed to determine which turbines, need to be equipped with lighting fixtures. Again, the placement of the lights is contingent upon which type of configuration is being used. o Linear: A light should be placed on each turbine positioned at each end of the line or string of turbines. From those end turbines, lights should then be positioned such that the next lit turbine is no more than 800m, from the last lit turbine. This pattern should continue until the end of the string is reached. If the last segment is significantly short, it may be practical to move the lit turbines back one or two turbines towards the starting point to present a nice, well-balanced string of lights. A high concentration of lights, in close proximity, should be avoided. o Cluster: A starting point should be selected along the outer perimeter of the cluster. This turbine should be lit, and then, continuing along the outer perimeter of the farm, a light should be placed on the next turbine with the maximum gap between the lit turbines being no more than 800m. This pattern should continue around the perimeter of the cluster, and end at the starting point. If it appears that the lights are crowded at the ending point, the lit turbines may be moved back by one turbine to present a balanced lighting presentation. If it is determined that the distance across the cluster is of a distance greater than 1500m, or the terrain may vary within the cluster (+30m from the perimeter elevations), it may be appropriate to place a few lit turbines at strategic locations throughout the centre of the cluster. This will prevent pilots from believing they may be able to climb over the outer perimeter and descend down into the centre of the cluster. Discretion should

Coastal & Environmental Services 29 Great Kei Wind Energy Facility Scoping Report – April 2014 be used when placing these lights to maintain a well-balanced, safe lighting configuration. o Grid: Initially, each of the defined corners of the grid layout should be selected for lighting, and then, using the same concept of the cluster configuration, lights should be placed on turbines along the outer limits of the farm so that the maximum spacing between lit turbines is no more than 800m. If it appears as though the end of the lighting strings may be crowded, it may be necessary to move the lights back one or two turbines to create an even lighting configuration. If the grid is more than 1500m wide across the centre of the group of turbines, it may be appropriate to position one or two lights within the centre of the configuration to again provide warning to pilots attempting to climb over the outer limits of the grid, and descending into the centre of the grid. Elevation should also be considered. o Special Instances: On occasion, if one or two turbines may be positioned at locations that do not lend themselves to the linear, cluster, or grid layouts, the following guidelines should be followed. If the turbine protrudes from the general limits of the wind farm, the turbine should automatically receive a lighting fixture. If another turbine is collocated with the first turbine, it does not require any lighting as long as it is within 150m from the lit turbine and not positioned on the outboard side of the lit turbine. If these requirements cannot be met, both turbines, in this case, would need to be illuminated.

Relevance to the proposed Great Kei Wind Energy Facility:

 Due to requirements of the Act to ensure the safety of aircrafts, the project proponent will engage directly with the Civil Aviation Authority regarding the structural details of the facility

4.2.9 Occupational Health and Safety Act (85 of 1993)

The objective of this Act is to provide for the health and safety of persons at work (See Box 3). In addition, the Act requires that, ―as far as reasonably practicable, employers must ensure that their activities do not expose non-employees to health hazards‖ (Glazewski, 2005: 575). The importance of the Act lies in its numerous regulations, many of which will be relevant to the proposed Great Kei Renewable Energy Facility. These cover, among other issues, noise and lighting.

Relevance to the proposed Great Kei Wind Energy Facility:

 The developer must be mindful of the principles and broad liability and implications contained in the OHSA and mitigate any potential impacts.

BOX 3: HEALTH AND SAFTY OF PERSONS AT WORK ACCORDING TO THE OCCUPATIONAL HEALTH AND SAFETY ACT

8: GENERAL DUTIES OF THE EMPLOYERS TO THEIR EMPLOYEES (1) Every employer shall provide and maintain, as far as is reasonably practicable, a working environment that is safe and without risk to the health of his employees. (2) Without derogating from the generality of an employer's duties under subsection (1), the matters to which those duties refer include in particular- a) The provision and maintenance of systems of work, plant and machinery that, as far as is reasonably practicable, are safe and without risks to health; b) Taking such steps as may be reasonably practicable to eliminate or mitigate any hazard or potential hazard to the safety or health of employees, before resorting to personal protective equipment; d) Establishing, as far as is reasonably practicable, what hazards to the health or safety of persons are attached to any work which is performed, any article or substance which is produced, processed, used, handled, stored or transported and any plant or machinery which is used in his

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business, and he shall, as far as is reasonably practicable, further establish what precautionary measures should be taken with respect to such work, article, substance, plant or machinery in order to protect the health and safety of persons, and he shall provide the necessary means to apply such precautionary measures; e) Providing such information, instructions, training and supervision as may be necessary to ensure, as far as is reasonably practicable, the health and safety at work of his employees; f) As far as is reasonably practicable, not permitting any employee to do any work or to produce, process, use, handle, store or transport any article or substance or to operate any plant or machinery, unless the precautionary measures contemplated in paragraphs (b) and (d), or any other precautionary measures which may be prescribed, have been taken; g) Taking all necessary measures to ensure that tire requirements of this Act are complied with by every person in his employment or on premises under his control where plant or machinery is used; h) Enforcing such measures as may be necessary in the interest of health and safety; i) Ensuring that work is performed and that plant or machinery is used under the general supervision of a person trained to understand the hazards associated with it and who have the authority to ensure that precautionary measures taken by the employer are implemented; and authority as contemplated in Section 37 (1) (b).

14: GENERAL DUTIES OF EMPLOYEES AT WORK Every employee shall at work:- (a) Take reasonable care for the health and safety of himself and of other persons who may be affected by his acts or omissions; (b) As regards any duty or requirement imposed on his employer or any other person by this Act, cooperate with such employer or person to enable that duty or requirement to be performed or complied with; (c) Carry out any lawful order given to him, and obey the health and safety rules and procedures laid down by his employer or by anyone authorized thereto by his employer, in the interest of health or safety; (d) If any situation which is unsafe or unhealthy comes to his attention, as soon as practicable report such situation to his employer or to the health and safety representative for his workplace or section thereof, as the case may be, who shall report it to the employer; and (e) If he is involved in any incident which may affect his health or which has caused an injury to himself, report such incident to his employer or to anyone authorized thereto by the employer, or to his health and safety representative, as soon as practicable but not later than the end of the particular shift during which the incident occurred, unless the circumstances were such that the reporting of the incident was not possible, in which case he shall report the incident as soon as practicable thereafter.

15: DUTY NOT TO INTERFERE WITH, DAMAGE OR MISUSE THINGS [S. 15 substituted by S. 3 of Act No. 181 of 1993.] No person shall intentionally or recklessly interfere with, damage or misuse anything which is provided in the interest of health or safety.

4.3 NATIONAL POLICY

4.3.1 The White Paper on Energy Policy for South Africa (Energy White Paper, 1998)

The White Paper on the Energy Policy for South Africa (Energy White Paper) is an overarching document which sets out the government‘s official policy on the supply and consumption of energy for the next decade. One of the main goals of the White Paper is to create energy security by diversifying the energy supply and energy carriers. Currently, much of South Africa‘s energy is derived from extremely expensive imported fuels and coal-powered energy generation, which could be threatened by climate change response measures of developed countries. The White Paper points out that, South Africa has abundant energy sources and it stresses that, ―all possible energy carriers should be taped to ensure economic growth and development‖. Many of the sectors contributing to the Gross Domestic Product (GDP) are practically driven by these energy carriers. In fact, according to Glazweski (2005), industry as a whole consumes approximately 40% of the total electricity generated, making it the chief energy source for South Africa‘s economic growth and development.

Coastal & Environmental Services 31 Great Kei Wind Energy Facility Scoping Report – April 2014 In addition to the above the Energy White Paper notes that there is currently insufficient renewable energy data and lack of transparency in publicly sharing the data. Information on renewable energy system applications, system standards, installation and performance guides, technical and economic characteristics, and identifying human training capacity is essential as the government commits to a healthier environment as part of their agenda. The position of the Energy White Paper on renewable energy is based on the integrated resource planning principle of, ―ensuring that an equitable level of national resources is invested in renewable technologies, given their potential and compared to investments in other energy supply options‖, and this has subsequently been elaborated by the White Paper on Renewable Energy (see section 3.2.9 that follows).

Relevance to the proposed Great Kei Wind Energy Facility:

 The proposed Wind Farm project is consistent with Government‘s White Paper on Energy Policy and the requirements therein to improve energy security of supply through diversification, as well as the demonstration and introduction of cleaner energy technologies and the promotion of competition and empowerment in the electricity market.

4.3.2 The White Paper on Renewable Energy Policy (Renewable Energy White Paper, 2003)

The White Paper on the Renewable Energy Policy (Renewable Energy White Paper) complements the White Paper on Energy Policy discussed in section 3.2.8 above, by pledging ―Government Support for the development, demonstration and implementation of renewable energy sources for both small and large scale applications‖. It sets out the policy principles, goals and objectives to achieve, ―An energy economy in which modern renewable energy increases its share of energy consumed and provides affordable access to energy throughout South Africa, thus contributing to sustainable development and environmental conservation‖. The Department of Minerals and Energy (DME) (now the Department of Energy) embarked on an Integrated Energy Plan (IEP) to develop the renewable energy resources, while taking safety, health and the environment into consideration. The government set a target of, ―10 000 GWh (0.8Mtoe) renewable energy contribution to final energy consumption by 2013, to be produced mainly from biomass, wind, solar and small-scale hydro‖. Four strategic areas that needed to be addressed to create the appropriate enabling environment for the promotion of renewable energy were identified. These included:-

 Financial instruments;  Legal instruments;  Technology development, and;  Awareness raising, capacity building and education.

Relevance to the proposed Great Kei Wind Energy Facility:

 The proposed Wind Farm project is consistent with Government‘s White Paper on Renewable Energy Policy and the objectives therein to develop an economy in which renewable energy has 4.3.3 aIntegrated significant Energy market sharePlan forand the provide Republics affordable of South access Africa, to energy March throughout 2003 South Africa, thus contributing to sustainable development and environmental conservation. The former Department of Minerals and Energy (DME) commissioned the Integrated Energy Plan (IEP) in response to the requirements of the National Energy Policy in order to provide a framework by which specific energy policies, development decisions and energy supply trade-offs could be made on a project-by-project basis. The framework is intended to create a balance between energy demand and resource availability so as to provide low cost electricity for social and economic development, while taking into account health, safety and environmental parameters.

In addition to the above, the IEP recognised the following:-

Coastal & Environmental Services 32 Great Kei Wind Energy Facility Scoping Report – April 2014  South Africa is likely to be reliant on coal for at least the next 20 years as the predominant source of energy;  New electricity generation will remain predominantly coal based but with the potential for hydro, natural gas, renewables and nuclear capacity;  Need to diversify energy supply through increased use of natural gas and new and renewable energies;  The promotion of the use of energy efficiency management and technologies;  The need to ensure environmental considerations in energy supply, transformation and end use;  The promotion of universal access to clean and affordable energy, with the emphasis on household energy supply being coordinated with provincial and local integrated development programmed;  The need to introduce policy, legislation and regulations for the promotion of renewable energy and energy efficiency measures and mandatory provision of energy data, and;  The need to undertake integrated energy planning on an on-going basis.

Relevance to the proposed Great Kei Wind Energy Facility:

 The proposed Wind Farm project is in line with the IEP with regards to diversification of energy supply and the promotion of universal access to clean energy.

4.3.4 Integrated Resources Plan 2010

The energy department has released the final report of the second integrated resource plan (IRP2010) on its website. The plan sets out South Africa‘s energy mix for the next twenty years. It seeks to outline how South Africa will meet its energy needs while ensuring that this is achieved in an affordable manner.

The report describes the IRP2010 as a ―living plan that is expected to be continuously revised and updated as necessitated by changing circumstances‖.

The report refers to the process leading up to the final revised IRP2010. A first round of public consultation took place in June 2010. This led to the revised balanced scenario (RBS) published for comment in October 2010. A second round of public comment took place in November/December.

The RBS is described as representing an appropriate balance between the expectations of different stakeholders. As a result, changes were introduced to the IRP2010 model assumptions.

Cabinet approved the revised IRP2010 for promulgation on 16 March.

Changes in the policy-adjusted IRP include: • Earlier introduction of renewables to speed up local industry • Nuclear to provide 9.6 GW • Emission constraint contained in RBS maintained (275 million tons of CO2 per annum after 2024) • Energy efficiency demand side management measures maintained at RBS levels

The report emphasises that the policy-adjusted plan will ensure security of supply.

It is described as a ―major step towards building local industry clusters and assists in fulfilling South Africa‘s commitments to mitigating climate change as expressed at the Copenhagen climate change summit‖.

Coastal & Environmental Services 33 Great Kei Wind Energy Facility Scoping Report – April 2014 The plan also includes 6.3 GW of coal, 17.8 GW of renewables and 8.9 GW of other generation sources.

Other changes include: • To roll out solar PV of 300 MW per year from 2012 • Secure at least 711 MW from combined cycle gas turbines between 2019 and 2021 • Modifications to the roll-out of wind and concentrated solar power

The report points out that the IRP2010 maintains a balance between different government objectives such as economic growth, job creation, security of supply and sustainable development.

Relevance to the proposed Great Kei Wind Energy Facility:

 The proposed Wind Farm project is in line with the IRP2010 and can contribute up to 105 MW of wind energy to the total requirement.

4.3.5 National Climate Change Response White Paper (2012)

South Africa, taking into account equity and the common but differentiated responsibilities and respective capabilities of all nations as well as the inter-generational commitment of the Environmental Right contained in Section 24 the country's Constitution, has the climate change response objective of: - Making a fair contribution to the global effort to achieve the stabilisation of greenhouse gas concentrations in the atmosphere at a level that prevents dangerous anthropogenic interference with the climate system; and - Effectively adapt to and manage unavoidable and potential damaging climate change impacts through interventions that build and sustain

Strategies South Africa will implement the following selected strategies (amongst others) in order to achieve its climate change response objective:

Coastal & Environmental Services 34 Great Kei Wind Energy Facility Scoping Report – April 2014 - The prioritisation of mitigation interventions that significantly contribute to a peak, plateau and decline emission trajectory where greenhouse gas emissions peak in 2020 to 2025 at 34% and 42% respectively below a business as usual baseline, plateau to 2035 and begin declining in absolute terms from 2036 onwards, in particular, interventions within the energy, transport and industrial sectors. - The prioritisation of mitigation interventions that have potential positive job creation, poverty alleviation and/or general economic impacts. In particular, interventions that stimulate new industrial activities and those that improve the efficiency and competitive advantage of existing business and industry. - Acknowledging that, with the energy intensive nature of the South African economy, the mitigation of greenhouse gases is generally not going to be easy or cheap and that Government must support and facilitate the mitigation plans of, in particular, the energy, transport and industrial sectors.

4.3.6 Electricity Regulation on New Generation Capacity (Government Gazette No R 399 of 4 May 2011)

On 4 May 2011 the government of the Republic of South Africa promulgated the Electricity Regulations on New Generation Capacity (Government Gazette No R 399) which were made by the Department of Energy in terms of the Electricity Regulation Act 2006, and are applicable to: - (a) new generation capacity derived from renewable energy sources and co-generation; (b) base load, mid-merit load and peak load new generation capacity; and (c) cross border projects. The objectives of these regulations are:

 to facilitate planning for the establishment of new generation capacity;  the regulation of entry by a buyer and a generator into a power purchase agreement;  to set minimum standards or requirements for power purchase agreements;  the facilitation of the full recovery by the buyer of all costs incurred by it under or in connection with a power purchase agreement and an appropriate return based on the risks assumed by the buyer thereunder and to ensure transparency and cost reflectivity in the determination of electricity tariffs; and  the provision of a framework for implementation of an IPP bid programme, a REFIT bid programme, and the relevant agreements to be concluded.

While the Regulations deal generally with procurement under an IPP bid programme (defined in the Regulations to mean a bidding process for the procurement of new generation capacity and/or ancillary services from IPPs), and specify the use of a bidding process involving requests for prequalification, requests for proposals and negotiations with the preferred bidder, the Regulations set out a special process for the procurement of renewable energy and cogeneration under the REFIT programme, described in Regulation 7. Refer to section 4.3.6 below for more detail on the IPP Procurement Process.

Relevance to the proposed project:

The proposed project is required to comply with any guidelines relating to the IPP bid programme.

4.3.7 Renewable Energy Independent Power Producer Procurement Programme (REIPPPP)

South Africa has a high level of renewable energy potential and presently has in place a target of 10 000 GWh of renewable energy. The Minister has determined that 3 725 megawatts (MW) to be generated from renewable energy sources is required to ensure the continued uninterrupted supply of electricity. This 3 725 MW is broadly in accordance with the capacity allocated to Renewable Energy generation in IRP 2010-2030.

Coastal & Environmental Services 35 Great Kei Wind Energy Facility Scoping Report – April 2014 The REIPPP Programme has been designed so as to contribute towards the target of 3 725 MW and towards socio-economic and environmentally sustainable growth, and to start and stimulate the renewable industry in South Africa.

In terms of this REIPPP Programme, bidders will be required to bid on tariff and the identified socio-economic development objectives of the DoE. The tariff will be payable by the Buyer (currently ESKOM) pursuant to the Power Purchase Agreement (PPA) to be entered into between the Buyer and the Project Company of a Preferred Bidder.

The generation capacity allocated to each technology is in accordance with the table below and the maximum tariff that a Bidder may bid for purposes of the IPP Procurement Programme is as set out in the RFP.

Based upon the principles of the REIPPP Programme, the DoE also intends to introduce a separate ―Small Projects IPP Procurement Programme‖ for electricity generation projects of less than 5MW.

Long Term Mitigation Scenarios (LTMS) (2007)

The aim was to produce Long Term Mitigation Scenarios (LTMS) to set the pathway for South Africa‘s long-term climate policy and will eventually inform a legislative, regulatory and fiscal package that will give effect to the policy package at a mandatory level. The overall goal is to ―develop a plan of action which is economically risk-averse and internationally aligned to the world effort on climate change.‖

The strategy assesses various response scenarios but concludes that the only sustainable option (―the preferred option‖) for South Africa is the ―Required by Science‖ scenario where the emissions reduction targets should target a band of between -30% to -40% emission reductions from 2003 levels by 2050 which includes increasing renewable energy in the energy mix by 50% by 2050.

4.3.8 Other relevant national legislation

Other national legislation that may be relevant to the proposed Great Kei Wind Energy Facility includes:-  The Telecommunication Act (1966) which has certain requirements with regard to potential impacts on signal reception.

Coastal & Environmental Services 36 Great Kei Wind Energy Facility Scoping Report – April 2014  The Environment Conservation Act No 73 of 1989 (ECA) Noise Control Regulations, which specifically provide for regulations to be made with regard to the control of noise, vibration and shock, including prevention, acceptable levels, powers of local authorities and related matters. In addition to the above, aside from the environmental authorisation, there are other permits, contracts and licenses that will need to be obtained by the project proponent for the proposed project some of which fall outside the scope of the EIA. However, for the purposes of completeness, these include:-  Local Municipality: Land Rezoning Permit  National Energy Regulator of South Africa (NERSA): Generation License  Eskom: Connection agreement and Power Purchase Agreement (PPA)

4.4 MUNICIPAL BY-LAWS

Certain activities related to the proposed development may, in addition to National legislation, be subject to control by municipal by-laws. These will need to be confirmed with the Great Kei Local Municipality prior to construction.

At this stage in the EIA process this list should not be regarded as definitive or exhaustive, and it is probable that additional legislative requirements will be identified as the process progresses. In this regard, the Terms of Reference for most of the specialist studies include the need for a review of all relevant legislation pertaining to the proposed development.

Coastal & Environmental Services 37 Great Kei Wind Energy Facility Scoping Report – April 2014 5 DESCRIPTION OF THE ENVIRONMENT

In terms of the EIA Regulations (2010: (1) A scoping report must contain all the information that is necessary for a proper understanding of the nature of issues identified during scoping, and must include – (e) a description of the environment that may be affected by the activity and the manner in which the activity may be affected by the environment.

5.1 THE BIO-PHYSICAL ENVIRONMENT

5.1.1 Current Land Use

Great Kei municipality covers an area of approximately 1 421 square kilometres. It is bounded in the east by the Great Kei River, in the south east by the Wild Coast, in the west by Buffalo City and by Stutterheim on the north. Regional access is obtained through the district via the N2 national route from East London to Butterworth. The Municipality is divided into six wards, which are the amalgamation of previously different communities and municipal entities, including Komga, Kei Mouth, Cintsa East, Haga-Haga, Mooiplaas and Kwelera.

Significantly, land set aside for private commercial agriculture constitutes the bulk (96%) of the municipal available land resource where much of the agricultural practice in the area (77%) is based on the extensive utilisation of the veld for livestock production (cattle, sheep and goats).

5.1.2 Climate

The Great Kei LM has a warm temperate to subtropical climate with an average annual rainfall that varies from 500-600mm. The area receives the highest rainfall (81mm) in March and lowest (8mm) in July. The temperature ranges between 19.3ºC in July to 25ºC in January, with minimum temperatures reaching as low as 6.6 ºC on average at night in July.

5.1.3 Topography

The topography of Great Kei municipality is varied, generally characterized by steep and undulating relief. Slope analysis indicates that large areas of Great Kei municipality fall within the category that is greater than 1:5 (20%).

5.1.4 Geology and Soils

The Amatola area consists predominantly of the Beaufort Series of the Karoo Supergroup with the Adelaide subgroup between the coast and the Amatola Mountains, the overlying Tarkastad subgroup between the Amatola Mountains and the Stormberg / Drakensberg range, and the Cape Supergroup (Molteno and Elliot formations) along the northern boundary.

The Adelaide subgroup comprises mostly mudstones alternating with lithofeldspathic sandstones. The Tarkastad subgroup is characterized by a greater proportion of sandstone and red coloured mudstone. The Molteno formation contains yellow grey sandstones alternating with olive mudstones and grey shale. The Elliot formation which overlies the Molteno formation comprises an upward fining cycle of sandstone, siltstone and mudstone.

A characteristic of the geology and soils of the area is that once the vegetation is removed by whatever means, erosion of the topsoil is rapid due to the nature of the dispersive soils derived from the underlying geology. This in turn causes high turbidities/suspended solids in the rivers and reduced quality of the water in the rivers and dams as well as siltation of dams.

The study area is underlain by the Adelaide and Tarkastad formations of the Beaufort series (shale, mudstones and sandstones) with dolerite intrusions, the largest of which is located on the

Coastal & Environmental Services 38 Great Kei Wind Energy Facility Scoping Report – April 2014 left bank of the Great Kei River. Soils are derived from the underlying rock and are generally shallow and low in fertility.

5.1.5 Vegetation and floristics

South African National Biodiversity Institute (SANBI)

The vegetation in the region falls into the Savanna biome, more specifically sub-escarpment savanna (Mucina and Rutherford). The dominant vegetation types are Amathole Mountain Grassland (Gd1) and Bhisho Thornveld (SVs 7). The project area is dominated by Bhisho Thornveld, with a small portion of Eastern Valley Bushveld in the west, and some Buffels Thicket in the southeast.

Bhisho Thornveld This vegetation type is distributed from near Mthatha in a band parallel to, but inland of, the coast to north of East London (Figure 5-1). It can also be found on the southern side of the Amatola Mountains as far as Fort Beaufort, with fragments on the hills and lower mountains around Grahamstown. The landscape is generally undulating to moderately steep, with shallow, incised drainage valleys. The open savanna is characterised by small tress such as Acacia natalitia with a short to medium dense sour grassy understorey dominated by Themeda triandra. A diversity of other woody species also occurs, particularly under conditions of overgrazing. Bhisho Thornveld is classified by Mucina and Rutherford (2006) as LEAST THREATENED

Buffels Thicket

This vegetation type is mainly found in various river valleys centred around East London, stretching 40 and 50 km inland and a small area in the Great Kei River Valley and also occurs in the valley bottom in Keiskammahoek. The landscape consists of steep slopes of river valleys in highly dissected hills and moderately undulating plains, where short, dense and tangled thicket stands reach up to 10 metres. The dense thicket grades into more open, shorter thornveld at the edges of the valley slopes. Mucina and Rutherford (2006) classify the Buffels Thicket as VULNERABLE.

Eastern Valley Bushveld

This vegetation type is mainly distributed in the Kwa-Zulu Natal and Eastern Cape Provinces in deeply incised river valleys and very seldom extends to the coast. The landscape and vegetation consists of semi-deciduous savanna woodlands in a mosaic with thickets, often succulent and dominated by species of Euphorbia and Aloe. Most of the river valleys run along a northwest-south east axis which results in unequal distribution of rainfall on respective north-facing and south-facing slopes since the rain-bearing winds blow from the south. The steep north-facing slopes are sheltered from the rain and also receive greater amounts of insolation adding to the xerophilous conditions on these slopes. Eastern Valley Bushveld is considered as LEAST THREATENED by Mucina and Rutherford (2006).

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Great Kei Wind Energy Facility

Figure 5.3: Vegetation map showing the vegetation type into which the turbines fall as Bhisho Thornveld, Buffels Thicket and Eastern Valley Bushveld.

Eastern Cape Biodiversity Conservation Plan

The Eastern Cape Biodiversity Conservation Plan (ECBCP) addresses land cover and the need to identify and map critical biodiversity areas (CBA) and priorities for conservation in the Eastern Cape. It also provides land use planning guidelines, recommending biodiversity-friendly activities in priority areas.

The ECBCP shows that a large portion of the northern farms on which the wind turbines are positioned fall into the CBA2 which is classified as ―maintain near natural state‖ (see Figure 5-4). The recommended land use objective for the ―maintain natural state‖ classification is that biodiversity should be maintained in as natural a state as possible and environmental authorisations should support ecosystem integrity while keeping natural habitat intact in wetlands and riparian zones. The land under this objective should also be managed for no biodiversity loss. The recommended land use for this classification is conservation.

The remaining portion of land is classified as ―Functional Landscapes‖ (Figure 5-4). The recommended land use objective is to manage the land for sustainable development, keeping natural habitat intact in wetlands (including wetland buffers) and riparian zones. Environmental authorisations should support the ecosystem integrity.

Coastal & Environmental Services 40 Great Kei Wind Energy Facility Scoping Report – April 2014

Great Kei Wind Energy Facility

Figure 5.4: Map taken from the Eastern Cape Biodiversity Conservation Plan showing the location of the turbines on land classified as “maintain near natural state” and “functional landscape”.

As with terrestrial CBAs, aquatic CBAs are grouped into BLMCs (Figure 5.5) as identified in the ECBCP. The ECBCP identified a large northern portion of land on which the wind turbines will be situated as CBA2 which is classified as ―maintain near natural state‖. The recommended land use objective for the ―maintain natural state‖ classification for Aquatic CBAs is same as for those of terrestrial CBAs.

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Great Kei Wind Energy Facility

Figure 5.5: Map taken from the ECBCP showing the Aquatic Critical Biodiversity Areas.

Subtropical Thicket Ecosystem Plan

The Subtropical Thicket Ecosystem Planning (STEP) Project map (Figure 5-6) indicates that all of the affected farms are classified as Class IV (currently not vulnerable land). This class includes ecosystems which cover most of their original extent and which are mostly intact, healthy and functioning. As a general rule, STEP suggests that depending on other factors, this Class IV land can withstand loss of natural area through disturbance or development. This development would obviously need to comply with suggested land use management guidelines and be in line with relevant Spatial Development Frameworks (SDFs). Within these constraints, the STEP suggests that this class is suitable for a wide range of activities such as extensive urban development, cultivation, tourism accommodation, ecotourism, game farming, etc.

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Great Kei Wind Energy Facility

Figure 5-6: Subtropical Thicket Ecosystem Planning (STEP) map indicating the site of the Great Kei Wind Energy Facility in relation to areas of critically endangered vegetation.

Coastal & Environmental Services 43 Great Kei Wind Energy Facility Scoping Report – April 2014 5.2 SITE DESCRIPTION

The table below indicates aspects of the general site in order to provide an indication of the prevailing environmental conditions. Figure 5-7: Grassland in the vicinity of WTG 04

Figure 5-8: A small farm dam near WTG 18

Coastal & Environmental Services 44 Great Kei Wind Energy Facility Scoping Report – April 2014 Figure 5-9: Thorn veld in the vicinity of WTG 19

Figure 5-10: Alien vegetation in the vicinity of WTG 25

Coastal & Environmental Services 45 Great Kei Wind Energy Facility Scoping Report – April 2014 Figure 5-11: An uninhabited old farm house in the vicinity of WTG 26.

Figure 5-12: View south from WTG 26.

5.3 SOCIO-ECONOMIC PROFILE

The site for the Great Kei wind energy facility falls within the ambit of Great Kei Local Municipality. It is likely that the development of the Great Kei wind energy project will have socio-economic impacts on the local municipal area and its population. Accordingly, the discussion that follows provides a brief socio-economic profile of the municipal area.

5.3.1 Demographics

Coastal & Environmental Services 46 Great Kei Wind Energy Facility Scoping Report – April 2014 Great Kei Local Municipality has a total population of approximately 44 469 people. Over 81 percent of the population of Great Kei lives in rural areas, villages and on farms. The population is spread amongst 6 wards with between 4 430 people (835 households) and 10052 people (1 897 households) resident in each ward. The average household consists of 4.8 people. The municipality comprises of 53% female and 47% male of the total population and consists of approximately 11 363 households.

According to Figure 6-10, 68 % of the population survive on a monthly household income of R800 or less. The major employment sectors in the municipality are agriculture (41 %), transport (15 %) and trade (14 %).

Figure 5-10: A graph indicating the monthly household income spread of the population of the Great Kei municipality (GKLM IDP, 2009).

5.3.2 Employment

Approximately 43 % of the population is economically active, however; only 21% of the population fall within the 20 to 34 year age group, this represents the half of the economically active population. This may be ascribed to the fact that (1) many of the economically active have left the municipality for further education, training and work; or (2) a distortion of the population pyramid through the possible impact of HIV/AIDS within this age group.

Figure 5-11: A graph indicating the major areas of employment in the Great Kei municipality (GKLM IDP, 2009).

Coastal & Environmental Services 47 Great Kei Wind Energy Facility Scoping Report – April 2014 The service centers of Komga and Kei Mouth as well as the coastal settlements of Morgan Bay, Haga-Haga and Cintsa can be described as urban areas falling within the national definition of "an urban area administered by a local authority or municipality". The population density within urban areas is estimated at 185 people/km2. This can be attributed to the diverse economic activity and higher level of social and physical infrastructure services to be found within the centres. Urban centres within the area display a growth rate of around 1.5% per annum compared to a negative growth rate of –1.9% for the entire Great Kei Municipal area. This is believed to be the result of the steady exodus of families from farming areas and adjacent rural settlements, causing a population increase within local urban centres. Recent studies in South Africa have found that resettlement to nearby small towns remains an attractive option to dislocated rural families and individuals (particularly women), as opposed to moving to larger urban environments such as Buffalo City, Port Elizabeth and Cape Town (DBSA 2001).

There are 34 primary schools within the Great Kei municipal area - located at Komga, Mooiplaas (9), Kwelera, Ocean View, and Icwili and upon Farms (20). There are 8 combined schools - located at Springvale, KwaTuba, Eluphindweni, Kwa-Jongilanga, Mooiplaas (2) and Farms (2). Three (3) secondary schools exist at Mooiplaas, Icwili and Eluqolweni. There is a notable deficiency in secondary schools available, resulting in this municipality being forced to send their pupils to secondary schools outside the municipal area. There is a trend that the educational facilities within the urban areas are of better quality and regular maintenance is being undertaken. Most of the population is leaving the municipality to receive further secondary and tertiary education, they do not return to the municipality after completing their education.

The Great Kei Municipal area appears to have a high illiteracy rate (25.6%) when compared to the rest of the country. This fact may be ascribed to a general low provision in higher education facilities within the municipality, a low demand for literacy within the local economic sector and the loss of a portion of the literate population to other work centres outside the municipality.

The Amathole District Municipality is also characterized by significant levels of underdevelopment, especially in the Eastern side of its region. The cause of this has been that there is very little if any investment in these areas.

The figure below shows economic growth of the ADM constituent local municipalities in 2002. GKLM rates the lowest in terms of economic growth, and in fact shows negative growth.

1.50 Buffalo City Mnquma 1.00 Nkonkobe

0.50 Nxuba Mbashe Amahlati Ngqshwa

0.00

-0.50 Great Kei

-1.00

Figure 5.12: Economic growth (%) of ADM constituent local municipalities during 2002 (ADM, LED Report, 2003)

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Coastal & Environmental Services 49 Great Kei Wind Energy Facility Scoping Report – April 2014 6 MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED

In terms of the EIA Regulations (2010), a Scoping Report must contain: (1) A scoping report must contain all the information that is necessary for a proper understanding of the nature of issues identified during scoping, and must include – (g) a description of environmental issues and potential impacts, including cumulative impacts, that have been identified.

6.1 POSSIBLE ENVIRONMENTAL ISSUES & IMPACTS

Below is a list of issues associated with wind energy generation facilities. The identification of these issues has resulted in the recommendation for various specialist assessments (see Table 6.1).

 Environmental Legal and Policy compliance

 Landscape & visual

 Ecology

 Noise

 Socio-economic

 Wetlands, Surface and Groundwater

 Traffic & transport

 Avifauna

 Electromagnetic Interference (EMI)

 Shadow flicker

 Cultural heritage & archaeology

 Waste Management

 Soil Erosion

 Air quality & climate change

 Land Use

6.2 IMPACT RATING

The above identified issues have been preliminarily rated according to an environmental significance scale. This scale is an attempt to evaluate the importance of a particular issue.

Negative issues that are ranked as being of ―VERY HIGH‖ and ―HIGH‖ significance will be investigated further to determine how the impact can be minimised or what alternative activities or mitigation measures can be implemented. These impacts may also assist decision makers i.e. many HIGH negative impacts may bring about a negative decision. These impacts will be assessed by specialist assessors trained to identify and minimize impacts related to their specialised field.

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For issues identified as having a negative impact of ―MODERATE‖ significance, it is standard practice to investigate alternate activities and/or mitigation measures. The most effective and practical mitigations measures will then be proposed as part of the general EIA impact assessment.

For issues ranked as ―LOW‖ significance, no investigations or alternatives will be considered. Possible management measures will be investigated to ensure that the impacts remain of low significance.

Table 6-1: Significance rating table No Significance There are no primary or secondary effects at all that are important to scientists or the public. Low Significance These issues will usually result in medium to short term effects on the social and/or natural environment. Impacts rated as LOW will need to be considered by the public and/or the specialist as constituting a fairly unimportant and usually short term change to the (natural and/or social) environment. These impacts are not substantial and are likely to have little real effect. Moderate Significance These issues will usually result in medium to long term effects on the social and/or natural environment. Impacts rated as MODERATE will need to be considered by society as constituting a fairly important and usually medium term change to the (natural and/or social) environment. These impacts are real but not substantial. High Significance These issues will usually result in long term effects on the social and/or natural environment. Impacts rated as HIGH will need to be considered by society as constituting an important and usually long term change to the (natural and/or social) environment. Society would probably view these impacts in a serious light. Very High Significance These issues would be considered by society as constituting a major and usually permanent change to the (natural and/or social) environment, and usually result in severe or very severe effects, or beneficial or very beneficial effects.

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Table 6-2: Significance of identified possible impacts. Issue Planning and Construction Operation Decommissioning Assessment Type Design Environmental Legal and Policy High No No No General EIR compliance Landscape & visual Very High Low Very High Low/ Specialist Ecology High High High High Specialist Noise Very High High Very High Low Specialist Socio-economic High High Very High Low Specialist Wetlands, Surface High High No No Specialist and Groundwater Traffic & transport Very High Very High No High General EIR Avifauna Very High No Very High No Specialist Electromagnetic Interference Low No High No General EIR (EMI) Shadow flicker Very High No No No Specialist Cultural heritage & archaeology Very High Very High No No Specialist Waste Management No High No High General EIR Soil erosion No Moderate No High Specialist Air Quality and Climate Change No No Very High No General EIR Land Use No No No Very High General EIR

The following specialist studies will be undertaken:

 Agricultural Impact Assessment (as required by DEA)  Avifaunal Impact Assessment  Bat Impact Assessment  Ecological Impact Assessment  Noise Impact Assessment  Visual Impact Assessment  Heritage Impact Assessment  Paleontological Impact Assessment  Socio-economic Impact Assessment

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An initial desktop assessment of the project area was undertaken using the following information:

 1:50 000 topographical maps  Google Earth imagery  The ECBCP  Standard buffer distances o National route: 250m o Eskom power lines: turbine drop height (160 – 180m) o Water courses: 32m o Noise sensitive areas: 500m

The preliminary site sensitivity/constraint (Figure 6-1), shows the interactions between these constraints and the preliminary wind turbine layout.

In most cases, micrositing of individual turbines will remove potential negative impacts, e.g. moving WTG 10 approximately 60m to the northwest would place it outside of the N2 buffer zone. At this stage of the EIA process, no turbines have been placed in areas that would require their removal from the layout.

Turbine Constrained at current Turbine Constrained at current number location? number location? WTG 01 Borders on a noise sensitive WTG 21 No area WTG 02 No WTG 22 No WTG 03 No WTG 23 No WTG 04 Close to a small dam WTG 24 No WTG 05 No WTG 25 No WTG 06 No WTG 26 No WTG 07 Within a power line buffer area WTG 27 No WTG 08 No WTG 28 Accessibility issues WTG 09 Within a power line and the N2 WTG 29 No buffer areas WTG 10 N2 buffer area WTG 30 No WTG 11 No WTG 31 No WTG 12 No WTG 32 No WTG 13 Close to a stream WTG 33 No WTG 14 No WTG 34 No WTG 15 No WTG 35 No WTG 16 Within a power line buffer area WTG 17 No WTG 18 Potentially steep slope WTG 19 No WTG 20 Potentially steep slope

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Great Kei Wind Energy Facility

Figure 6-1: Preliminary site sensitivity assessment.

Coastal & Environmental Services Great Kei54 Wind Energy Facility Scoping Report – April 2014 6.4 LONG-TERM BIRD AND BAT MONITORING PROGRAMMES

The bird and bat monitoring programmes have been in effect since August 2013.

6.4.1 Bird Monitoring Preliminary Report Summary

The 12 month pre-construction Bird Monitoring Programme is being undertaken by Mr Jon Smallie of Wildskies Ecological Services. The programme was initiated in August 2013 (winter survey), and is proposed to run until the winter of 2014.

Four site visits will be made during the programme, in order to adequately collect season data. While on site, a number of data collection methods will be used in order to maximise the quantity and improve the quality of the data collection. The methods proposed include:

 Sample counts of small terrestrial species  Counts of large terrestrial species and raptors  Focal site surveys  Incidental observations  Direct observation of bird movements

A control site, with many topographical and habitat similarities has been identified approximately 5km from the Great Kei site. This site will be monitored using the same data collection methods as for the project site. This is in line with the ―Best practice guidelines for avian monitoring and impact mitigation at proposed wind energy developments in Southern Africa‖.

A list of ‗target species‘ has been developed for the site based on regional and global conservation status. Table 6-4 indicates the species to be targeted as well as their conservation status.

Table 6-1. Preliminary target bird species for the Great Kei Wind Energy Facility site.

Barnes 2000 IUCN Presence on site Regional 2012 Conservation Global Common name status status - - Confirmed African Darter - - Likely African Harrier-Hawk VU LC Confirmed African Marsh-Harrier - - Confirmed African Sacred Ibis - - Confirmed African Spoonbill NT VU Confirmed Black Harrier - - Confirmed Black-headed Heron - - Confirmed Black-shouldered Kite NT LC Confirmed – likely Black-winged Lapwing seasonal VU VU Confirmed – likely Cape Vulture occasional visitor VU NT Confirmed – likely Denham's Bustard breeding on or near site - - Confirmed Egyptian Goose VU EN Confirmed – likely Grey Crowned Crane breeding on or near site - - Confirmed Grey Heron - - Confirmed – likely Jackal Buzzard breeding on or near site

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NT LC Confirmed Lanner Falcon - - Confirmed Long-crested Eagle - - Confirmed Red-billed Teal - - Confirmed Reed Cormorant - - Confirmed Rock Kestrel NT VU Confirmed – likely breeding in broader Secretarybird area - - Confirmed Spur-winged Goose - - Likely – summer visitor Steppe Buzzard - - Confirmed Yellow-billed Duck - - Likely – summer visitor Yellow-billed (Black) Kite EN = Endangered; VU = Vulnerable; NT = Near-threatened; LC = Least concern.

Of these target species the Denham‘s Bustard and Grey Crowned Crane stand out as being of most importance at this stage of this programme.

Preliminary findings (1 site survey)

The comment below should be considered preliminary in nature, and will be refined, added to or overruled based on additional data still to be collected on site over the course of the monitoring programme.

―The area under consideration is quite large, and very diverse in terms of the habitats it offers birds, and this is reflected in the bird species recorded on site. Monitoring has so far identified two river valleys that should probably be avoided by infrastructure. In addition a large dam on the farm Amberdene will probably be considered sensitive in the final analysis. The area of grassland and wetland immediately north of the N2 appears to be an important site for Denham’s Bustard, and other grassland and wetland species, and will probably need to be afforded some protection in the form of constraints on construction of infrastructure.‖ Jon Smallie, Wildskies

6.4.2 Bat Monitoring Preliminary Report Summary

The 12 month pre-construction Bat Monitoring Programme is being undertaken by Mr Werner Marais and associates, from Animalia Zoological and Ecological Consultation. The programme was initiated in August 2013 (winter survey), and is proposed to run until the winter of 2014.

Four site visits will be made during the programme, in order to adequately collect season data. During the site visits, standardised transects will be traversed each evening with a mobile bat detector in order to identify areas with significant bat activity.

Long term monitoring stations have been established on site; two on short masts at a height of 10 m, and one on a meteorological mast with two detectors (one at 10 m and one at 55 m). These systems will record bat activity every night for 12 months.

The following objectives have been defined for the bat study:  Study bat species assemblage and abundance on the site  Study temporal distribution of bat activity across the night as well as the four seasons of the year in order to detect peaks and troughs in activity  Determine whether weather variables (wind, temperature, humidity and barometric pressure) influence bat activity  Determine the weather range in which bats are mostly active  Develop long-term baseline data for use during operational monitoring.

Coastal & Environmental Services 56 Great Kei Wind Energy Facility Scoping Report – April 2014  Identify which turbines need to have special attention with regards to bat monitoring during the operational phase and if any turbines, if possible, would ideally be dropped from the final wind farm layout.  Detail the types of mitigation measures that are possible if bat mortalities rates are found to be unacceptable including the potential times/ circumstances which may result in high mortality rates

Once more detailed information becomes available (at least 3 months of passive data), a preliminary site sensitivity map can be created

Coastal & Environmental Services 57 Great Kei Wind Energy Facility Scoping Report – April 2014 7 PUBLIC PARTICIPATION

In terms of the EIA Regulations (2010), a Scoping Report must contain: (1) A scoping report must contain all the information that is necessary for a proper understanding of the nature of issues identified during scoping, and must include – (h) details of the public participation process conducted in terms of regulation 27 (a), including (i) the steps that were taken to notify potentially interested and affected parties of the application; (ii) proof that notice boards, advertisements and notices notifying potentially interested and affected parties of the application have been displayed, placed or given; (iii) a list of all persons or organisations that were identified and registered in terms of regulation 55as interested and affected parties in relation to the application; and (iv)a summary of the issues raised by interested and affected parties, the date of receipt of and the response of the EAP to those issues; (k) copies of the minutes of any meetings held by the EAP with interested and affected parties and other role players which record the views of the participants; and (l) Any responses by the EAP to those representations and comments and views

Coastal & Environmental Services 58 Great Kei Wind Energy Facility Scoping Report – April 2014 Release of Draft Scoping Report (28 November – 24 January 2014)

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Coastal & Environmental Services 66 Great Kei Wind Energy Facility Scoping Report – April 2014 Advert from newspaper (Published on the 29th of November 2013 – Daily Dispatch).

Coastal & Environmental Services 67 Great Kei Wind Energy Facility Scoping Report – April 2014 On-site signage

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Coastal & Environmental Services 79 Great Kei Wind Energy Facility Scoping Report – April 2014 Meeting Register for Focus Group Meeting: Municipality

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Photographs from the Focus group meeting with the Great Kei Local Municipality staff and ward councillors. Mr Lungisa Bosman (CES Social specialist, in the orange shirt) presented the project to attendees.

Coastal & Environmental Services 81 Great Kei Wind Energy Facility Scoping Report – April 2014 Meeting Register for Focus Group Meeting: Farm workers on affected properties

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Various photographs from the focus group meetings with farm workers.

Coastal & Environmental Services 86 Great Kei Wind Energy Facility Scoping Report – April 2014 Comments received

Mr SP van Huysteen, Surrounding landowner

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Coastal & Environmental Services 88 Great Kei Wind Energy Facility Scoping Report – April 2014 Mr Andre de Wet, surrounding landowner

Coastal & Environmental Services 89 Great Kei Wind Energy Facility Scoping Report – April 2014 Mr Bryan Church, Interested party

Coastal & Environmental Services 90 Great Kei Wind Energy Facility Scoping Report – April 2014 Mr Khaya Ndlazi, Interested party

Coastal & Environmental Services 91 Great Kei Wind Energy Facility Scoping Report – April 2014 Mr Roger Day, Affected landowner

Norton Thompson, Affected landowner

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Coastal & Environmental Services 93 Great Kei Wind Energy Facility Scoping Report – April 2014 DISTRIBUTION OF INITIAL NOTIFICATION LETTERS AND BID

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Organisation Name Email Postal Address Stakeholders

ADM: Municipal Manager Chris Magwangqana [email protected] P O Box 320, East London, 5200

Great Kei LM manager Mr Chris Mbekela [email protected] PO Box X2 Komga 4950

Great Kei Strategic Mr D Mbizeni [email protected] Manager Ward councillor 5 Cllr Mgema Private Bag X2, Great Kei Municipality, 17 Main Street, Komga. 4950 Eskom Eddie Leach [email protected]

SAHRA Mariagrazia Galimberti [email protected] DEDEA Mrs Hlomela Ntsini [email protected]

v.za

Amatole & BCMM Honjiwe Mayaphi [email protected]

SACAA Lizelle Stroh [email protected]

Chairman of Komga Mr Norton Thompson [email protected] Farmers Assoc. Department of Energy M Mathekgana mokgadi.mathekgana@energy.

gov.za DAFF (Agric) Ms Mashudu Marubini Delegate of the Minister (Act [email protected] Physical address: Delpen Building cnr 70 of 1970) Annie Botha and Union Street Office 270 Attention: Delegate of the Minister Act 70 of 1970

Ms Thoko Buthelezi AgriLand Liaison office [email protected] Postal Address: Department of Agriculture, Forestry and Fisheries Private Bag X120 Pretoria 0001 Attention: Delegate of the Minister Act 70 of 1970

Birdlife Border Ian Field [email protected] 16 Heidia Street Gonubie 5257

DWA Lizna Fourie [email protected] Farm Number Farm Name Name Email Postal Address Landowners

RE/56 Mr Norton Thompson [email protected] P O BOX 19, KOMGA, 4950 2/56, 3/56, 2/162 Cornelius Johannes Greyling P O BOX 27, KOMGA, 4950

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1/162 Napoleon [email protected]

RE/202 Gavin Strydom [email protected]

RE/1/163, RE/163 Pierre Hart [email protected]

2/164 Graham Hart [email protected] P O BOX 57, KOMGA, 4950

RE/203, 195, 196, 198, Roger Day [email protected] 197, 199, 201, RE/1/203, 193 Farm Number Name Email Postal Address Surrounding Landowners

1/160 Sindile Ngonyama 69 Frere Road Trust [email protected] 1/166, 442, RE/166 Mr UA Hein McGillivray Brothers Pty Ltd PO Box 15, Mooiplass, 5288 1/168, 184 Anna Susanna du Preez

194, 378, Roger Day Family Trust [email protected]

1/373, 375, 376, 377 Justin Claude Holl [email protected] 19A William Avenue, Vincent, 5247 1/52 Jacobus Nicolaas van Rooyen PO Box 689, Gonubie, 5256 1/55, 2/55, 438, RE/54, JW Els Farm Trust [email protected] RE/55 PO Box 18, Komga, 4950 1/57 LG Nel [email protected] 17 Rabie Street, Baysville, 5200 10/26, 12/26, RE/2/25, Craig George Carr [email protected] Tangla Farm, PO Box 176, Komga, 4950 RE/25, RE/26 156, 157, 158 Trevor Clive Harris Britnor Farming cc [email protected] PO Box 455, East London, 5200 161, 2/186, 443, 454 RSA Govt [email protected] ; [email protected]; [email protected] 185 Colin Melville Langdon Estates Pty Ltd [email protected] PO Box 51, East London, 5200 Russell 187, 188, 383, 384, 385, Jan Hendrik Riverwalk Trading [email protected] PO Box 147, Kwelera, 5259 386, 401 Bezuidenhout 189, 190, 191, 192 Stephanus Phillipus Huyssteen 8 Cuyler Street, Constantia Kloof, 1708

2/58 Elvin Victor Krull [email protected] PO Box 1165, East London, 5200 205 Michael Desmond Khaya la Bantu Courtlands [email protected] PO Box 6, Mooiplaas, 5288

Coastal & Environmental Services Great Kei104 Wind Energy Facility Scoping Report – April 2014 Corbett Farms 210 Thembakazi Vinolia Botoka Trading No 90 St Georgers Road, Southernwood, Nyaka East London, 5201 211 SA Native Trust

3/159 Andre de Wet Zero Waste Organic Farming [email protected] Trust 209/3, RE/209 Nomathamsanqa Superspot 4 [email protected] Madliwa 3/25, 4/56, RE/10, RE/27 Norton Peter Thompson [email protected] P O BOX 19, KOMGA, 4950 335, 336, 337, 346 Rudolf Alfred Gernetzky Rooikop farm, P O Box 1, Mooiplaas, 5288 349, 350, 351 Peter Wayne Barnes [email protected] PO Box 12, Mooiplaas, 5288 371, 372, 381, 382, Eugene Desman Venske PO Box 1447, East London, 5200 390,391, 392, 394, 396 387, 388, 397, 398, 400, Siviwe Stemele Stemele Farming cc PO Box 330, Mooiplaas, 5288 402, 404, 406 (manager) Sicelo Stemele Stemele Farming cc [email protected] PO Box 330, Mooiplaas, 5288 393, RE/373 Nobusi Zita-Malusi [email protected] PO Box 12659, Amalinda, 5252 403 Michael Maurice Ehlert PO Box 65, Mooiplaas, 5288 445 [email protected] PO Box 6, Komga, 4950 7/57 Melvin Edgar Hein Welterverede Farm, Mooiplaas, East London, 5288

RE/1/209 Notozana White [email protected] PO Box 18058, Quigney, 5211 RE/159 Kenneth August Freitag PO Box 55, Mooiplaas, 5288 RE/168 Jacques Steyn du Preez [email protected] PO Box 182, Bideford, Komga, 4950

RE/183 Transnet Ltd [email protected] RE/2/159 Adriano Paul Striglia [email protected] PO Box 119, Komga, 4950 RE/2/209 Richard Pindile Nkatu [email protected] PO Box 2812, Beacon Bay, 5205 RE/52 WH Vermeulen PO Box 124, Komga, 4950 RE/53 Murray Matthew Tainton Estates Pty Ltd [email protected] PO Box 90, Komga, 4950 Harman Elliott

RE/57 WR Kretzmann [email protected] Hopewell Farm, Komga, 4950

Coastal & Environmental Services Great Kei105 Wind Energy Facility Scoping Report – April 2014 8 RECOMMENDATIONS

8.1 ACTIVITY DESCRIPTION

The proposed activity involves the establishment of a wind energy facility in the Great Kei Local Municipality, to be located on farm land in the Komga area.

The details of the proposed facility include:  Construction and operation of 35 turbines to produce up to 115.5 MW of electricity.  Construction of access roads within the wind farm locality.  Construction of underground infrastructure required for the transmission of the electricity generated on the wind farm to the Chaba substation.

The nature of the proposed site for the establishment of the facility is suitably placed on land currently used for livestock grazing. However, the establishment of the proposed facility raises various issues relating to visual intrusion on the landscape, noise impacts on surrounding land inhabitants, and bird and animal impacts.

It is therefore vital that all possible impacts are evaluated and the best mitigation measures and design alternatives be implemented.

In addition to this it is vital that the EIA process include engagement with the relevant registered I&APs.

8.2 FATAL FLAWS

At this stage no fatal flaws have been identified, and there is no reason why the proposed development should not proceed to EIA.

8.3 EIR PHASE

It is recommended that the following form part of the EIR phase:

 Public Participation  Specialist studies  Consultation with I&APs regarding possible significance of impacts and suitable mitigation measures.  Evaluation of impacts prior to mitigation.  Compilation of mitigation measures.  Evaluation of impacts after mitigation.  Provision of an opinion as to whether or not the activity should be authorised.  Compilation of an environmental impact statement.  Compilation of a draft Environmental Management Programme (EMP).

These key issues are to be addressed and assessed in full detail during the EIR phase.

Coastal & Environmental Services 106 Great Kei Wind Energy Facility Scoping Report – April 2014 9 PLAN OF STUDY FOR THE EIA

In terms of the EIA Regulations (2010), a Scoping Report must contain: (1) A scoping report must contain all the information that is necessary for a proper understanding of the nature of issues identified during scoping, and must include – (n) a plan of study for environmental impact assessment which sets out the proposed approach to the environmental impact assessment of the application, which must include: (i) a description of the tasks that will be undertaken as part of the environmental impact assessment process, including any specialist reports or specialised processes, and the manner in which such tasks will be undertaken; (ii) an indication of the stages at which the competent authority will be consulted (iii) a description of the proposed method of assessing the environmental issues and alternatives, including the option of not proceeding with the activity; and (iv) particulars of the public participation process that will be conducted during the environmental impact assessment process

In line with the above-mentioned legislative requirement, this Chapter therefore sets out the Plan of Study (PoS) for the EIA phase of the assessment. Consultation with DEA will be on-going throughout this EIA. However, it is anticipated that DEA will provide relevant comment with respect to the adequacy of this Plan of Study for the EIA, as it informs the content of the EIR and sufficiency thereof.

9.1 EIA PHASE

The EIA phase has four key elements, namely:-

 Specialist Studies: Specialist studies identified as being necessary during the Scoping Phase, plus any additional studies that may be required by the authorities, will be undertaken during the initial phase of the EIA. Appropriately qualified and experienced specialists will be appointed to undertake the various assessments. Specialists will gather baseline information relevant to the study being undertaken and will assess impacts associated with the development. Specialists will also make recommendations to mitigate negative impacts and enhance benefits. The resulting information will be synthesised into the Environmental Impact Report (EIR), whilst the full specialist reports will be attached to the EIR as a Specialist Volume.

 Environmental Impact Report (EIR): The main purpose of this report is to gather and synthesise environmental information and evaluate the overall environmental impacts associated with the development, to consider mitigation measures and alternative options, and make recommendations in choosing the best development alternative. The EIR also identifies mitigation measures and management recommendations to minimise negative impacts and enhance benefits. The EIR and associated specialist reports are made available for public and authority review and comment. The availability of the report will be advertised in one Provincial and one local newspaper and the report will also be made available for public scrutiny in easily accessible locations.

 Comments Report: The comments report provides a detailed record of comments, issues and concerns raised by I&APs and the authorities during the review period, and also provides relevant responses to these comments.  Environmental Management Programme (EMPr): The EMPr provides guidelines to the

Coastal & Environmental Services 107 Great Kei Wind Energy Facility Scoping Report – April 2014 project proponent and the technical team on how best to implement the mitigation measures and management recommendations outlined in the EIR during the construction and operational phase.

In addition to the above, the Public Participation Process commenced during the Scoping Phase is continued, during which I&APs are afforded further opportunities to raise their issues, concerns and comments regarding the proposed project. It is possible that some of the project details may have changed in response to the preliminary findings of the Scoping Report, and as a result of design changes made by the project proponent. I&APs and key stakeholders are given the opportunity to review the Draft EIR before it is submitted to the authorities for consideration. Comments on the Draft EIR received from I&APs are included and addressed in the submitted EIR.

9.2 SPECIALIST STUDIES

The following Specialist Studies are proposed for the EIA Phase of the assessment –

 Visual and Landscape Impact Assessment  Ecological Assessment (Flora and Fauna)  Noise impact Assessment  Archaeological Impact Assessment  Avifauna Assessment  Bat Assessment  Palaeontological Impact Assessment  Agricultural Impact Assessment  Socio-economic Impact Assessment

The Terms of Reference for the above-mentioned studies, which outline the information required from the specialists, are provided in Sections 9.1.1.1 – 9.1.1.5 below and the methodology for assessing the significance of impacts and alternatives is described in Section 9.1.2 that follows. Specialists will also be required to address issues raised by I&APs in their reports.

9.2.1 Visual and Landscape Impact Assessment

The specific Terms of Reference for the Visual and Landscape Impact Assessment will include:-

1. Conduct a site reconnaissance visit and photographic survey of the proposed project site. 2. Conduct a desk top mapping exercise to establish visual sensitivity:-  Describe and rate the scenic character and sense of place of the area and site.  Establish extent of visibility by mapping the view-sheds and zones of visual influence  Establish visual exposure to viewpoints  Establish the inherent visual sensitivity of the site by mapping slope grades, landforms, vegetation, special features and land use and overlaying all relevant above map layers to assimilate a visual sensitivity map. 3. Review relevant legislation, policies, guidelines and standards. 4. Preparation of a draft Visual Baseline/Sensitivity report  Assessing visual sensitivity criteria such as extent of visibility, the sites inherent sensitivity, visual sensitivity of the receptor‘s, visual absorption capacity of the area and visual intrusion on the character of the area  Prepare photomontages of the proposed development  Conduct shadow flickering modelling  Assess the proposed project against the visual impact criteria (visibility, visual exposure, sensitivity of site and receptor, visual absorption capacity and visual intrusion) for the site.  Assess impacts based on a synthesis of criteria for each site (criteria = nature of impact, extent, duration, intensity, probability and significance)

Coastal & Environmental Services 108 Great Kei Wind Energy Facility Scoping Report – April 2014  Establish mitigation measures/recommendations with regards to minimizing visual risk areas

9.2.1 Ecological Impact Assessment

The assessment will follow on from the initial study, which included a site visit (see Chapter 4 above) conducted during the scoping phase, and will address any key issues raised by interested and affected parties. The study will also comprise a desktop study of all available relevant literature.

A detailed survey of the site will be undertaken to determine the possibility of there being listed threatened or protected ecosystems and species on the proposed project site. If any of these are found, the Environmental Management Plan will include recommended measures to remove or otherwise protect plant species found on the site that are afforded protection under the National Environmental Management: Biodiversity Act during construction.

This specialist study will therefore include but will not be limited to –

 A detailed description of the ecological (fauna and flora) environment within and immediately surrounding the footprint of the proposed development and will consider terrestrial fauna and flora. Fauna include mammals, reptiles, amphibians, and insects but not avifauna as these will be the subject of a separate specialist study (refer to Section 8.1.1.5 below). This aspect of the report will specifically include the identification of -  Areas of high biodiversity;  The presence of species of special concern, including sensitive, endemic and protected species;  Habitat associations and conservation status of the identified fauna and flora;  The presence of areas sensitive to invasion by alien species; and  The presence of conservation areas and sensitive habitats where disturbance should be avoided or minimised.  Review relevant legislation, policies, guidelines and standards.  An assessment of the potential direct and indirect impacts resulting from the proposed development (including the wind turbines, associated infrastructure e.g. access road), both on the footprint and the immediate surrounding area during construction and operation.  A detailed description of appropriate mitigation measures that can be adopted to reduce negative impacts for each phase of the project, where required; and  Checklists of faunal groups identified in the region to date, highlighting sensitive species and their possible areas of distribution.

9.2.2 Noise Impact Assessment

1. Determine the land use zoning and identify all potential noise sensitive sites that could be impacted upon by activities relating to the construction and operation of the proposed wind energy facility. 2. Identify all noise sources relating to the activities of the facility during the construction and operation phases that could potentially result in a noise impact at the identified noise sensitive sites. 3. Determine the sound emission, operating cycle and nature of the sound emission from each of the identified noise sources. 4. Calculate the combined sound power level due to the sound emissions of the individual noise sources. 5. Calculate the expected rating level of sound at the identified noise sensitive sites from the combined sound power level emanating from identified noise sources. 6. Display the rating level of sound emitted by the noise sources in the form of noise contours superimposed on the map of the study area. 7. Determine the existing ambient levels of noise at identified noise sensitive sites by conducting representative sound measurements.

Coastal & Environmental Services 109 Great Kei Wind Energy Facility Scoping Report – April 2014 8. Determine the acceptable rating level for noise at the identified noise sensitive sites. 9. Calculate the noise impact at identified noise sensitive sites. 10. Assess the noise impact at identified noise sensitive sites in terms of:-  SANS 101 SANS 10103 for ―The measurement and rating of environmental noise with respect to land use, health, annoyance and to speech communication‖.  Noise Control Regulations.  World Health Organisation - Guidelines for Community Noise.  World Bank - Environmental Guidelines. 11. Investigate alternative noise mitigation procedures, if required, in collaboration with the design engineers of the facility and estimate the impact of noise upon implementation of such procedures. 12. Prepare and submit a full environmental noise impact report containing detailed procedures and findings of the investigation including recommended noise mitigation procedures, if relevant.

9.2.3 Archaeological Impact Assessment

The National Heritage Resources Act 25 of 1999 (NHR) requires that ―…any development or other activity which will change the character of a site exceeding 5 000m², or the rezoning or change of land use of a site exceeding 10 000 m², requires an archaeological impact assessment‖

An archaeological impact assessment will therefore be conducted, the primary objective of which is to determine whether there are any indications that the proposed site is of archaeological significance. This will be a phase 1 assessment and will be largely desk-top although a site visit will be required to enable the specialist the opportunity to look for significant artefacts on the surface of the site. It is not expected that a more detailed Phase 2 assessment will be required but this remains to be confirmed.

The terms of reference for the Phase 1 archaeological study will be to:

 Determine the likelihood of archaeological remains of significance in the proposed site;  Identify and map (where applicable) the location of any significant archaeological remains;  Assess the sensitivity and significance of archaeological remains in the site; and  Identify mitigation measures to protect and maintain any valuable archaeological sites and remains that may exist within the proposed site.

9.2.4 Avifauna Assessment

An avifauna specialist study will be conducted. The assessment will include:

 A desk-top review of existing literature

The literature will seek: 1. Previous means of predicting bird mortality (and other impacts) of wind turbines affecting birds in groups similar to those in the study area. 2. Accounts of mortality at wind turbines 3. Information on the status, in Komga, Eastern Cape, South Africa and globally, of bird groups most likely to be affected

 A site visit to identify species of special concern and assess the likely impacts of the construction and operational phases on the avifauna of the site.

Surveys will be conducted on at least two days at sites at either end, and in the middle of the proposed turbine corridor and, as a control against the post construction situation, one-day surveys at two similar sites outside the turbine affected area. Survey sites will be selected to reflect variation in local habitat and terrain.

Coastal & Environmental Services 110 Great Kei Wind Energy Facility Scoping Report – April 2014 At each site, a camp will be established in the early afternoon. Two hours of observations will be undertaken before dusk and two during the first hours of darkness (when night-migrating birds are likely to be flying at lower altitude). Observations will begin again at first light and continue for 3-4 hours (depending on bird activity levels and especially the use of thermals by soaring birds).

During daylight in each survey hour  2 x 15 minutes for visual scans of birds crossing the proposed turbine corridor (with appraisal of flight height above the ground)  2 x 10 minutes circular point surveys

After dark in each hour scans by night vision binoculars  2 x 10 minutes focused on bird activity

 Conduct a review of international literature and experience relating to operational wind farms; including state of the art plants around the world  Contextualize the literature and experience and relate it to the Eastern Cape scenario and local avifauna;  Map sensitive areas in and around the proposed project site(s);  Describe the affected environment and determine the status quo in terms of avifauna;  Indicate how an avifaunal resource or community will be affected by the proposed project;  Discuss gaps in the baseline data with respect to avifauna and relevant habitats;  List and describe the expected impacts;  Assess and evaluate the anticipated impacts, and;  Make recommendations for relevant mitigation measures which will allow the reduction of negative impacts and the maximization of the benefits associated with any identified positive impacts.

Although the avifauna specialist will assess avian collision risk and provide detailed explanations and ratings of the likelihood of collisions of various species, detailed avian collision modelling i.e. quantitatively assessing the collision risk potential (i.e. birds directly colliding with rotor blades and turbine towers) of the proposed wind farm cannot be undertaken. This is because the extent to which this can formally be modelled and quantified to arrive at predicted numbers of collisions, would depend largely on the primary data collection related to flight frequencies and species, but it is unlikely that even the best possible data collection between now and mid 2011 would provide much confidence in such a model, as it would require more representative data collection across a range of conditions/seasons etc. In addition, very often the worst bird collision ‗events‘ at wind farms around the world have been found to have occurred in extreme weather conditions, when flight behaviour etc. is abnormal.

9.2.5 Bat Assessment

A bat specialist study will be conducted. The assessment will include:

 A desk-top review of existing literature

The literature will seek: 1. Previous means of predicting bat mortality (and other impacts) of wind turbines affecting birds in groups similar to those in the study area. 2. Accounts of mortality at wind turbines 3. Information on the status, in Komga, Eastern Cape, South Africa and globally, of bat groups most likely to be affected.

 A site visit to identify species of special concern and assess the likely impacts of the construction and operational phases on the bat of the site.

Surveys will be conducted on at least two days at sites at either end, and in the middle of the proposed turbine corridor and, as a control against the post construction situation, one-day surveys

Coastal & Environmental Services 111 Great Kei Wind Energy Facility Scoping Report – April 2014 at two similar sites outside the turbine affected area. Survey sites will be selected to reflect variation in local habitat and terrain.

At each site, a camp will be established in the late afternoon. Two hours of observations will be undertaken during the first hours of darkness and two hour during the night (when bat activity is likely to be the highest). Observations will begin again at first light and continue for 2-3 hours (depending on bat activity levels).

During dusk in each hour survey  2 x 10 minutes focused on bat activity

During dark hours in each survey hour  2 x 15 minutes for visual scans of bats crossing the proposed turbine corridor (with appraisal of flight height above the ground)  2 x 10 minutes circular point surveys

 Conduct a review of international literature and experience relating to operational wind farms; including state of the art plants around the world  Contextualize the literature and experience and relate it to the Eastern Cape scenario and local bat fauna;  Map sensitive areas in and around the proposed project site(s);  Describe the affected environment and determine the status quo in terms of bat fauna;  Indicate how a bat resource or community will be affected by the proposed project;  Discuss gaps in the baseline data with respect to bats and relevant habitats;  List and describe the expected impacts;  Assess and evaluate the anticipated impacts, and;  Make recommendations for relevant mitigation measures which will allow the reduction of negative impacts and the maximization of the benefits associated with any identified positive impacts.

Although the bat specialist will assess bat collision risk and provide detailed explanations and ratings of the likelihood of collisions of various species, detailed bat collision modelling i.e. quantitatively assessing the collision risk potential (i.e. bats directly colliding with rotor blades and turbine towers) of the proposed wind farm cannot be undertaken. This is because the extent to which this can formally be modelled and quantified to arrive at predicted numbers of collisions, would depend largely on the primary data collection related to flight frequencies and species, but it is unlikely that even the best possible data collection between now and mid 2012 would provide much confidence in such a model, as it would require more representative data collection across a range of conditions/seasons etc. In addition, very often the worst bat collision ‗events‘ at wind farms around the world have been found to have occurred in extreme weather conditions, when flight behaviour etc. is abnormal.

9.2.6 Palaeontological Impact Assessment

Following the ―SAHRA APM Guidelines: Minimum Standards for the Archaeological & Palaeontological Components of Impact Assessment Reports‖ the aims of the PIA are to:  identify exposed and subsurface rock formations that are considered to be palaeontologically significant;  assess the level of palaeontological significance of these formations;  conduct fieldwork to assess the immediate risk to exposed fossils as well as to document and sample these localities;  comment on the impact of the development on these exposed and/or potential fossil resources;  make recommendations as to how the developer should conserve or mitigate damage to these resources.

Coastal & Environmental Services 112 Great Kei Wind Energy Facility Scoping Report – April 2014 9.2.7 Agricultural Impact Assessment

The study site and surrounding areas will be described using a two-phased approach. Firstly, a desktop assessment of the site will be conducted in terms of current agricultural classifications. The assessment will be based on existing soil and agricultural potential data for the site.

Further to the above, a site visit will be conducted to assess soils onsite. Soil samples will be collected at random points and sent to a Soil Laboratory for comparative analysis.

The following terms of reference is used as a guideline for the study:

 Identify and assess all potential impacts (direct, indirect and cumulative) and economic consequences of the proposed development on soils and agricultural potential.  Describe and map soil types (soil forms) and characteristics (soil depth, soil colour, limiting factors, and clay content of the top and sub soil layers.  Describe the slope of the site.  Determine the agricultural potential of the site.  Describe current land use as well as possible alternative land use options.  Provide recommended mitigation measures, monitoring requirements, and rehabilitation guidelines.

9.2.8 Socio-economic Impact Assessment

The major function of an SIA is to alert the developer to the most critical impacts of a project and to provide suggestions for mitigation and management planning. This issues-based approach will ensure that proposed activity impacts will be socially acceptable, bearing in mind local residents‘ abilities both to deal with and adapt to change and the residents‘ relative fragility within this process. It should be borne in mind, however, that the implementation of mitigation measures is not the sole responsibility of the developer. Government departments will have to play a role in ensuring that some of the impacts identified in an SIA and mitigation measures proposed are implemented.

The project is anticipated to impact directly upon the people living in the study area and those in the wider local municipality. The ToR for this study will require the study team to:

 Examine the impacts of the project, to contextualise these impacts and then to assess them;  Provide recommendations for mitigating the assessed impacts;  Investigate the legal and institutional opportunities and constraints relevant to the establishment of the trust; and  Review the comments made by Interested and Affected Parties (I&APs) to ensure that all issues and concerns raised by them have been addressed and, if some issues cannot be addressed at this stage, indicate these in the report and discuss the implications or when can they be addressed.

In order to fulfil the brief, the report will examine the macro socio-economic environment and the municipality context and then consider the way in which households will be directly affected by the project. The report will then assesses impacts, rate them against a standard impact assessment rating, and provide recommendations for mitigation and management strategies that might be applied to deal with the impacts.

9.3 METHODOLOGY FOR ASSESSING THE SIGNIFICANCE OF IMPACTS

Although specialists will be given relatively free rein on how they conduct their research and obtain information, they will be required to provide their reports to the EAP in a specific layout and structure, so that a uniform specialist report volume can be produced.

Coastal & Environmental Services 113 Great Kei Wind Energy Facility Scoping Report – April 2014 To ensure a direct comparison between various specialist studies, a standard rating scale has been defined and will be used to assess and quantify the identified impacts. This is necessary since impacts have a number of parameters that need to be assessed. Five factors need to be considered when assessing the significance of impacts, namely:

1. Relationship of the impact to temporal scales - the temporal scale defines the significance of the impact at various time scales, as an indication of the duration of the impact.

2. Relationship of the impact to spatial scales - the spatial scale defines the physical extent of the impact.

3. The severity of the impact- the severity/beneficial scale is used in order to scientifically evaluate how severe negative impacts would be, or how beneficial positive impacts would be on a particular affected system (for ecological impacts) or a particular affected party.

The severity of impacts can be evaluated with and without mitigation in order to demonstrate how serious the impact is when nothing is done about it. The word ‗mitigation‘ means not just ‗compensation‘, but also the ideas of containment and remedy. For beneficial impacts, optimization means anything that can enhance the benefits. However, mitigation or optimization must be practical, technically feasible and economically viable.

4. The likelihood/probability of the impacts occurring - the likelihood of impacts taking place as a result of project actions differs between potential impacts. There is no doubt that some impacts would occur (e.g. loss of vegetation), but other impacts are not as likely to occur (e.g. vehicle accident), and may or may not result from the proposed development. Although some impacts may have a severe effect, the likelihood of them occurring may affect their overall significance.

The environmental significance scale is an attempt to evaluate the importance of a particular impact. This evaluation needs to be undertaken in the relevant context, as an impact can either be ecological or social, or both. The evaluation of the significance of an impact relies heavily on the values of the person making the judgment. For this reason, impacts of especially a social nature need to reflect the values of the affected society.

Negative impacts that are ranked as being of ―VERY HIGH‖ and ―HIGH‖ significance will be investigated further to determine how the impact can be minimised or what alternative activities or mitigation measures can be implemented. These impacts may also assist decision makers i.e. lots of HIGH negative impacts may bring about a negative decision.

For impacts identified as having a negative impact of ―MODERATE‖ significance, it is standard practice to investigate alternate activities and/or mitigation measures. The most effective and practical mitigations measures will then be proposed.

For impacts ranked as ―LOW‖ significance, no investigations or alternatives will be considered. Possible management measures will be investigated to ensure that the impacts remain of low significance.

Coastal & Environmental Services 114 Great Kei Wind Energy Facility Scoping Report – April 2014 Table 9-1: Criterion used to rate the significance of an impact

Significance Rating Table

Temporal Scale (The duration of the impact) Short term Less than 5 years (Many construction phase impacts are of a short duration). Medium term Between 5 and 20 years.

Long term Between 20 and 40 years (From a human perspective almost permanent). Permanent Over 40 years or resulting in a permanent and lasting change that will always be there. Spatial Scale (The area in which any impact will have an affect) Individual Impacts affect an individual.

Localised Impacts affect a small area of a few hectares in extent. Often only a portion of the project area. Project Level Impacts affect the entire project area.

Surrounding Areas Impacts that affect the area surrounding the development

Municipal Impacts affect either the Local Municipality, or any towns within them.

Regional Impacts affect the wider district municipality or the province as a whole. National Impacts affect the entire country.

International/Glob Impacts affect other countries or have a global influence. al Will definitely Impacts will definitely occur. occur Degree of Confidence or Certainty (The confidence with which one has predicted the significance of an impact) Definite More than 90% sure of a particular fact. Should have substantial supportive data. Probable Over 70% sure of a particular fact, or of the likelihood of that impact occurring. Possible Only over 40% sure of a particular fact, or of the likelihood of an impact occurring. Unsure Less than 40% sure of a particular fact, or of the likelihood of an impact occurring.

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Table 9-2: The severity rating scale Impact severity (The severity of negative impacts, or how beneficial positive impacts would be on a particular affected system or affected party) Very severe Very beneficial An irreversible and permanent change to the A permanent and very substantial benefit to affected system(s) or parties which cannot be the affected system(s) or parties, with no mitigated. For example the permanent loss of real alternative to achieving this benefit. For land. example the vast improvement of sewage effluent quality. Severe Beneficial Long term impacts on the affected system(s) A long term impact and substantial benefit or parties that could be mitigated. However, to the affected system(s) or parties. this mitigation would be difficult, expensive or Alternative ways of achieving this benefit time consuming, or some combination of would be difficult, expensive or time these. For example, the clearing of forest consuming, or some combination of these. vegetation. For example an increase in the local economy. Moderately severe Moderately beneficial Medium to long term impacts on the affected A medium to long term impact of real system(s) or parties, which could be benefit to the affected system(s) or parties. mitigated. For example constructing the Other ways of optimising the beneficial sewage treatment facility where there was effects are equally difficult, expensive and vegetation with a low conservation value. time consuming (or some combination of these), as achieving them in this way. For example a ‗slight‘ improvement in sewage effluent quality. Slight Slightly beneficial Medium or short term impacts on the affected A short to medium term impact and system(s) or parties. Mitigation is very easy, negligible benefit to the affected system(s) cheap, less time consuming or not necessary. or parties. Other ways of optimising the For example a temporary fluctuation in the beneficial effects are easier, cheaper and water table due to water abstraction. quicker, or some combination of these. No effect Don’t know/Can’t know The system(s) or parties are not affected by In certain cases it may not be possible to the proposed development. determine the severity of an impact.

Table 9-3: The rating of overall significance Overall Significance (The combination of all the above criteria as an overall significance) VERY HIGH NEGATIVE VERY BENEFICIAL These impacts would be considered by society as constituting a major and usually permanent change to the (natural and/or social) environment, and usually result in severe or very severe effects, or beneficial or very beneficial effects. Example: The loss of a species would be viewed by informed society as being of VERY HIGH significance. Example: The establishment of a large amount of infrastructure in a rural area, which previously had very few services, would be regarded by the affected parties as resulting in benefits with VERY HIGH significance. HIGH NEGATIVE BENEFICIAL These impacts will usually result in long term effects on the social and/or natural environment. Impacts rated as HIGH will need to be considered by society as constituting an important and usually long term change to the (natural and/or social) environment. Society would probably view these impacts in a serious light. Example: The loss of a diverse vegetation type, which is fairly common elsewhere, would

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have a significance rating of HIGH over the long term, as the area could be rehabilitated. Example: The change to soil conditions will impact the natural system, and the impact on affected parties (such as people growing crops in the soil) would be HIGH. MODERATE NEGATIVE SOME BENEFITS These impacts will usually result in medium to long term effects on the social and/or natural environment. Impacts rated as MODERATE will need to be considered by society as constituting a fairly important and usually medium term change to the (natural and/or social) environment. These impacts are real but not substantial. Example: The loss of a sparse, open vegetation type of low diversity may be regarded as MODERATELY significant. LOW NEGATIVE FEW BENEFITS These impacts will usually result in medium to short term effects on the social and/or natural environment. Impacts rated as LOW will need to be considered by the public and/or the specialist as constituting a fairly unimportant and usually short term change to the (natural and/or social) environment. These impacts are not substantial and are likely to have little real effect. Example: The temporary change in the water table of a wetland habitat, as these systems is adapted to fluctuating water levels. Example: The increased earning potential of people employed as a result of a development would only result in benefits of LOW significance to people who live some distance away. NO SIGNIFICANCE There are no primary or secondary effects at all that are important to scientists or the public. Example: A change to the geology of a particular formation may be regarded as severe from a geological perspective, but is of NO significance in the overall context. DON’T KNOW In certain cases it may not be possible to determine the significance of an impact. For example, the primary or secondary impacts on the social or natural environment given the available information. Example: The effect of a particular development on people‘s psychological perspective of the environment.

9.4 ENVIRONMENTAL IMPACT REPORT

The results of the Specialist Studies given above will inform the preparation of the EIR. In addition, the EIR will gather any comments received from I&APs and determine whether it is necessary to increase the scope of work or amend the ToR.

The EIR will also examine the option of not proceeding with the proposed development – the so- called ―No Go‖ option.

9.4.1 Proposed structure of EIR

To avoid the EIR being excessively long and cumbersome, whilst meeting the content requirements specified in the NEMA EIA regulations, the final report will be divided into a number of volumes indicated in Table 9-4.

Table 9-4: Reports that will be generated in the EIA phase for the proposed Great Kei Wind Energy Project Report Contents Scoping Report

Environmental Impact This report will contain the following; Report (EIR) 1. Introduction  Detail of the environmental assessment practitioner who compiled the report  Expertise of the EAP to carry out an environmental impact assessment

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2. Description of the Project  A description of the property on which the activity is to be undertaken  The location of the activity on the property  A description of the types of activities that are proposed for the development. 3. Description of the Affected Environment  The natural environment  The socio-economic environment  The legal, policy and planning setting 4. The Public Participation Process  Steps undertaken in order to notify and involve I&APs  Advertisements and media  Meetings held in the PPP  Issues and Comment Trail management 5. Summary of Comments and Response Trail  Summary of comments and issues raised by I&APs and responses to the issues 6. Summary of Specialist Reports  Summary of the findings and recommendations of all specialist studies 7. Alternatives Considered  Description of all alternatives considered in the EIA  Initial screening of alternatives  Description and comparative assessment of all alternatives identified during the EIA 8. The Significance of Potential Environmental Impacts  The methodology used to determine the significance of environmental impacts  Impacts on the natural environment  Impacts on the socio-economic environment  Impacts on the legal, policy and planning setting 9. Environmental Impact Statement  A summary of the key findings of the EIA  Comparative assessment of the positive and negative implications of the proposed activity and identified alternatives 10. Conclusions  Mitigation measures for identified adverse environmental impacts  Opinion as to whether the activity should or should not be authorised  Any conditions that should be made in respect to any form of authorisation

It should be noted that the above is not the exact Table of Contents for the EIA, but is intended to indicate the major topics that will be covered in the report.

Specialist Studies This will be a compilation of all the specialist studies undertaken in the EIA, and will include detailed assessments of -  Visual impacts  Heritage impacts  Paleontological impacts  Noise impacts  Ecological impacts  Avifauna impacts  Bat Impacts  Agricultural impacts  Socio-economic impacts

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Comments and This will include - Response Trail 1. Lists of persons, organisations and organs of state that were registered as I&APs 2. Comments and Response trail for the Scoping and EIA phases 3. Copies of any representations, objections and comments received from I&APs Environmental Environmental management programme for key activities at the proposed Management renewable energy facility, which will contain the following - Programme (EMP) 1. Introduction  The details of the EAP who prepared the EMP  The expertise of the EAP to prepare an EMP 2. Detailed description of the aspects of the activity covered by the EMP 3. Mitigation Measures and Actions  Planning and Design  Pre-construction and construction activities  Operation and undertaking of the activity  Rehabilitation of the environment 4. Responsibilities  Persons responsible  Time periods for implementation 5. Monitoring Programme

9.5 CONSIDERATION BY THE COMPETENT AUTHORITY FOR ENVIRONMENTAL AUTHORISATION AND APPEALS PROCESS

Once the EIR has been finalised it will be submitted to the competent authority for review and consideration for authorisation. The authority will grant authorisation, refuse authorisation or request further detail or information to clarify areas of concern. Should authorisation be granted, the decision will carry Conditions of Approval, to which the proponent is obliged to adhere.

The competent authority‘s decision will be advertised in the newspapers mentioned in Chapter 7 (Public Participation) above and registered I&APs will be informed within 12 days of the date of the Decision. Once the public have been notified of the Environmental Authorisation, anyone wishing to appeal the decision must lodge a notice of intention to appeal with the Minister, MEC or delegated person within 20 days of the date of decision on the application, and the appeal must be submitted, on a form prescribed by the competent authority, within 30 days after the lapsing of the 20 days of notice for the intention to appeal.

Coastal & Environmental Services 119 Great Kei Wind Energy Facility Scoping Report – April 2014 10 REFERENCES

IDP: Integrated Development Plan of the Great Kei Local Municipality

IDP: Integrated Development Plan of the Amathole District Municipality

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

National Environment Management Act (Act 107 of 1998).

National Environmental Management: Air Quality Act (163 of 2004).

National Environmental Management: Biodiversity Act (10 of 2004).

National Environmental Management: Integrated Coastal Management Act.

National Environmental Management: Waste Act (November 2006).

National Forests Act (84 of 1998).

National Heritage Resource Act (25 of 1999).

National Water Act (Act 36 of 1998).

Coastal & Environmental Services 120 Great Kei Wind Energy Facility