INTERWASTE (Pty) Ltd.

Proposed Waste Recovery, Beneficiation and Energy Project, Erf 34, Wellington, Western Cape

DRAFT SCOPING REPORT

PREPARED FOR: INTERWASTE (PTY) Ltd

REPORT NO: RMS/D-WtE/DSR/10/14

DEA REFERENCE No.: 14/12/16/3/3/3/114

DATE: OCTOBER 2014

P O Box 4296 DURBANVILLE 7551

Tel: 021 975 7396 Fax: 021 975 1373 Cell: 082 444 2630 E-mail: [email protected] Website: www.rmsenviro.co.za

DRAFT SCOPING REPORT: INTERWASTE (Pty) Ltd - DWtE OCTOBER 2014

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... 6

1. INTRODUCTION ...... 17 1.1 Project Background ...... 17 1.2 Details of the Applicant, Independent EIA Practitioner and Competent Authority ...... 17 1.2.1 Details of the applicant ...... 17 1.2.2 Details of the Independent EIA Practitioner ...... 17 1.2.3 Details of the Competent Authority ...... 18

2. DESCRIPTION OF THE BASELINE ENVIRONMENT ...... 19 2.1 Site Locations ...... 19 2.1.1 Site Alternatives 1 and 2 (Erf 34)...... 19 2.1.2 Site Alternative 3 (Portion of Erf 736) ...... 20 2.2 Climate: Temperature, Rainfall and Wind ...... 22 2.3 Vegetation ...... 22 2.3.1 Site Alternatives 1 and 2 ...... 22 2.3.2 Site Alternative 3 ...... 22 2.4 Geology, Geohydrology and Hydrology ...... 23 2.4.1 Site Alternative 1 and 2 ...... 23 2.4.2 Site Alternative 3 ...... 23 2.5 BGIS Mapping Overview ...... 24 2.6 Cape Winelands Biosphere Reserve ...... 27 2.7 Socio-Economic...... 29

3. PLANNING AND LEGISLATIVE CONTEXT ...... 31 3.1 Legal Framework ...... 31 3.2 Policy and Planning Framework ...... 38 3.2.1 Western Cape Provincial Spatial Development Framework (PSDF) ...... 38 3.2.2 CWDM: Spatial Development Framework (SDF) (March 2011) ...... 38 3.2.3 CWDM: Integrated Development Plan (IDP) (2008/2009) ...... 39 3.2.4 CWDM: Draft Review Integrated Development Plan (IDP) (2014/2015) ...... 40 3.2.5 CWDM: Environmental Management Framework (EMF) (2011) ...... 40 3.2.6 CWDM Waste Recycling Plan (July 2010 Final) ...... 41 3.2.7 Drakenstein Revised IDP (2014/2015) ...... 41 3.2.8 Drakenstein Spatial Development Framework (Amended October 2010) ...... 41 3.2.9 Drakenstein Integrated Waste Management Plan (IWMP) (2009) ...... 42 3.2.10 Drakenstein Strategic Environmental Assessment (SEA) – Wellington Industrial Precinct ...... 42 3.2.11 Drakenstein Strategic Environmental Assessment (SEA) – Klapmuts North ...... 45 3.2.12 Drakenstein Environmental Management Framework ...... 46 3.2.13 Principles contained in Section 23 and Section 2 of NEMA ...... 46

4. PROJECT DESCRIPTION (PREFERRED ALTERNATIVE) ...... 49 4.1 Proposed Waste Recovery, Beneficiation and Energy Project ...... 49 4.1.1 The Preferred Location Alternative (Option 1) ...... 54 4.2 Listed activities ...... 58 4.2.1 National Environmental Management Act (Act No. 107 of 1998) ...... 58 4.2.2 National Environmental Management: Waste Act (Act No. 59 of 2008) ...... 59 4.2.3 National Environmental Management: Air Quality Act (Act No. 39 of 2004) ...... 59

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4.3 Need and Desirability ...... 60 4.3.1 Need (timing) ...... 60 4.3.2 Desirability (Place) ...... 62

5. PROJECT ALTERNATIVES ...... 64 5.1 Introduction ...... 64 5.2 Description of the Proposed Alternatives ...... 65 5.2.1 Location Alternatives ...... 65 5.2.2 No-Go Alternative ...... 68

6. SCOPING PROCESS AND METHODOLOGY ...... 69 6.1 Objectives of Scoping ...... 69 6.2 Content of scoping report ...... 70 6.3 Scoping Process ...... 71 6.3.1 Availability of Background Information Document ...... 71 6.3.2 Availability of Draft Scoping Report (DSR) ...... 71 6.3.3 Public and Authorities Meetings ...... 71 6.3.4 Availability of Final Scoping Report ...... 72 6.3.5 Submission of Final Scoping Report to DEA and DEADP ...... 72 6.3.6 Consideration of Final Scoping Report by DEA ...... 72 6.4 Public Participation Process ...... 74 6.5 Overview of the Scoping Process to date ...... 74

7. DESCRIPTION OF IDENTIFIED ISSUES AND IMPACTS ...... 75 7.1 Issues/ Impacts raised during scoping by I&AP’s ...... 75

8. CONCLUSIONS AND RECOMMENDATIONS ...... 75 8.1 Conclusions and Recommendations ...... 75

9. REFERENCES ...... 76

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LIST OF TABLES

Table 1: Soil Permeability’s ...... 23 Table 2: CBA map categories for Drakenstein and Stellenbosch...... 27 Table 3: Relevant Legislation and Guidelines ...... 31 Table 4: General objectives of IEM ...... 46 Table 5: Principles of Environmental Management ...... 47 Table 6: List of activities triggered in terms of the Listing Notices published under the National Environmental Management Act (Act No. 107 of 1998) ...... 58 Table 7: List of activities triggered in terms of the activities published under the National Environmental Management: Waste Act (Act No. 59 of 2008) ...... 59 Table 8: List of activities triggered in terms of the activities published under the National Environmental Management: Air Quality Act (Act No. 39 of 2004)...... 60 Table 9: Contents of Scoping Report ...... 70 Table 10: Overview of the Scoping Process to date ...... 74

LIST OF FIGURES

Figure 1: (showing site locations see folder Figures) ...... 20 Figure 2: Locality of Proposed Site Alternative 3 ...... 21 Figure 3: The area has been historically flattened and the vegetation modified...... 22 Figure 4: Terrestrial Biodiversity Map for the Drakenstein Municipality...... 25 Figure 5: BGIS Map of Critical Biodiversity Areas(CBA) within the Drakenstein & Stellenbosch Municipal areas...... 26 Figure 6: Cape Winelands Biosphere Reserve Map...... 28 Figure 7: Access to refuse removal 2011 ...... 30 Figure 8: Proposed Eco Corridor...... 43 Figure 9: Wellington Industrial Park - Site Development Plan (Spatial Point of Departure for a Precinct Plan for the Site)...... 44 Figure 10: Environmental Sensitivity Map...... 45 Figure 11: Materials Recovery Facility (MRF) and Waste Press Process Flow Diagram...... 51 Figure 12: Anaerobic Digestion Process Flow Diagram...... 53 Figure 13: The Preferred Site Location ...... 55 Figure 14: Schematic – 3 D View of Anaerobic Digestion and Direct Combustion Facility ...... 56 Figure 15: Schematic – 3 D View of Anaerobic Digestion and Direct Combustion Facility and link to Wellington Substation...... 57 Figure 16: Proposed Location of Site Alternative 2...... 65 Figure 17: Proposed Location of Site Alternative 3...... 67

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Figure 18: EIA Process Diagram...... 73

ANNEXURES

ANNEXURE A: PUBLIC PARTICIPATION REPORT ANNEXURE B: PLAN OF STUDY FOR EIA ANNEXURE C: AUTHORITY CORRESPONDENCE ANNEXURE D: MAPS OF PROPOSED WASTE MANAGEMENT FACILITY ANNEXURE E: PROJECT FEASIBILITY REPORT

ABBREVIATIONS DEA Department of Environmental Affairs DEA&DP Department of Environmental Affairs and Development Planning DSR Draft Scoping Report EIA Environmental Impact Assessment FSR Final Scoping Report NEMA National Environmental Management Act (Act No. 107 of 1998) NEM:WA National Environmental Management: Waste Act (Act No. 59 of 2008) RMS Resource Management Services

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EXECUTIVE SUMMARY i) Introduction Interwaste appointed Resource Management Services (“RMS”) to facilitate the Scoping/ Environmental Impact Assessment (EIA) process for the proposed Waste Recovery, Beneficiation and Energy Project.

In terms of the National Environmental Management Act (Act 107 of 1998, as amended), and the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008, as amended), Interwaste is required to apply to the National Department of Environmental Affairs for both an Environmental Authorisation and a Waste Management Licence to lawfully undertake the proposed project activities.

The Drakenstein Municipality (“DM”) is committed to significantly reducing the amount of waste going to landfill and aims to meet the objectives of the National Waste Management Strategy.

Due to this commitment, the DM has entered into a medium to long-term Public Private Partnership (“PPP”) agreement with Interwaste. The Interwaste PPP agreement includes the integrated management of the DM’s waste management operations, including the planning, designing, financing, construction and operation of a Waste to Energy Project. The contract also includes provision for the management, operation and maintenance of the existing municipal waste management facilities.

The two main objectives for the Waste to Energy project as necessitated by the DM contract are: . The generation of Renewable Energy from Municipal Solid Waste, . Reduction of Municipal Solid Waste to Landfill, and

The primary focus of the project is energy from waste, but it will also entail waste recovery and waste beneficiation activities. All other waste management activities are secondary focuses.

The overall waste management facility will consist of four main elements to be operated in series or as separate entities, namely: . Materials Recovery Facility (MRF) – clean or dirty . Municipal Solid Waste Pressing Plant . Anaerobic digestion (AD) plant . Direct Combustion (DC) plant

Materials Recovery Facility (MRF) It is proposed to construct a Materials Recovery Facility (MRF) as part of the project for the recovery of recyclables and separation of organic wastes. The proposed development of the MRF will take place in two phases, . phase one will consist of a facility with a capacity of less than 200 tonnes of waste per day and with a footprint of less than 1 000m2 . phase two will address the expansion of the MRF to process between 200 to 300 tonnes of waste per day and the expansion of the footprint will exceed 1000m2.

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MRF Phase One will take place in parallel with the EIA process.

A MRF is a plant that receives waste materials which are either separated at source (clean co-mingled waste) or mixed (“dirty” wastes). At the proposed plant, materials will be separated, processed and stored for later use as raw materials or for remanufacturing processes.

At the MRF the recyclable materials will be sorted to specifications/grade, baled, shredded, crushed, and/or otherwise prepared for transport to market. It is intended that the organic waste separated from the recyclables be utilized for the anaerobic digestion (“AD”) plant.

The Wellington MRF will be designed to handle 200 to 300 tonnes of waste per day, which equates to a throughput of 5 to 11 tonnes per hour. Waste will be primarily sourced from the Drakenstein Municipal area

The facility will operate from 08h00 to 17h00 on a two shift system (08h00 -16h00 and 09h00 -17h00). The facility therefore has a maximum throughput capacity of 75,600 tonnes per year.

Pressing Plant Subsequent to the recovery of recyclable materials from the municipal waste stream, a waste pressing technology will be utilized to separate the organic fraction from the remaining, unrecyclable fraction of the Municipal Solid Waste (“MSW”) stream. The organic fraction will be used as feedstock in the proposed Anaerobic Digestion plant.

The proposed press is designed to physically, at high pressure, separate the largely unrecyclable waste fraction into two fractions, i) an organic wet fraction and ii) a solid dry fraction. The separation process consists of a chamber with a very strong mesh, against which waste is compressed using high pressure of up to 1000Bar. This results in changing the structure of the organic material into fluid plasma, allowing it to be pressed through the mesh. This wet organic fraction will be recovered in the anaerobic digestion plants to generate biogas. The dry non-organic fraction contains mainly refuse derived fuel (“RDF”), but also some residue minerals and metals. After the dry fraction has undergone an additional separation process by sorting out these metals, only RDF and recyclables remain. The recyclables will join the materials recovered at the MRF and be sold to market.

The waste handling capacity of the pressing plant is 450 ton/day MSW and the output streams will supplement the proposed Anaerobic Digestion Plant (organic fraction) and Direct Combustion Plant (refuse derived fuel) as well as creating a potential revenue stream from sales of recyclables.

Anaerobic digestion plant Anaerobic digestion is a biological process in which microorganisms break down biodegradable material through a series of processes in the absence of oxygen. The process is widely used in industry to treat wastewater and as part of an integrated waste management system. Anaerobic digestion as a process whereby a renewable energy source can be generated as it produces a methane rich biogas which can be used as fossil fuel replacement for energy production.

The Anaerobic digestion plant will utilize the organic fraction of the MSW diverted in the separation plant (MRF & pressing unit) as well as alternative organic waste streams such as winery waste, condemned food, etc., that is compatible. In addition 220 m³ per day of sewage sludge from the Paarl waste water treatment works will be utilized for dilution in the AD facility. In total the AD plant will have a capacity to process 194 t/d of organic waste and will produce an anticipated 2.5 MW (gross) of electricity.

The digestate left over at the end of the AD process will be used as a feedstock for the Direct Combustion process.

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Direct Combustion plant Direct Combustion was chosen as the preferred management option for the waste fraction that will not be used as feedstock for the Anaerobic Digestion (AD) Facility or waste materials recovered or landfilled. A direct combustion (DC) system burns the biomass to generate hot flue gas, which is either used directly to provide heat, or fed into a boiler to generate steam.

In a boiler system, the steam can be used to provide heat for industrial processes, or space heating and a steam turbine can be used to generate electricity.

The feedstocks to be used in the direct combustion plant are the following: . dry fraction and unrecyclable material from the separation plant including RDF; . Digestate, as a waste stream from the Anaerobic Digestion process; and . Non-biodegradable Municipal Solid Waste (MSW).

The Direct Combustion plant will have a capacity to process 300t/d of biomass and will produce an anticipated 10 MW (gross) of electricity.

At a later stage MSW from the landfill may also be mined and utilised as a feedstock. This will, however, only take place in purpose built cells that will be utilised after Interwaste has taken over management of the Wellington landfill site. None of the historic landfill will be mined at this stage.

The waste stream generated from the DC will be inert ash and will be disposed of at the landfill site or used in the brick making process.

The total amount of MSW to be accepted at the waste management facility is 430 ton/day waste; of which 194 ton/day will be organic waste to be utilized in the AD plant. In addition the DC plant will accept 300 ton/day of waste but this will consist of 114 ton/day of digestate from the AD, as well as the 120 ton/day inorganic waste material (refuse derived fuel) from the separation plant.

It is also important to note that in order to ensure maximum diversion of waste from the landfill, it is necessary to import waste from adjacent municipalities or sources to warrant the establishment of the AD and DC plants. There is therefore an economy of scale that can be achieved by bringing in the additional amount of waste.

The two of the main objectives for the Waste to Energy project as necessitated by the DM contract are: . The generation of Renewable Energy from Municipal Solid Waste, and . Reduction of Municipal Solid Waste to Landfill. ii) The Preferred Location Alternative (Option 1) The Preferred Location, Portion of Erf 34 is located adjacent to the existing Wellington landfill site which is situated off the R44 to the west of Wellington, approximately 800m from the turn-off from the R44. Refer to Figure i.

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Figure i: Proposed Locality of Site Alternative 1 (Preferred site)

The Drakenstein & Stellenbosch Critical Biodiversity Areas (CBA) Map classifies an area in the centre and northern edge of the proposed site as a Critical Biodiversity Area. The site has however been highly degraded and little to no vegetation remains. A vegetation constraints assessment will be undertaken to identify a suitable footprint area for the proposed facility and to investigate whether any further studies are required. The site has been historically levelled and has been utilised for illegal dumping in the past. iii) Listed activities National Environmental Management Act (Act No. 107 of 1998) The following activities have been identified in Listing Notice 1 and Listing Notice 21 of the activities published under Sections 24(2) and 24D of the National Environmental Management Act, 1998 (Act No. 107 of 1998).

1 Environmental Impact Assessment Regulations Listing Notice 2 of 2010

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Table i: List of activities triggered in terms of the Listing Notices published under the National Environmental Management Act (Act No. 107 of 1998)

GN. R544 Activity Activities as per Listing Notice 1 (subject to Basic Assessment) No(s) The construction of facilities or infrastructure for the generation of electricity where: 1 (i) the electricity output is more than 10 megawatts but less than 20 megawatts (mw); or (ii) the output is 10 MW or less but the total extent of the facility covers an area in excess of 1 hectare. The construction of facilities or infrastructure exceeding 1000 meters in length for the bulk transportation of water, sewage or storm water – (i) with an internal diameter of 0.36 meters or more or; (ii) with a peak throughput of 120 litres per second or more, excluding where: 9 a. such facilities or infrastructure are for bulk transportation of water, sewage or storm water drainage inside a road reserve; or b. where such construction will occur within urban areas but further than 32 meters from a watercourse, measured from the edge of the watercourse. The construction of facilities or infrastructure for the transmission and distribution of electricity – (i) outside urban areas or industrial complexes with a capacity of more than 33 but less than 275 10 kilovolts. (ii) inside urban areas or industrial complexes with a capacity of 275 kilovolts or more. The transformation of undeveloped, vacant or derelict land to – (ii) residential, retail, commercial, recreational, industrial or institutional use, outside an urban area and where the total area to be transformed is bigger than 1 hectare but less than 20 hectares; - 23 Except where such transformation takes place – (i) for linear activities; or (ii) for purposes of agriculture or afforestation, in which case Activity 16 of Notice No. R. 545 applies. GN. R545 Activity Activities as per Listing Notice 2 (subject to Scoping and Environmental Impact Reporting No(s) (S&EIR)) The construction of a facilities or infrastructure for the storage, or storage and handling of a dangerous 3 good, where such storage occurs with a combined capacity of more than 500 cubic meters. The construction of facilities or infrastructure for any process or activity which requires a permit or licence in terms of national or provincial legislation governing the generation or release of emissions, 5 pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply. Commencing of an activity, which requires an atmospheric emission licence in terms of section 21 of 26 the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), except where such commencement requires basic assessment in terms of Notice No. R544 of 2010.

Activities as per Listing Notice 2 as per NEMA (table above) require that an environmental impact assessment process, as stipulated in the environmental impact assessment regulations made under section 24(5) of the National Environmental Management Act, 1998 (Act No. 107 of 1998) must be undertaken.

An Environmental Authorisation must be issued by the Department of Environmental Affairs (DEA) for the undertaking of the activities mentioned above.

National Environmental Management: Waste Act (Act No. 59 of 2008) The following activities have been identified in Category A and Category B of “The list of waste management activities that have, or are likely to have a detrimental effect on the environment” published under Section 19(1) of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) on 03 July 2009 and amended on 29 November 2013:

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Table ii: List of activities triggered in terms of the activities published under the National Environmental Management: Waste Act (Act No. 59 of 2008)

Government Notice No. 32368 Category A Waste Management Activities Activity No(s): The sorting, shredding, grinding, crushing, screening or bailing of general waste at a facility 2 that has an operational area in excess of 1000m2. The construction of a facility for a management activity listed in Category A of this Schedule 12 (not in isolation to associated waste management activity), Government Notice No. 32368, Category B Waste Management Activities Activity No(s): The recovery of waste including the refining, utilization or co-processing of the waste at a facility that processes in excess of 100 tons of general waste per day or in excess of 1 ton of 3 hazardous waste per day, excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises. The treatment of hazardous waste in excess of 1 ton per day calculated as a monthly 4 average; using any form of treatment excluding the treatment of effluent, wastewater or sewage. The treatment of general waste in excess of 100 tons per day calculated as a monthly 6 average, using any for of treatment. The construction of facility for a waste management activity listed in Category B of this 10 Schedule (not in isolation to associated waste management activity),

Category B Waste Management Activities require that an environmental impact assessment process, as stipulated in the environmental impact assessment regulations made under section 24(5) of the National Environmental Management Act, 1998 (Act No. 107 of 1998) must be undertaken as part of a waste management licence application. A Waste Licence must be issued by the National Department of Environmental Affairs (DEA) for the undertaking of the activities mentioned above.

Due to the fact that a Waste Management Licence involves hazardous waste management activities and an Environmental Authorisation is needed for a power generation activity, it is necessary that the application follows an integrated approach; where the DEA will issue a single Integrated Environmental Authorisation for the project.

National Environmental Management: Air Quality Act (Act No. 39 of 2004) The following activities have been identified in the list of the activities2 published under Section 21(1)(a) of the National Environmental Management: Air Quality Act (Act No. 39 of 2004).

Table iii: List of activities triggered in terms of the activities published under the National Environmental Management: Air Quality Act (Act No. 39 of 2004).

Government Notice No. 248 Activities Activity No(s): Category 1: Combustion (Subcategory 1.6: Waste Co feeding Combustion Installations) Applicable to combustion Installations facilities. Category 8: Thermal Facilities where general and hazardous waste are treated by the application of heat. Treatment of Hazardous and Applicable to all installations treating 10 Kg per day of waste. General Waste Processes for the rendering cooking, drying, dehydrating, digesting, evaporating or protein 19. Category 10: Animal concentrating of any animal matter not intended for human consumption. matter processing Application: All installations handling more than 1 ton or raw materials per day

2 List of activities which result in atmospheric emissions which have or may have a significant detrimental effect on the environment, including health, social conditions, economic conditions, ecological conditions or cultural heritage (Government Notice No. 248).

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(a) The following special agreement shall apply: (i) Best practice measures intended to minimise or avoid offensive odours must be implemented by all installations. These measures must be documented to the satisfaction of the Licencing Authority.

In terms of the National Environmental Management: Air Quality Act (Act No. 39 of 2004), it is expected that the applicant Interwaste will need to apply to the Cape Winelands District Municipality (CWDM) for an Atmospheric Emissions Licence (AEL) for the project. Refer to Table 6 above. iv) Location Alternatives – Alternative 2 and 3

Alternative 2

The proposed location of Alternative 2 is shown in Figure ii below.

Figure ii: Proposed Locality of Site Alternative 2, showing Eco Corridor.

The facility would be located in the North eastern corner of Erf 34, where the current Drakenstein Municipality green waste and builders rubble facilities are located, with the DM WWTW located to the west, the Wellington landfill site to the south, the DM recycling facility and industrial properties to the east and the Proposed Eco- corridor for the Wellington Industrial Park to the south.

The southern border of the site is classified as a CBA and an Eco-corridor has been proposed for the natural area within the Wellington Industrial Park. The proposed Eco-corridor Wellington Industrial Park that borders the site contains wetlands and the border of the site will be within 100m of these features.

The site is currently utilised for green waste chipping and building rubble crushing and may need some preparation works before construction can commence. The Drakenstein Municipality will have to relocate the existing chipping & crushing facilities (most likely to Location Alternative 1).

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Alternatives 1 and 2 formed part of a Strategic Environmental Assessment (SEA) conducted by Worley Parsons. The SEA included a number of specialist assessments. The environmental sensitivity map is included as part of Figure ii above.

Alternative 3 The proposed location areas, referred to as Alternative 3a,b,c are shown in Figure iii and Figure iv below. The facility could be located in the far northern corner of the property adjacent to the old Klapmuts waste disposal site to the East and in close proximity to the previously authorised Biocircle Composting Facility (now owned and managed by MD&P (Pty) Ltd) also located to the East. The alternative two areas on Erf 736 could be on either side of the gravel road that divides Erf 736. Klapmuts residential area would be situated to the South, private agricultural property is located to the North and West.

The property Erf 736 formed part of the area which was included in the comprehensive Strategic Environmental Assessment (SEA) process which commenced in 2013 and is still ongoing due to the fact that the Drakenstein Municipality have not made any decisions as to the preferred use/s of Erf 736.

Figure iii: Proposed Locality of areas for Site Alternative 3a,b,c. final site localities still to be included

The SEA completed to date has included a number of specialist studies. An environmental sensitivity map is included as Figure iv below.

The Preferred Location Alternative is Alternative 1.

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Figure iv: Environmental Sensitivity Map showing proposed location areas for Site Alternative 3 v) No-Go Alternative The No-Go Alternative is the option of not implementing the activities and will result in the status quo being maintained.

The No-Go Alternative is presently not considered feasible since no beneficiation of organic waste will take place, no minimisation of waste disposed of to landfill and no “green” energy production will take place. Waste management practises will continue as is and the Wellington waste disposal site will reach its useful life in the 2016/2017 financial year. The site will then need to be rehabilitated and closed. Waste will then have to be transported to the City of Cape Town’s waste disposal site and to cover these transport and disposal costs refuse removal tariffs will have to increase by 41.3% and 30.5% in the 2016/2017 and 2017/2018 financial years. This won’t be sustainable over the long-term.

In addition the opportunity to reuse a fuel source (methane from anaerobic digestion and heat from combustion of waste) would be lost.

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vi) Public Participation Process The Public Participation Process to date is documented in Annexure A to the Draft Scoping Report (DSR). Key activities are tabulated below:

Table iv: Summary of activities undertaken during public consultation Activity Date Submit Application to DEA 4 July 2014 Acknowledgement of Receipt of Application (DEA) 1 August 2014 Advertising the availability of a Background Information Document (BID) and 21-day I&AP Thursday 7 August 2014 – registration & commenting period in one (1) local newspaper (PaarlPost) and one (1) regional Friday 29 August 2014 newspaper (Die Burger) Advertising the availability of a Draft Scoping Report (DSR), Public Open Day and 40-day I&AP registration & commenting period in one (1) local newspaper (PaarlPost) and one (1) Thursday 30 October 2014 regional newspaper (Die Burger) Notification via registered and electronic mail to neighbouring landowners and stakeholders Wednesday 29 October 2014 on preliminary stakeholder database Placement of reports in Paarl Public Library. Posters placed at the entrance to the respective Friday 31 October 2014 sites. 40-day review and comment period on Draft Scoping Report Monday 3 November 2014 – Friday 12 December 2014 Final Scoping Report submitted to DEA January 2015 vii) Issues/ Impacts raised during scoping by I&AP’s The potential significant impacts which have been identified by the EAP, applicant, I&AP’s (to date) and which need to be assessed in the EIR Phase as part of the specialist or engineering assessment include: • Botanical impact relating to the removal of natural vegetation for the construction of the integrated waste management (IWMF) facility; • Potential Noise impact of the IWMF facility on surrounding areas; • Suitability and availability of on-site services • Potential Health Risks associated with the operation of the proposed waste management facility; • Socio-Economic Impacts that may result from the construction and operational phases of the proposed facility – the emphasis being on the social impact; • Potential Visual Impact of the proposed facility on surrounding areas; • Potential Air Quality Impacts especially emissions, odour and dust; • Potential Traffic Impact on the surrounding road network due to the increase in the number of vehicles entering and exiting the site and or alternative site area; • The proposed site may have resources of heritage or archaeological value and ; • Potential water quality and biodiversity impacts.

The Strategic Environmental Assessments (SEA) completed for those areas (Wellington Industrial Precinct and Klapmuts North) within which all three (3) alternatives are located provided valuable insight into potential environmentally sensitivity issues.

The specialist studies to be undertaken during the impact assessment phase are required to recommend suitable mitigation measures for the issues identified above.

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viii) Conclusions and Recommendations The following specialist studies have been identified (based on the issues/ impacts identified above) and will commence during the impact assessment phase. • Botanical – Freshwater Constraints Assessment; • Noise Impact Assessment; • Health Risk Assessment; • Socio-Economic Impact Assessment; • Visual Impact Assessment; • Air Quality Impact Assessment (including odour and dust); • Traffic Impact Statement – Impact Assessment; • Archaeological and Heritage investigation; and a • Major Hazardous Installation investigation.

Specialist Studies will need to take into account the immediate and long term significance, geographic extent, duration, permanency of the impacts that are being assessed. The Plan of Study (PoS) for EIA is attached as Annexure B.

In addition to the above specialist studies listed above the completion of a detailed Engineering Services Report will be important.

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1. INTRODUCTION

1.1 Project Background Interwaste appointed Resource Management Services (“RMS”) to facilitate the Scoping/ Environmental Impact Assessment (EIA) process for the proposed Waste Recovery, Beneficiation and Energy Project.

In terms of the National Environmental Management Act (Act 107 of 1998, as amended), and the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008, as amended), Interwaste is required to apply to the National Department of Environmental Affairs for both an Environmental Authorisation and a Waste Management Licence to lawfully undertake the proposed project activities.

1.2 Details of the Applicant, Independent EIA Practitioner and Competent Authority 1.2.1 Details of the applicant Applicant: Interwaste (Pty) Ltd Contact: Leon Grobbelaar Address: 2 Brammer Road, Industries East, Germiston South, 1401 Tel: +27 (0)11 323 7300 Fax: +27 (0)86 504 4345 E-mail: [email protected]

1.2.2 Details of the Independent EIA Practitioner Resource Management Services (www.rmsenviro.co.za) has been appointed as the Independent Environmental Assessment Practitioner (EAP) and has adequate experience within the required environmental impact assessment field to facilitate the required Scoping and EIA Process in a professional manner. The persons from RMS that are involved in the project include:

Larry Eichstadt - Project Management and Review Larry Eichstadt is an environmental scientist with 20 years experience in the environmental management field. He holds a BSc Honours degree in Biochemistry and Zoology from the University of Port Elizabeth and has worked for the following companies: Coopers Animal Health in East London; Department of Water Affairs and Forestry (Eastern Cape and Western Cape offices) and Ingerop Africa. His professional affiliations include the International Association for Impact Assessment (South Africa) (IAIAsa) and the Institute of Waste Management South Africa (IWMSA).

During the course of his career, Larry has been exposed to environmental projects within the urban development, water resource management, waste management and mining fields. He has worked with many professionals (consulting and industry) both nationally and internationally and has gained broad experience in the environmental field.

Nelia Maritz - Report Writing Nelia Maritz has been working as an Environmental Practitioner for 10 years during which time she has managed projects ranging in size and scope from small BAs to large-scale EIAs in various provinces and on Provincial and National level. Nelia provides project coordination, compilation of Environmental Scoping Reports and Environmental Impact Assessments, co-ordination of the public participation process, conducting Feasibility Studies and Status Quo Assessments and compiling Environmental Management Programme Reports. She is registered with the South African Council for Natural Scientific Professions. Her qualifications include an M. Phil in Environmental Management, University of Stellenbosch, Hon. BSc in African Vertebrate Biodiversity Studies, Rhodes University and B Sc in Genetics, University of Stellenbosch.

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Specialists Specialists with the exception of Tony Barbour (Social Specialist) are still to be appointed. Refer to the Plan of Study for EIA (Annexure B) for the proposed specialist’s Terms of Reference (ToR).

1.2.3 Details of the Competent Authority Due to the fact that a Waste Management Licence involves hazardous waste management activities and an Environmental Authorisation is needed for a power generation activity, it is necessary that the application follows an integrated approach; where the DEA will issue a single Integrated Environmental Authorisation for the project.

Department of Environmental Affairs: Directorate Integrated Licensing

Contact person/s: Ms Mmatlala Rabothata Address: Private Bag x447 Pretoria 0001 Tel: 012 395 1768 Fax: 012 320 7539 Email: [email protected]

The primary commenting authorities would include:

Provincial and National Departments: • DEA&DP, Directorate: Pollution Management; • DEA&DP, Directorate: Waste Management; • DEA&DP, Directorate: Land Management; • Department of Water Affairs; • Cape Nature • Heritage Western Cape • Energy? • Department of Health; and • Provincial and District Roads Department. • Cape Winelands District Municipality

Local Municipality – Drakenstein Municipality: • Environmental Resource Management • Engineering Services • Town Planning • Ward Councilor;

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2. DESCRIPTION OF THE BASELINE ENVIRONMENT

2.1 Site Locations

2.1.1 Site Alternatives 1 and 2 (Erf 34) The two (2) proposed alternatives are located adjacent to the existing Wellington landfill site which is situated off the R44 to the west of Wellington, approximately 800m from the turn-off from the R44. The Wellington Golf course is located immediately to the east of the preferred site. The GPS coordinates are S 33o 39’ 13.4”, E18o 59’ 03.5”. (Refer to Figure 1, below). Site alternative 2 is located to the North of the Wellington landfill site.

Current activities on site The preferred area for the proposed facility is currently lying fallow and is not being utilized for any specific purpose. The area has historically been flattened and the vegetation has largely been removed. Some illegal dumping takes place on the site and it is cleaned periodically by the municipality. Site alternative 2 is currently being used for green waste chipping and building rubble disposal and crushing.

Surrounding land use With reference to the preferred alternative the proposed Integrated Waste Management Facility (IWMF) will be located in the North western corner of Erf 34. West of the access road leading from the R44 to the entrance of the Wellington Landfill site, east of the Wellington Golf course and bordering the Wellington landfill site to the south.

The existing Wellington landfill site operates along Champagne Street in the Wellington area east of the R44. The nearest residential areas are Mbekweni and Newton, which are located approximately >1 km east of the site. It is also located approximately >3 km from the Berg River.

The preferred site is also located within the proximity of the Wellington Industrial Park (Light Industrial). Based on one of the outcomes of the Wellington Industrial Precinct SEA completed, the Drakenstein Municipality has proposed an eco corridor within the industrial area (Figure 1). Residential areas are located East of the golf course and an existing rail network borders the residential area.

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Figure 1: Proposed Site Locality Alternative 1 (preferred) and 2

2.1.2 Site Alternative 3 (Portion of Erf 736) Erf 736 is located West of the R44 gravel road and immediately North of the N1 National Road. The proposed waste management facility could either be located in the far northern corner of the property adjacent to the old Klapmuts waste disposal site to the East and in close proximity to the previously authorised Biocircle Composting Facility (now owned and managed by MD&P (Pty) Ltd) also located to the East or on either side of the gravel road that bisects Erf 736. The remainder of Erf 736, Klapmuts would be situated to the South, private agricultural property is located to the North and West.

Current Activities The property is not being used for any specific purposes hence the need for the SEA conducted to propose potential future uses of the property.

Surrounding Land Use The surrounding land use is predominantly of an agricultural nature with small holdings bordering certain areas of the proposed site areas. County Fair has chicken hatcheries located further to the West of the proposed site alternative areas. The distance from the County fair operations exceeds 1000m.

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Figure 2: Locality of Proposed Areas for Site Alternative 3

Figure 3: Locality of Proposed Areas on Environmental Sensitivity Map for Site Alternative 3

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2.2 Climate: Temperature, Rainfall and Wind Climatic conditions within the Drakenstein Municipality are described as typically Mediterranean (cool, wet winters and warm, dry summers), and is known for its hot summer days. The average annual rainfall is approximately 700 mm, with the southern portion receiving more than the northern portion. The evaporation rate is high, approximately 1900 mm per annum, which is more than double the rainfall in this area.

During summer, autumn and spring a southerly wind predominates with stronger southerly winds occurring during summer. During spring and autumn a northerly breeze also occurs but infrequently, while in winter a northerly breeze predominates. The temperatures range from a maximum of 32°C in January and February to a minimum of 7°C typically in July, with the average temperatures ranging from approximately 25°C in summer to approximately 11°C in winter.

2.3 Vegetation 2.3.1 Site Alternatives 1 and 2 Historically, the area was covered by Swartland Alluvium Fynbos, which is now considered to be a critically endangered vegetation type. However, the site is largely degraded and transformed. Some illegal dumping takes place on the proposed site.

Figure 4: The area has been historically flattened and the vegetation modified.

2.3.2 Site Alternative 3

a b

Figure 5 (a): Southern View of Erf 736 from gravel road (XX) and (b) Northern view of Erf 736 from gravel road (XX).

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2.4 Geology, Geohydrology and Hydrology

2.4.1 Site Alternative 1 and 2 Based on the Groundwater Consulting Services report titled “Hydrogeological Investigation of the Proposed Extension to the Existing Site” (February 1998) prepared by Jeff Jolly - the following important background information pertaining to the immediate vicinity of the preferred site alternative (adjacent to the current Wellington Landfill site) was obtained:

The site is underlain initially by Quaternary age river sands and gravels, in turn underlain by phyllite, greywacke and schists of the Moorreesburg Formation (Malmesbury Group). The proposed site is located in an area where numerous other sources of potential groundwater contamination exist and groundwater use is unlikely, not only because of the contamination threats, but also because of the low groundwater potential. The site is underlain by clays which form a barrier to vertical seepage.

The typical surface and near surface geology of the area consists of a thin surface soil horizon (less than 0.25 metres thick), underlain by alluvial gravels 90.5 – 2.5 m in thickness) in turn underlain by clays down to a depth of at least 3m. The clays are divided into two horizons – the lower horizon being laminated, suggesting that they are the product of weathering of the Malmesbury Group rocks.

In order to assess the barrier potential of the near surface geology, permeability was calculated for the two most important horizons identified - namely the gravels and the underlying clays. Soil samples were taken and analysed for grain size variation. The results of the soil samples analyses and the permeability tests are contained in Table 1 below. The permeability calculations show that the gravels underlying the site are highly permeable, while the underlying clays are far more impermeable.

Table 1: Soil Permeability’s

The Malmesbury Group rocks are not known to have high groundwater potential. There is no groundwater use within a 1 km radius of the existing Wellington waste site, although to a large degree this may be more related to the availability of surface water which has probably limited the amount of geohydrological exploration which has taken place in the past.

The groundwater located in the area showed signs of contamination which appears to be related to the historical sludge disposal ponds. It is however unlikely that strategic groundwater resources would be contaminated by the activities which form part of the overall waste recovery and treatment facility.

2.4.2 Site Alternative 3 Klapmuts is situated in the low relief hills of the Cape Winelands, about 7 km northwest of Simonsberg. Quaternary alluvium and gravelly soils underlie the settlement, which in turn cover granites (Stellenbosch Pluton) of the Cape Granite Suite. A NW-SE orientated normal fault, just south of Klapmuts, downfaults a small portion of the sedimentary Klipheuwel Group against the Cape Granite Suite.

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Groundwater from the intergranular and fractured regolith basement and Quaternary alluvial aquifers is currently used by a number of farms in the immediate region surrounding Klapmuts. Yields (based on available data from the NGDB) are in the range of 0.5 - 2 l/s. Higher yielding boreholes (~ 2 - 5 l/s) may be intersected along the faulted contact zone between the Klipheuwel Group and Cape Granite Suite. This is a result of the fault being connected to a higher recharge zone at Simonsberg, the conglomeratic nature of the Klipheuwel Group in the area, and the increased fractured nature of the rock in the vicinity of the fault.

2.5 BGIS Mapping Overview Approximately 60.9 % of the Drakenstein Municipality is comprised of areas where there is no natural vegetation remaining, the proposed alternatives sites fall within these particular regions (see Figures 6&7 below). Critically endangered and vulnerable plant species exist within the vegetated areas. Please take note of Figures 1 and 3 above which reflect the environmental sensitivity mapping provided for the different site alternatives.

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Figure 6: Terrestrial Biodiversity Map for the Drakenstein Municipality.

Please refer to Figure 7 for BGIS map of the site.

25 The general soil description for the preferred site area reveals that the area has a marked clay layer which is associated with slow water infiltration. Historically the area was covered with Swartland Alluvium Fynbos and according to the NSBA (National Spatial Biodiversity Assessment) ecosystem status the ecosystem is classified as critically endangered and has been poorly protected. The Drakenstein & Stellenbosch Critical Biodiversity Areas (CBA) Map classifies an area in the centre and northern edge of the proposed site as a Critical Biodiversity Areas. The site has however been highly degraded and little to no vegetation remains. A vegetation constraints assessment will be undertaken to identify a suitable footprint area for the proposed facility and to investigate whether any further studies are required.

Figure 7: BGIS Map of Critical Biodiversity Areas(CBA) within the Drakenstein & Stellenbosch Municipal areas. Table 2: CBA map categories for Drakenstein and Stellenbosch. CBA map category Desired management objective

Protected Areas Maintain natural land. Rehabilitate degraded to natural or near Critical Biodiversity Areas natural. (CBAs) Manage for no further degradation. Including and aquatic features,

and any buffer required to protect the feature)

Protected Areas

Ecological Support Areas (ESAs) Maintain ecological processes.

Including feature and any buffer required to protect the feature.

In certain areas, Critical Ecological Support Areas (CESA) are differentiated from ESA

Other Natural Areas Sustainable development and management within general rural land- No Natural Areas use principles. Favoured areas for development.

2.6 Cape Winelands Biosphere Reserve The Cape Winelands Biosphere Reserve was established and proclaimed by the United Nations Educational, Scientific and Cultural Organisation (UNESCO) in 2007. The Biosphere Reserve extends from the Kogelberg Biosphere Reserve in the south, northwards along the Cape Fold Belt Mountain Chain and adjoining valleys constituting the Cape Winelands (see Figure 8). The reserve includes both private and municipal owned land. The aims of the reserve are to promote conservation and sustainable development within the area through the identification of 3 different “management areas” • Core area: provides for the conservation of biodiversity, monitoring of ecosystems, and non-disruptive, non-consumptive land uses • Buffer area: identifies as “soft boundaries” and mostly includes privately-owned land • Transition area: identified as a flexible area to accommodate consumptive and disruptive activities, such as agriculture, settlement development, etc.

The proposed site alternatives do not fall within the Cape Winelands Biosphere Reserve. Although the sites fall within the demarcated reserve area, the area is categorised as a “main local town”, which will allow for the establishment of waste management facilities within this area.

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Figure 8: Cape Winelands Biosphere Reserve Map.

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2.7 Socio-Economic Drakenstein Municipality has the largest population of all the municipalities in the Cape Winelands District Municipal (CWDM) Area. The population of the Drakenstein Local Municipality (DLM) is dispersed across urban and agricultural areas: . 44.59 % of DLM’s population resides in Paarl . 22.10 % of DLM’s population resides in Wellington . 14.72 % of DLM’s population resides in Drakenstein NU . 12.29 % of DLM’s population resides in Mbekweni . 3.12 % of DLM’s population resides in Saron . 1.37 % of DLM’s population resides in Gouda . 1.13 % of DLM’s population resides in Victor Vester . 0.33 % of DLM’s population resides in Onverwacht . 0.19 % of DLM’s population resides in Water-Vliet . 0.12 % of DLM’s population resides in Val De Vie . 0.03 % of DLM’s population resides in Diemersfontein

The Regional Development Profile of 2012 highlighted Drakenstein as the most populous municipality within the Cape Winelands region. The population of Drakenstein grew from 194,413 in 2001 to 251,262 in 2011. The number of people in Drakenstein Municipal Area has increased from 194,418 in 2001 to 251,262 in 2011; it grew with an extra 59,844 people for the 2011 census. Coloured people represent the largest population group by 157,030, with the second largest being Black African Population by 56,960 followed by the White group of 33,939 and thereafter the Indians/Asian group of 997. Census 2011 highlighted that the Population of Drakenstein Municipality has increased across all race groups.

Drakenstein Municipality is a Category B Municipality – comprising Paarl, Wellington, Saron, Gouda, and Hermon, in the Cape Winelands District. The Regional Development Profile of 2012 highlighted that Drakenstein is the most populous municipality in the Cape Winelands District. The population in Drakenstein grew from 194,413 in 2001 to 251,262 in 2011. It is the economic centre of the region, with a strong manufacturing and business services base and has recorded positive growth over the period 2001 to 2009.

According Census 2011, Drakenstein Local Municipality has a total population of 251,262, of which 22, 7% are black African, 62, 5% are coloured people, 13, 5% are white people, with the other population groups making up the remaining 0, 4%.Of those aged 20 years and older, 6, 5% have completed primary school, 37, 7% have some secondary education, 27, 9% have completed matric and 11, 9% have some form of higher education. 3, 3% of those aged 20 years and older have no form of schooling.

Access to Refuse Removal The number of households with access to refuse removal increased from 36,671 (2001) to 53,151 (2011). The number of households with no rubbish disposal decreased from 782 (2001) to 614 (2011). More households within the Drakenstein Municipal boundaries have access to refuse removal.

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Figure 9: Access to refuse removal 2011

30 3. PLANNING AND LEGISLATIVE CONTEXT

3.1 Legal Framework The legislation and guidelines that need to be considered in this application, together with the authorities that will play a key regulatory role in the respective authorisation processes are listed in Table 3.

Table 3: Relevant Legislation and Guidelines Legislation/ Guideline Primary Function Applicability Responsible Authority Constitution of South Africa Chapter 2 of the Constitution is the Bill of Rights. The Bill of Rights is a 24. Environment - Everyone has the cornerstone of democracy in South Africa. It enshrines the rights of all people in right – our country and affirms the democratic values of human dignity, equality and (a) to an environment that is not freedom. 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. National Environmental To reform the law regulating waste management in order to protect health and the The proposed development application Department of Environmental Affairs Management: Waste Act (Act environment by providing reasonable measures for the prevention of pollution and triggers waste management activities (DEA) No. 59 of 2008). ecological degradation and for securing ecologically sustainable development; to which require a licence in terms of the provide for institutional arrangements and planning matters; to provide for national Act. Chapter 5 of the Act deals with the norms and standards for regulating the management of waste by all spheres of Licensing of Waste Management government; to provide for specific waste management measures; to provide for Activities. the licensing and control of waste management activities; to provide for the remediation of contaminated land; to provide for the national waste information system; to provide for compliance and enforcement; and to provide for matters connected therewith. DRAFT SCOPING REPORT: INTERWASTE (Pty) Ltd OCTOBER 2014

Legislation/ Guideline Primary Function Applicability Responsible Authority National Environment The purpose of this Act is to provide for co-operative, environmental governance A Scoping & EIR process must be Department of Environment Affairs & Management Act, 1998 (Act No. by establishing principles for decision-making on matters affecting the undertaken since Listing Notice 2 Development Planning (DEA&DP) 107 of 1998) environment, institutions that will promote co-operative governance and activities are triggered. Refer to Table procedures for coordinating environmental functions exercised by organs of state; 2. and to provide for matters connected therewith. The proposed development application triggers activities which require an environmental authorisation in terms of the Act.

Chapter 5, Section 24 of the Act deals with Environmental Authorisations. NEMA EIA Regulations, 2010 The purpose of these Regulations is to regulate the procedure and criteria as Due to the listed activities falling within Department of Environmental Affairs contemplated in Chapter 5 of the Act relating to the submission, processing and the scope of Category B (NEM:WA) consideration of, and decision on, applications for environmental authorisations and Listing 2 (NEMA), the for the commencement of activities in order to avoid detrimental impacts on the investigation, assessment and environment, or where it can not be avoided, ensure mitigation and management communication of the potential impact of impacts to acceptable levels, and to optimise positive environmental impacts, of activities associated with the and for matters pertaining thereto. proposed development must follow the scoping and environmental impact reporting (S&EIR) as prescribed in regulations 26 - 35 of the Environmental Impact Assessment Regulations 2010, published in terms of NEMA. National Health Act (Act No. 61 This Act provides a framework for a structure uniform health system within the Sewage waste is included as part of Department of Health of 2003) Republic, taking into account the obligations imposed by the Constitution and the waste streams to be processed. other laws on the national, provincial and local governments with regard to health services; and to provide for matters connected therewith. Occupational Health and Safety To provide for the health and safety of persons at work and for the health and All activities on site to comply with the Department of Labour Act 1993 (Act No. 85 of 1993) safety of persons in connection with the use of plant and machinery; the Act. Activities on site also need to protection of persons other than persons at work against hazards to health and comply with the standard Occupational safety arising out of or in connection with the activities of persons at work; to Health and Safety standards. establish an advisory council for occupational health and safety; and to provide for matters connected therewith. Ambient Air Quality Standards, National ambient air quality standards set in terms of Section 9(1) of the National Applicable to emissions resulting from Cape Winelands District Municipality published in Government Environmental Management: Air Quality Act 2004 (Act No.39 of 2004) the anaerobic and combustion – Air Pollution Control Gazette no. 32816 on 24 treatment of waste. December 2009

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Legislation/ Guideline Primary Function Applicability Responsible Authority National Environmental The purpose of this Act is to reform the law regulating air quality in order to An Atmospheric Emissions Licence Cape Winelands District Municipality Management: Air Quality Act (Act protect the environment by providing reasonable measures for the prevention of (AEL) will have to be obtained in terms – Air Pollution Control No. 39 of 2004) pollution and ecological degradation and for securing ecologically sustainable of the National Environmental development while promoting justifiable economic and social development; to Management: Air Quality Act (Act No. provide for national norms and standards regulating air quality monitoring, 39 of 2044) for the digestion management and control by all spheres of government; for specific air quality component of the project. measures; and for matters incidental thereto. Category 1: Combustion Installations Category 8: Thermal Treatment of Hazardous and General Waste 19. Category 10: Animal matter processing National Environmental To provide for the management and conservation of South Africa’s biodiversity Critical Biodiversity Areas have been Department of Environmental Affairs Management: Biodiversity Act within the framework of the National Environmental Management Act, 1998; the identified on and near the proposed (DEA) (Act No. 10 of 2004) protection of species and ecosystems that warrant national protection; the site alternatives. sustainable use of indigenous biological resources; the fair and equitable sharing of benefits arising from bioprospecting involving indigenous biological resources; the establishment and functions of a South African National Biodiversity Institute; and for matters connected therewith. National Heritage Resources Act To introduce an integrated and interactive system for the management of the A Notice of Intent to Develop will be Heritage Western Cape national heritage resources; to promote good government at all levels, and submitted to Heritage Western Cape empower civil society to nurture and conserve their heritage resources so that for consideration and guidance on any they may be bequeathed to future generations; to lay down general principles for further studies they may deem governing heritage resources management throughout the Republic; to introduce necessary. an integrated system for the identification, assessment and management of the heritage resources of South Africa; to establish the South African Heritage Resources Agency together with its Council to co-ordinate and promote the management of heritage resources at national level; to set norms and maintain essential national standards for the management of heritage resources in the Republic and to protect heritage resources of national significance; to control the export of nationally significant heritage objects and the import into the Republic of cultural property illegally exported from foreign countries; to enable the provinces to establish heritage authorities which must adopt powers to protect and manage certain categories of heritage resources; to provide for the protection and management of conservation-worthy places and areas by local authorities; and to provide for matters connected therewith.

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Legislation/ Guideline Primary Function Applicability Responsible Authority National Road Traffic Act GN To provide for road traffic matters which shall apply uniformly throughout the Chapter VIII: Transport of dangerous Department of Transport R225 (March 2000) Republic and for matters connected therewith. goods and substances by road. Possibly relevant to the Transportation of sewage sludge.

“dangerous goods" means the commodities, substances and goods listed in the standard specification of the South African Bureau of Standards SABS 0228 "The identification and classification of dangerous substances and goods"; (xvii) Guidelines for Involving DEA&DP has developed policy guidelines around specialist involvement in EIA Guidance for involving specialists in Department of Environmental Affairs Specialists in the EIA Processes processes. The guidelines aim to improve the quality of specialist input and the Scoping and EIR process. and Development Planning facilitate informed decision-making. They clarify the roles and responsibilities of all (DEA&DP) role players with regard to specialist input in the EIA process. This will help practitioners draft appropriate terms of reference for specialist input and assist role players to evaluate the appropriateness of specialist input in individual cases. DEA&DP EIA Guideline and These guidelines provide information and guidance for applicants, authorities and Guidance during the Scoping & EIR Department of Environmental Affairs Information Document Series interested and affected parties (“I&APs”) on the procedures and the provisions in process. and Development Planning (March 2013) terms of NEMA, the EIA Regulations, the NEM: AQA, and NEM: WA. (DEA&DP) DEA Companion Guideline on A series of guideline documents on environmental impact management legislation Guidance during the Scoping & EIR Department of Environmental Affairs the Implementation of the and regulations. It provides guidance on the procedures and the provisions in process. (DEA) Environmental Impact terms of NEMA and its EIA Regulations as well as other relevant legislation. Assessment Regulations, 2010 and Public Participation Guideline published October 2012 Guidelines for the Utilization and These Guidelines were developed to encourage the implementation of beneficial Relevant to biodigestion with sewage Department of Environmental Affairs Disposal of Wastewater Sludge use of sludge. Rather than attempting to develop a single guideline to address all sludge (Volumes 1-5) the management options, separate Guideline Volumes deal with each of the possible management options. This also simplifies the document(s) for the users, as each Guideline Volume is dedicated to the management, technical and legislative aspects associated with a particular option, as well as the sludge characterisation requirements for that option.

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Legislation/ Guideline Primary Function Applicability Responsible Authority GN 634 of 2013: Waste • Regulate the classification and management of waste in manner which The applicant’s proposed activities Department of Environmental Affairs Classification and Management supports and implements the NEMWA, 2008 (Act No. 59 of 2008); must be in-line with the relevant/ (DEA) and Regulations • Establish a mechanism and procedure for the listing of waste management applicable regulations in terms of the Department of Environmental Affairs activities that do not require Waste Management Licences; NEMWA, 2008 (Act No. 59 of 2008). and Development Planning • Prescribe requirements for the assessment of the environmental risk (DEA&DP) associated with the disposal of waste to landfill; • Prescribe requirements and timeframes for the management of waste; and • Prescribe general duties of waste generators, transporters and managers. GN 635 of 2013: National Norms This Notice prescribes the requirements for the assessment of the level of risk Standard requirements for the Department of Environmental Affairs and Standards for Assessment of associated with the disposal of waste to landfill in terms of the Waste assessment of waste disposed of to (DEA) and Department of Waste for Landfill Disposal Classification and Management Regulations, 2013, in terms of Section 69 (1) (a), landfill, - thereby identifying the Environmental Affairs and (b), (g), (h), (m), (q), (s), (dd) and (ee) of the NEMWA, 2008 (Act No. 59 of 2008). possible risk to the environment. Development Planning (DEA&DP) GN 636 of 2013: National Norms Prescribes the requirements for the disposal of waste to landfill as contemplated This document provides criteria for the Department of Environmental Affairs and Standards for Disposal of in the Waste Classification and Management Regulations, 2013, in terms of disposal of waste to landfill. (DEA) and Department of Waste to Landfill Section 69 (1) (a), (b), (g), (h), (m), (q), (s), (dd) and (ee) of the NEMWA, 2008 Environmental Affairs and (Act No. 59 of 2008). Development Planning (DEA&DP) National Building Regulations To provide for the promotion of uniformity in the law relating to the erection of The erection of buildings/ infrastructure Drakenstein Municipality and Building Standards Act No. buildings in the areas of jurisdiction of local authorities; for the prescribing of on site must be inline with the Act. 103 of 1977 (as amended) building standards; and for matters connected therewith. National Waste Management This National Waste Management Strategy presents Government’s strategy for Waste streams that include hazardous Department of Environmental Affairs Strategy (May 2012) integrated waste management for South Africa. components and that present The NWMS is a legislative requirement of the National Environmental particular strategic challenges include Management: Waste Act, 2008 (Act No. 59 of 2008), here after referred to as the sewage sludge. “Waste Act”. The Act requires that it is reviewed at least every five years, and the The NWMS recognizes that focus of this strategy is therefore on the waste management measures and uncontaminated sewage sludge has a actions that need to be taken within the next five years. variety of commercial uses and can be recycled.

The management and disposal of sewage sludge emanating from wastewater treatment facilities requires input and cooperation from DWA. Air Quality Monitoring Plan for The mission of the AQMP is “To ensure the effective and consistent Due to the combustion activities, the DEADP the Western Cape, 2010 implementation of sustainable air quality management practices, by all spheres of project will trigger a listed activity in government, relevant stakeholders and civil society to progressively achieve and terms on NEM:AQA. efficiently maintain clean and healthy air in the Western Cape”

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Legislation/ Guideline Primary Function Applicability Responsible Authority Hazardous Waste Management The aim of integrated hazardous waste management planning is to ensure the Sewage sludge has been identified as DEADP Plan, 2006 protection and safety of the environment through efficient and effective hazardous a Priority Hazardous Waste Stream. waste management. Thus HWMP shall subscribe to the environmental management principals as described in Section 2, of the National Environmental Management Act, Act. 107 of 1998 (NEMA), while ensuring the attainment of acceptable standards of management, practice and technology in relation to the generation, handling, storage, transportation, treatment, disposal and record keeping of hazardous waste. Provincial Integrated Waste The Provincial IWMP has a direct focus on the diversion of organic waste from Strategic Objective 7.1 is To promote PGWC Management Plan (IWMP) for landfill. The management of animal waste including abattoir waste and sewage safe handling, storage, transportation the Western Cape, 2011 sludge were identified as Priority Needs during the formulation of the Plan. and disposal of hazardous waste. (Provincial and National Approval Activity 7.1.4.4 under this objective to be granted) states as follows: To initiate the establishment of regional hazardous waste and problematic waste (sewage sludge and abattoir waste) treatment facilities. Strategic Objective 7.3 is To reduce the generation of hazardous waste. Target 7.3.1 under this objective states as follows: To increase the recovery and recycling rates for priority hazardous wastes identifies by 5% by 2014.

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Legislation/ Guideline Primary Function Applicability Responsible Authority Assessment for the Best Sewage sludge is considered as one Practicable Environmental of the priority hazardous wastes in the Option for Managing Priority province. Hazardous Waste Streams for the Western Cape, DEADP, The ‘current BPEO’ is “land March 2006 application” and the ‘future BPEO’ includes “land application / restrictions on disposal of sludge to landfill…”. Recycling of sewage sludge through land application was selected as the BPEO based on exclusion of other recycling options which were considered to be economically unfeasible.

This document goes on to state that gasification and energy generation is considered to be an inappropriate option due to “the relative scale of sludge generation in the province along with transport distances and absence of significant demand for gas as an energy source”.

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3.2 Policy and Planning Framework It is important that service facilities and infrastructure which are being proposed and assessed for long term planning take into account and integrate future planning requirements on a broader provincial, regional and local scale - particularly within the immediate vicinity to be affected. The planning approach adopted is important to ensure that the waste management facility is suitably located. In addition, possible conflicting land uses must be considered so that the environmental needs of the broader community are taken into account.

The following policy and planning documents must be taken into account:

3.2.1 Western Cape Provincial Spatial Development Framework (PSDF) The Western Cape Provincial Spatial Development Framework (PSDF) is a broad scale, provincial policy document. The PSDF promotes recycling, composting and waste minimisation. The PSDF (2009) sets out a number of Objectives – of relevance to this project is Objective 9.

Objective 9: Minimise consumption of scarce environmental resources – waste recycling A number of policies have been compiled under this objective relating to waste management, which reads as follows:

• RC32: All municipalities should follow an integrated hierarchical approach to waste management i.r.o. avoidance, reduction, reuse; • RC37: Every municipality should have waste management facilities located and operated according to DWAF’s minimum requirements that will service the transfer stations in the urban settlements in that municipality. These sites may or may not be located within the urban edge of urban settlements. The main criteria for their location will be to meet satisfactory environmental and transport requirements.

The proposed Waste Recovery, Beneficiation and Energy Project facility is in line with RC32 in terms of the recovery of recyclable items at the proposed Material Recovery Facility (MRF), the digestion of organic waste to generate energy (electricity), combustion of inorganic waste and finally providing landfill airspace for final disposal. CWDM will encourage local Municipalities to meet the requirements of the waste hierarchy and in general there will be pressure on local Municipalities to reduce the amount of waste that is disposed of to landfill in order to limit the transport costs.

3.2.2 CWDM: Spatial Development Framework (SDF) (March 2011) The SDF is a long-term plan to manage growth and change, as it:

• Makes recommendation relating to opportunities to optimise the utilisation of the existing resources, including agriculture, land, the natural environment, water, minerals, bulk infrastructure, roads, transport and social facilities so as to facilitate tourism and environmental conservation as a socio- economic base for the area; • Propose strategies to discourage inefficient and insensitive development and protect the agriculture and biodiversity resource base of the area; • Propose strategies to contribute to the correction of historically distorted patterns of land ownership and settlement; • Propose strategies to beneficially use the existing infrastructure, roads and transport opportunities; • Propose strategies to maximise opportunities for the co-ordinated management of large conservation areas by Cape Nature or any other statutory body; • An SDF does not grant any rights pertaining to land use, nor take any rights away.

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In reviewing the status quo the CWDM SDF acknowledges that urban development requires waste treatment and disposal services; and the challenges facing solid waste management due to a lack of services in the district municipal area.

A number of studies, investigations, plans, projects and initiatives have been identified to help achieve this long term vision expressed in the framework and applied in the SDF. There are a number of initiatives underway in the District that has direct implications for the SDF. As far as possible proposed actions, projects and initiatives should utilise or build on existing initiatives. The investigation into a Waste Recovery, Beneficiation and Energy Project facility is inline with existing initiatives.

3.2.3 CWDM: Integrated Development Plan (IDP) (2008/2009) The Municipal Systems Act (MSA) compels municipalities to draw up an Integrated Development Plan (IDP) as a singular, inclusive and strategic development plan that is aligned with the deliberate efforts of the surrounding municipalities and other spheres of government. In terms of the MSA, the Cape Winelands District Municipality (CWDM) is required to formulate an IDP made up of the following components:

• A vision of the long-term development of the CWDM; • An assessment of the existing level of development in the CWDM which must include an identification of the need for basic municipal services; • The CWDM development priorities and objectives for its elected term; • The CWDM development strategies which must be aligned with any national or provincial sectoral plans and planning requirements; • A spatial development framework which must include the provision of basic guidelines for a land use management system; • The CWDM operational strategies; • A disaster management plan; • A financial plan, which must include a budget projection for at least the next 3 years; and • Key performance indicators and performance targets.

The CWDM IDP highlights the gradual deterioration in the health of ecosystem in the district, which without the necessary interventions, will lead to a crisis in the ability of these ecosystems to provide ‘ecosystem services’ required to support the sustainable economic development and improved quality of life that the Municipality strives for in its area of jurisdiction. Human activity in the CWDM is putting pressure on the continued ability of ecosystems to deliver ‘ecosystem services’ into the future.

A vital aspect of the function of the CWDM is the provision of high-level basic services and infrastructure that will underpin economic and social development in the region. This includes waste management.

A strategic Integrated Waste Management Plan (IWMP) which paints a holistic view of waste management for the District as well as the local Municipalities has been developed. This document identified management issues of a district nature which were investigated and are in the process of being implemented.

Sustainable development has also been raised as a critical issue within the District. It was agreed that all sectors should commit to the promotion of cleaner technologies, waste minimisation practices, utilising renewable energy sources, and proactively addressing pollution. The proposed project is inline with all of the listed commitments. An Integrated Environmental Management Plan has been adopted for the CWDM. It was agreed that the relevant government departments should enforce compliance with environmental legislation.

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3.2.4 CWDM: Draft Review Integrated Development Plan (IDP) (2014/2015) With regards to waste management Service Provision and Infrastructure Analysis the IDP Review states that Council is currently in the process of completing a second generation Integrated Waste Management Plan (IWMP) for the district as a whole. Most of the local municipalities have completed or are in the process of completing their own IWMP and in combining these plans into one strategic document, a holistic view of waste management in the district can be obtained. Through this, management issues of a district nature can be identified, investigated and implemented. The IWMP is a statutory requirement of the National Environmental Management: Waste Act (Act No. 59 of 2008) that has been promulgated and came into effect on 1 July 2009. Plan is borne out of the requirements of the National Waste Management Strategy and forms the first action plan in terms of this strategy.

The IWMP will underline the following principles of the National Waste Management Strategy: 58

i. The prevention of waste generation; ii. The recovery of waste of which the generation cannot be prevented; and iii. The safe disposal of waste that cannot be recovered

Council has developed an Integrated Waste Management Plan (IWMP) for the district as a whole and has also assisted some municipalities in the compilation of their IWMP. This integrated strategic document gives a holistic view of waste management in the district. Through this, management issues of a district nature can be identified, investigated and implemented.

Waste management in the local municipalities are generally well done insofar as the collection of domestic municipal waste is concerned with waste collection provided for the vast majority of urban residents. However, the management of waste disposal is generally poor. Waste avoidance is not significantly practiced anywhere in the District except for at certain private enterprises. Reference must be made to the Blue Bag system in Stellenbosch that promotes separation at source while other municipalities are also venturing in this direction. Waste avoidance will only be achieved through the implementation of a public awareness campaign.

Waste Recovery of any significance is only done at the Materials Recovery Facilities (MRFs) at Paarl and Touws River. Scavenging takes place at a number of the waste disposal sites in the area, contributing to operational difficulties. These type of facilities must be constructed in all larger towns with populations larger than 50 000.

Composting is done successfully near Stellenbosch. Klapmuts and Robertson and should be extended to all larger towns in the District. Mobile builder’s rubble crushing plants should be established that can rotate between the various larger towns.

3.2.5 CWDM: Environmental Management Framework (EMF) (2011) The CWDM appointed SRK Consulting to develop an Environmental Management Framework (EMF) for the eastern portion of the CWDM. The study area includes the District Management Area, Witzenberg, Breede Valley and Langeberg Local Municipalities, but excludes the Drakenstein and Stellenbosch Municipalities.

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3.2.6 CWDM Waste Recycling Plan (July 2010 Final) For the purposes of evaluating the status quo of waste management within the CWDM, a detailed desk-top analysis of the Cape Winelands DM waste stream was completed. Data was extracted from a number of sources including the District’s IWMP, Waste Characterisation Surveys and the Spatial Development Framework for the CWDM. Information from the Waste Recycling Plan is summarised further in Section 3 of the report in which an Overview of Waste Management in the WCDM is broadly presented.

It is clear from the planning documents listed and summarised above, that waste minimization and recycling are a top priority within the CWDM. The development of a proposed Waste Recovery, Beneficiation and Energy Project for the Drakenstein Municipal area should result in improved waste management and minimisation of waste to be disposed of to landfill, most of which are quickly running out of airspace.

The proposed development is considered to be aligned with the above plans and policies; as well as with the future requirements of the district and local municipalities.

3.2.7 Drakenstein Revised IDP (2014/2015) The Integrated Development Plan for Drakenstein Municipality represents the strategic plan to address the development challenges and needs of the Drakenstein community by guiding and directing a development agenda.

The IDP has also identified Infrastructure and Backlogs issues within the municipality as a Key Focus Area. One of the major challenges within Waste Services is the limited airspace available at the Drakenstein Landfill Facility at Wellington. This project will result in the reduction of waste that needs to be disposed of to landfill within the Municipal area.

The IDP has also indicated that the Drakenstein Municipality has embarked on a waste to energy project (namely the current application) whereby waste will be used to generate energy and in the same instance valuable air space will be saved at the landfill site. The Budget Assumptions has also taken the proposed project into account and states under Refuse removal revenue:

“The increase of 9.7% for the 2014/2015 to 2017/2018 financial years has to do with the envisaged waste to energy public private partnership project that will ensure the extension of the useful life of the Wellington waste disposal site. If the public private partnership does not materialise the Wellington waste disposal site will reach its useful life in the 2016/2017 financial year and then needs to be rehabilitated and closed. Waste will then have to be transported to the City of Cape Town’s waste disposal site and to cover these transport and disposal costs refuse removal tariffs will have to increase by 41.3% and 30.5% in the 2016/2017 and 2017/2018 financial years. This financial impact won’t be sustainable over the long-term.”

3.2.8 Drakenstein Spatial Development Framework (Amended October 2010) A municipal Spatial Development Framework is a planning document which provides guidelines for the future long-term spatial development of the municipality. A SDF aligns and focuses on principles set out in the IDP, on issues such as infrastructure development, crime, tourism etc. The aim of the document is to guide the municipality in decision-making processes relating to the use of space.

The Drakenstein Spatial Development Framework aims to: - alleviate poverty through spatial restructuring - compact urban environment to spread the benefits of urban living - increase accessibility to existing and new service infrastructure to enhance the overall quality of life of the communities - provide new and reinforce existing opportunities for economic development - protection of natural resources - protection of agricultural resources

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The above mentioned aims are not directly related to the proposed Waste to Energy project. However it is to be noted that no fatal flaws have been identified for the alternative site locations selected.

3.2.9 Drakenstein Integrated Waste Management Plan (IWMP) (2009) The purpose of the Integrated Waste Management Plan To address the challenge of Waste Management in Drakenstein in line with the National Waste Management Strategy. The IWMP contributes to the IDP strategy by ensuring that the residents of Drakenstein live in a clean and healthy environment.

The actions of the plan are on-going and more than 90% of the action items for the 2nd generation IWMP have been addressed. The Plan addresses all areas of Waste Management – from waste prevention and minimisation (waste avoidance),to its collection, treatment, recovery, final disposal and advance technology like the approved Waste to Energy project (2014) (this project) for the next 20 years.

3.2.10 Drakenstein Strategic Environmental Assessment (SEA) – Wellington Industrial Precinct The Drakenstein SEA conducted for the Wellington Industrial Park area extension included a range of specialist studies; Botanical, Freshwater, Soils Potential, Traffic, Visual, Heritage, Socio-Economic.

The proposed Eco-Corridor is shown in Figure 10 below. This will need to be taken into account during the evaluation and assessment of site alternatives 1 (preferred) and 2.

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Figure 10: Proposed Eco Corridor.

Figure 11 below was prepared on completion of the SEA and provides for a spatial point of departure for a Precinct Plan for the site. The Site Development Plan reflects the proposed and preferred site location alternative for the Drakenstein Waste to Energy Treatment Facility.

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Figure 11: Wellington Industrial Park - Site Development Plan (Spatial Point of Departure for a Precinct Plan for the Site).

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3.2.11 Drakenstein Strategic Environmental Assessment (SEA) – Klapmuts North The Environmental Sensitivity mapping for Erf 736 as prepared following the completion of the specialist studies during the SEA process is reflected in Figure 12.

The specialist studies completed included the following; Botanical, Freshwater, Agricultural, Visual, Cultural Heritage, Archaeological, Socio- Economic and Geotechnical.

Figure 3: Environmental Sensitivity Map – Erf 736.

45 3.2.12 Drakenstein Environmental Management Framework The EMF is aimed at providing information that can be used by the authorities to support him/her in making decisions that will take development in the “right direction.” The idea is to find the best possible match between protecting natural and cultural resources (i.e. preventing their loss or degradation), whilst addressing the need for development to address pressing social needs such as poverty.

According to the ‘Control Zone Layers’ generated as part of the EMF, the following is of relevance to the proposed site alternatives: • An ecological corridor runs along the Berg River. • The part of the proposed preferred site is identified as a critical biodiversity area in terms of the EMF.

The site has however been highly degraded and little to no vegetation remains. A vegetation constraints assessment will be undertaken to identify a suitable footprint area for the proposed facility and to investigate whether any further studies are required.

3.2.13 Principles contained in Section 23 and Section 2 of NEMA It is required to show how the proposed development complies with the principles contained in Section 2 of NEMA and must also show how the proposed development meets the requirements of sustainable development.

Table 4 below describes how the general objectives of Integrated Environmental Management as set out in section 23 of NEMA have been taken into account:

Table 4: General objectives of IEM Relevant IEM Objective Relevance to EIA Process/ Project The general objective of integrated environmental 2 management is to - promote the integration of the principles of environmental The EIA process is required to take into account the management set out in section 2 into the making of all (a) social, environmental and economic aspects of the decisions which may have a significant effect on the proposed activity – as applicable. environment: identify, predict and evaluate the actual and potential impact A Scoping Report must include “a description of on the environment, socio-economic conditions and cultural environmental issues and potential impacts, including heritage, the risks and consequences and alternatives and cumulative impacts that have been identified” as well as (b) options for mitigation of activities, with a view to minimizing “a description of identified potential alternatives to the negative impacts. maximizing benefits, and promoting proposed activity, including advantages and compliance with the principles of environmental management disadvantages that the proposed activity may have on set out in section 2; the environment and the community that may be affected by the activity”.

ensure that the effects of activities on the environment receive Chapter 7 of the Draft Scoping Report provides a (c) adequate consideration before actions are taken in connection description of environmental issues and potential with them; impacts that have been identified. Additional issues and impacts may be identified by the specialists during the impact assessment phase. A public participation process as required by the NEMA ensure adequate and appropriate opportunity for public (d) EIA Regulations, 2010 has been undertaken. Refer to participation in decisions that may affect the environment; Annexure A for the Public Participation Report. ensure the consideration of environmental attributes in Refer to Chapter 7 for a description of identified issues (e) management and decision-making which may have a and impacts. significant effect on the environment; and identify and employ the modes of environmental management A summary of the relevant Principles and how they have best suited to ensuring that a particular activity is pursued in (f) been taken into account are contained in the table accordance with the principles of environmental management below. set out in section 2. DRAFT SCOPING REPORT: INTERWASTE (Pty) Ltd – Drakenstein WtE OCTOB

Table 5 below describes how the principles of environmental management as set out in section 2 of NEMA have been taken into account:

Table 5: Principles of Environmental Management NEMA Principle Relevance to EIA Process/ Project Sustainable development requires the consideration of all 4(a) relevant factors including the following: The site in question is already disturbed i.e. historically flattened and illegal dumping taking place. The Draft That the disturbance of ecosystems and loss of biological Scoping Report identifies environmental issues and (i) diversity are avoided, or, where they cannot be altogether potential impacts. Measures to avoid/ reduce/ minimise avoided, are minimised and remedied; environmental impacts and disturbance to the surrounding environment will be included in the EMPr. The Draft Scoping Report identifies environmental issues that pollution and degradation of the environment are and potential impacts. Measures to avoid/ reduce/ (ii) avoided, or, where they cannot be altogether avoided, are minimise environmental impacts and disturbance to the minimised and remedied; surrounding environment will be included in the Draft EIR. The Draft Scoping Report identifies environmental issues and potential impacts. Measures to avoid/ reduce/ that the disturbance of landscapes and sites that constitute minimise environmental impacts and disturbance to the (iii) the nation’s cultural heritage is avoided, or where it cannot surrounding environment will be included in the Draft EIR. be altogether avoided, is minimised and remedied; A Notification of Intent to Develop (NID) will be submitted to Heritage Western Cape (HWC) along with a copy of the Draft EIA Report. The proposed activities i.e. waste separation for recycling, that waste is avoided, or where it cannot be altogether anaerobic digestion and combustion is a treatment (iv) avoided, minimised and re-used or recycled where possible methods will minimize waste and create beneficial product and otherwise disposed of in a responsible manner; i.e. renewable energy source. The proposed activities i.e. waste separation for recycling, That the use and exploitation of non-renewable natural anaerobic digestion and combustion is a treatment (v) resources is responsible and equitable, and tales into methods will minimize waste and create beneficial product account the consequences of the depletion of the resource i.e. renewable energy source. That the development, use and exploitation of renewable The main goals of the proposed project is to reduce waste (vi) resources and the ecosystem of which they are part do not disposed of to landfill and generate sustainable energy. exceed the level beyond which their integrity is jeopardized. That a risk-averse and cautious approach is applied, which The Draft Scoping Report list assumptions and gaps in (vii) takes into account the limits of current knowledge about the knowledge; as it was compiled through desktop study. consequences of decisions and actions; and Refer to the Plan of Study for EIA. That negative impacts on the environment and on people’s The Draft Scoping Report identifies environmental issues environmental rights be anticipated and prevented, and and potential impacts. Measures to avoid/ reduce/ (viii) where they cannot be altogether prevented, are minimised minimise environmental impacts and disturbance to the and remedied. surrounding environment will be included in the Draft EIR. Environmental management must be integrated, acknowledging that all elements of the environment are The scoping and EIA process must take into account linked and interrelated, and it must take into account the (b) social, environmental and economic aspects of the effects of decisions on all aspects of the environment and proposed activity – as applicable. all people in the environment by pursuing the selection of the best practicable environmental option. Environmental justice must be pursued so that adverse environmental impacts shall not be distributed in such a The proposed facility will be an improvement on the (c) manner as to unfairly discriminate against any person, current waste water management systems in place. particularly vulnerable and disadvantaged persons. Equitable access to environmental resources, benefits and The proposed activities i.e. waste separation for recycling, services to meet basic human needs and ensure human anaerobic digestion and combustion is a treatment (d) wellbeing must be pursued and special measures may be methods will minimize waste and create beneficial product taken to ensure access thereto by categories of persons i.e. renewable energy source. disadvantaged by unfair discrimination Responsibility for the environmental health and safety An Environmental Management Programme (EMPr) which (e) consequences of a policy, programme, project, product, deals with the construction and operational phase impact process, service or activity exists throughout its life cycle of the proposed facility will be included in the Draft EIR.

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NEMA Principle Relevance to EIA Process/ Project The participation of all interested and affected parties in environmental governance must be promoted, and all The EIA Process provides for the participation of potential people must have the opportunity to develop the (f) I&AP’s. The Public Participation Report (Annexure A) understanding, skills and capacity necessary for achieving provides an account of the detailed public participation equitable and effective participation, and participation by process undertaken to date to ensure that the public are vulnerable and disadvantaged persons must be ensured. provided with an opportunity to play an active role in the Decisions must take into account the interests, needs and decision-making process. The public participation process values of all interested and affected parties, and this (g) should be fair, transparent and inclusive. includes recognizing all forms of knowledge, including traditional and ordinary knowledge. Community wellbeing and empowerment must be promoted The sharing of local knowledge will be facilitated through through environmental education, the raising of the Public Participation Process – by means of public (h) environmental awareness, the sharing of knowledge and meetings and allowing for review and comment on all experience and other appropriate means. reports. The social, economic and environmental impacts of The Draft Scoping Report identifies environmental issues activities, including disadvantages and benefits, must be and potential impacts. The significant impact will be (i) considered, assessed and evaluated, and decisions must assessed during the Impact Assessment Phase. Refer to be appropriate in the light of such consideration and Chapter 7. assessment. The applicant will be made aware of this Principle. The EMPr will need to make provision for on-site training of staff so that they perform their work with all the necessary The right of workers to refuse work that is harmful to human skills and training. (j) health or the environment and to be informed of dangers

must be respected and protected. All the necessary safety signage must be displayed and explained to workers by the applicant/ contractor during the construction and operational phases of the project. The EIA Process provides for the participation of potential I&AP’s. The Public Participation Report (Annexure A) Decisions must be taken in an open and transparent provides an account of the detailed public participation (k) manner, and access to information must be provided in process undertaken to date to ensure that the public are accordance with the law. provided with an opportunity to play an active role in the decision-making process. The public participation process should be fair, transparent and inclusive. There must be intergovernmental co-ordination and Chapter 3 provides an indication of the policies, guidelines (l) harmonisation of policies, legislation and actions relating to and legislation (at all levels of government) which must be the environment. considered. Actual or potential conflicts of interest between organs of No such conflicts have been brought to the attention of (m) state should be resolved through conflict resolution RMS to date. These will be dealt with accordingly. procedures. Global and international responsibilities relating to the (n) This project is of local to regional relevance. environment must be discharged in the national interest. The environment is held in public trust for the people, the The proposed activities i.e. waste separation for recycling, beneficial use of environmental resources must serve the anaerobic digestion and combustion is a treatment (o) public interest and the environment must be protected as methods will minimize waste and create beneficial product the people’s common heritage. i.e. renewable energy source. The costs of remedying pollution, environmental degradation and consequent adverse health effects and of (p) preventing, controlling or minimizing further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment. The vital role of women and youth in environmental The public participation process will be fair, transparent (q) management and development must be recognised and and inclusive allowing all potential I&AP’s to raise their full participation therein must be promoted. concerns related to the proposed project. Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal shores, estuaries, wetlands, and similar systems require specific attention in The proposed development will be located in an existing (r) management and planning procedures, especially where built-up industrial area. they are subject to significant human resource usage and development pressure.

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4. PROJECT DESCRIPTION (PREFERRED ALTERNATIVE)

4.1 Proposed Waste Recovery, Beneficiation and Energy Project The Drakenstein Municipality (“DM”) is committed to significantly reducing the amount of waste going to landfill and aims to meet the objectives of the National Waste Management Strategy.

Due to this commitment, the DM has entered into a medium to long-term Public Private Partnership (“PPP”) agreement with Interwaste. The Interwaste PPP agreement includes the integrated management of the DM’s waste management operations, including the planning, designing, financing, construction and operation of a Waste to Energy Project. The contract also includes provision for the management, operation and maintenance of the existing municipal waste management facilities.

The three main objectives for the Waste to Energy project as necessitated by the DM contract are: . The generation of Renewable Energy from Municipal Solid Waste, . Reduction of Municipal Solid Waste to Landfill, and

The primary focus of the project is energy from waste, but it will also entail waste recovery and waste beneficiation activities. All other waste management activities are secondary focuses.

The overall waste management facility will consist of four main elements to be operated in series or as separate entities, namely: . Materials Recovery Facility (MRF) – clean or dirty . Municipal Solid Waste Pressing Plant . Anaerobic digestion (AD) plant . Direct Combustion (DC) plant

Materials Recovery Facility (MRF) It is proposed to construct a Materials Recovery Facility (MRF) as part of the project for the recovery of recyclables and separation of organic wastes. The proposed development of the MRF will take place in two phases, . phase one will consist of a facility with a capacity of less than 200 tonnes of waste per day and with a footprint of less than 1 000m2 . phase two will address the expansion of the MRF to process between 200 to 300 tonnes of waste per day and the expansion of the footprint will exceed 1000m2.

MRF Phase One will take place in parallel with the EIA process.

A MRF is a plant that receives waste materials which are either separated at source (clean co-mingled waste) or mixed (“dirty” wastes). At the proposed plant, materials will be separated, processed and stored for later use as raw materials or for remanufacturing processes.

At the MRF the recyclable materials will be sorted to specifications/grade, baled, shredded, crushed, and/or otherwise prepared for transport to market. It is intended that the organic waste separated from the recyclables be utilized for the anaerobic digestion (“AD”) plant.

The Wellington MRF will be designed to handle 200 to 300 tonnes of waste per day, which equates to a throughput of 5 to 11 tonnes per hour. Waste will be primarily sourced from the Drakenstein Municipal area

The facility will operate from 08h00 to 17h00 on a two shift system (08h00 -16h00 and 09h00-17h00). The facility therefore has a maximum throughput capacity of 75,600 tonnes per year.

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Pressing Plant Subsequent to the recovery of recyclable materials from the municipal waste stream, a waste pressing technology will be utilized to separate the organic fraction from the remaining, unrecyclable fraction of the Municipal Solid Waste (“MSW”) stream. The organic fraction will be used as feedstock in the proposed Anaerobic Digestion plant.

The proposed press is designed to physically, at high pressure, separate the largely unrecyclable waste fraction into two fractions, i) an organic wet fraction and ii) a solid dry fraction. The separation process consists of a chamber with a very strong mesh, against which waste is compressed using high pressure of up to 1000Bar. This results in changing the structure of the organic material into fluid plasma, allowing it to be pressed through the mesh. This wet organic fraction will be recovered in the anaerobic digestion plants to generate biogas. The dry non-organic fraction contains mainly refuse derived fuel (“RDF”), but also some residue minerals and metals. After the dry fraction has undergone an additional separation process by sorting out these metals, only RDF and recyclables remain. The recyclables will join the materials recovered at the MRF and be sold to market.

The waste handling capacity of the pressing plant is 450 ton/day MSW and the output streams will supplement the Anaerobic Digestion Plant (organic fraction) and Direct Combustion Plant (refuse derived fuel) as well as creating a potential revenue stream from sales of recyclables.

50

Figure 4: Materials Recovery Facility (MRF) and Waste Press Process Flow Diagram. Anaerobic digestion plant Anaerobic digestion is a biological process in which microorganisms break down biodegradable material through a series of processes in the absence of oxygen. The process is widely used in industry to treat wastewater and as part of an integrated waste management system. Anaerobic digestion as a process whereby a renewable energy source can be generated as it produces a methane rich biogas which can be used as fossil fuel replacement for energy production.

The Anaerobic digestion plant will utilize the organic fraction of the MSW diverted in the separation plant (MRF & pressing unit) as well as alternative organic waste streams such as winery waste, condemned food, etc., that is compatible. In addition 220 m³ per day of sewage sludge from the Paarl waste water treatment works will be utilized for dilution in the AD facility. In total the AD plant will have a capacity to process 194 t/d of organic waste and will produce an anticipated 2.5 MW (gross) of electricity.

The digestate left over at the end of the AD process will be used as a feedstock for the Direct Combustion process.

Figure 5: Anaerobic Digestion Process Flow Diagram. Direct Combustion plant Direct Combustion was chosen as the preferred management option for the waste fraction that will not be used as feedstock for the Anaerobic Digestion Facility or waste materials recovered or landfilled. A direct combustion (DC) system burns the biomass to generate hot flue gas, which is either used directly to provide heat, or fed into a boiler to generate steam.

In a boiler system, the steam can be used to provide heat for industrial processes, or space heating and a steam turbine can be used to generate electricity.

The feedstocks to be used in the direct combustion plant are the following: . dry fraction and unrecyclable material from the separation plant including RDF; . Digestate, as a waste stream from the Anaerobic Digestion process; and . Non-biodegradable MSW.

The Direct Combustion plant will have a capacity to process 300t/d of biomass and will produce an anticipated 10 MW (gross) of electricity.

At a later stage MSW from the landfill may also be mined and utilised as a feedstock. This will, however, only take place in purpose built cells that will be utilised after Interwaste has taken over management of the Wellington landfill site. None of the historic landfill will be mined at this stage.

The waste stream generated from the DC will be inert ash and will be disposed of at the landfill site or used in the brick making process.

The total amount of MSW to be accepted at the waste management facility is 430 ton/day waste; of which 194 ton/day will be organic waste to be utilized in the AD plant. In addition the DC plant will accept 300 ton/day of waste but this will consist of 114 ton/day of digestate from the AD, as well as the 120 ton/day inorganic waste material (refuse derived fuel) from the separation plant.

It is also important to note that in order to ensure maximum diversion of waste from the landfill, it is necessary to import waste from adjacent municipalities or sources to warrant the establishment of the AD and DC plants. There is therefore an economy of scale that can be achieved by bringing in the additional wastes.

The two of the main objectives for the Waste to Energy project as necessitated by the DM contract are: . The generation of Renewable Energy from Municipal Solid Waste, and . Reduction of Municipal Solid Waste to Landfill.

4.1.1 The Preferred Location Alternative (Option 1) The Preferred Location Alternative is located adjacent to the existing Wellington landfill site which is situated off the R44 to the west of Wellington, approximately 800m from the turn-off from the R44.

The Drakenstein & Stellenbosch Critical Biodiversity Areas (CBA) Map classifies an area in the centre and northern edge of the proposed site as a Critical Biodiversity Areas. The site has however been highly degraded and little to no vegetation remains. A vegetation constraints assessment will be undertaken to identify a suitable footprint area for the proposed facility and to investigate whether any further studies are required. The site has been historically levelled and has been utilised for illegal dumping in the past.

The Preferred Location Alternative (Option 1) is shown in Figure 15 below.

Figure 6: The Preferred Site Location Alternative 1

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Figure 7: Schematic – 3 D View of Anaerobic Digestion and Direct Combustion Facility

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Figure 8: Schematic – 3 D View of Anaerobic Digestion and Direct Combustion Facility and link to Wellington Substation.

57 Refer to Chapter 5 for more information regarding location, activity and layout alternatives.

4.2 Listed activities

4.2.1 National Environmental Management Act (Act No. 107 of 1998) The following activities have been identified in Listing Notice 1 and Listing Notice 23 of the activities published under Sections 24(2) and 24D of the National Environmental Management Act, 1998 (Act No. 107 of 1998).

Table 6: List of activities triggered in terms of the Listing Notices published under the National Environmental Management Act (Act No. 107 of 1998) GN. R544 Activity Activities as per Listing Notice 1 (subject to Basic Assessment) No(s) The construction of facilities or infrastructure for the generation of electricity where: 1 (i) the electricity output is more than 10 megawatts but less than 20 megawatts (mw); or (ii) the output is 10 MW or less but the total extent of the facility covers an area in excess of 1 hectare. The construction of facilities or infrastructure exceeding 1000 meters in length for the bulk transportation of water, sewage or storm water – (i) with an internal diameter of 0.36 meters or more or; (ii) with a peak throughput of 120 litres per second or more, excluding where: 9 a. such facilities or infrastructure are for bulk transportation of water, sewage or storm water drainage inside a road reserve; or b. where such construction will occur within urban areas but further than 32 meters from a watercourse, measured from the edge of the watercourse. The construction of facilities or infrastructure for the transmission and distribution of electricity – (i) outside urban areas or industrial complexes with a capacity of more than 33 but less than 275 10 kilovolts. (ii) inside urban areas or industrial complexes with a capacity of 275 kilovolts or more. The transformation of undeveloped, vacant or derelict land to – (ii) residential, retail, commercial, recreational, industrial or institutional use, outside an urban area and where the total area to be transformed is bigger than 1 hectare but less than 20 hectares; - 23 Except where such transformation takes place – (i) for linear activities; or (ii) for purposes of agriculture or afforestation, in which case Activity 16 of Notice No. R. 545 applies. GN. R545 Activity Activities as per Listing Notice 2 (subject to Scoping and Environmental Impact Reporting No(s) (S&EIR)) The construction of a facilities or infrastructure for the storage, or storage and handling of a dangerous 3 good, where such storage occurs with a combined capacity of more than 500 cubic meters. The construction of facilities or infrastructure for any process or activity which requires a permit or licence in terms of national or provincial legislation governing the generation or release of emissions, 5 pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply. Commencing of an activity, which requires an atmospheric emission licence in terms of section 21 of 26 the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), except where such commencement requires basic assessment in terms of Notice No. R544 of 2010.

Activities as per Listing Notice 2 as per NEMA (table above) require that an environmental impact assessment process, as stipulated in the environmental impact assessment regulations made under section 24(5) of the National Environmental Management Act, 1998 (Act No. 107 of 1998) must be undertaken.

An Environmental Authorisation must be issued by the Department of Environmental Affairs (DEA) for the undertaking of the activities mentioned above.

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4.2.2 National Environmental Management: Waste Act (Act No. 59 of 2008) The following activities have been identified in Category A and Category B of “The list of waste management activities that have, or are likely to have a detrimental effect on the environment” published under Section 19(1) of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) on 03 July 2009 and amended on 29 November 2013:

Table 7: List of activities triggered in terms of the activities published under the National Environmental Management: Waste Act (Act No. 59 of 2008) Government Notice No. 32368 Category A Waste Management Activities Activity No(s): The sorting, shredding, grinding, crushing, screening or bailing of general waste at a facility 2 that has an operational area in excess of 1000m2. The construction of a facility for a management activity listed in Category A of this Schedule 12 (not in isolation to associated waste management activity), Government Notice No. 32368, Category B Waste Management Activities Activity No(s): The recovery of waste including the refining, utilization or co-processing of the waste at a facility that processes in excess of 100 tons of general waste per day or in excess of 1 ton of 3 hazardous waste per day, excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises. The treatment of hazardous waste in excess of 1 ton per day calculated as a monthly 4 average; using any form of treatment excluding the treatment of effluent, wastewater or sewage. The treatment of general waste in excess of 100 tons per day calculated as a monthly 6 average, using any for of treatment. The construction of facility for a waste management activity listed in Category B of this 10 Schedule (not in isolation to associated waste management activity),

Category B Waste Management Activities require that an environmental impact assessment process, as stipulated in the environmental impact assessment regulations made under section 24(5) of the National Environmental Management Act, 1998 (Act No. 107 of 1998) must be undertaken as part of a waste management licence application.

A Waste Licence must be issued by the National Department of Environmental Affairs (DEA) for the undertaking of the activities mentioned above.

Due to the fact that a Waste Management Licence involves hazardous waste management activities and an Environmental Authorisation is needed for a power generation activity, it is necessary that the application follows an integrated approach; where the DEA will issue a single Integrated Environmental Authorisation for the project.

4.2.3 National Environmental Management: Air Quality Act (Act No. 39 of 2004) The following activities have been identified in the list of the activities4 published under Section 21(1)(a) of the National Environmental Management: Air Quality Act (Act No. 39 of 2004).

4 List of activities which result in atmospheric emissions which have or may have a significant detrimental effect on the environment, including health, social conditions, economic conditions, ecological conditions or cultural heritage (Government Notice No. 248).

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Table 8: List of activities triggered in terms of the activities published under the National Environmental Management: Air Quality Act (Act No. 39 of 2004). Government Notice No. 248 Activities Activity No(s): Category 1: Combustion (Subcategory 1.6: Waste Co feeding Combustion Installations) Applicable to combustion Installations facilities. Category 8: Thermal Treatment Facilities where general and hazardous waste are treated by the application of heat. of Hazardous and General Applicable to all installations treating 10 Kg per day of waste. Waste Processes for the rendering cooking, drying, dehydrating, digesting, evaporating or protein 19. Category 10: Animal matter concentrating of any animal matter not intended for human consumption. processing Application: All installations handling more than 1 ton or raw materials per day

(a) The following special agreement shall apply: (i) Best practice measures intended to minimise or avoid offensive odours must be implemented by all installations. These measures must be documented to the satisfaction of the Licencing Authority.

In terms of the National Environmental Management: Air Quality Act (Act No. 39 of 2004), it is expected that the applicant Interwaste will need to apply to the Department of Environmental Affairs and Development Planning for an Atmospheric Emissions Licence (AEL) for the project. Refer to Table 6 above.

4.3 Need and Desirability The Guideline on Need and Desirability (DEA&DP, August 2010) states that the “consideration of ‘need and desirability’ in EIA decision-making … requires the consideration of the strategic context of the development proposal along with the broader societal needs and the public interest. The government decision-makers, together with the environmental assessment practitioners and planners, are therefore accountable to the public and must serve their social, economic and ecological needs equitably. This requires a long-term approach to decision making in order to ensure that limits are not exceeded and that the proposed actions of individuals are measured against the long-term public interest. Sustainable development therefore calls for the simultaneous achievement of the triple bottom-line.”

The concept of need and desirability relates to the type of development being proposed, and can be explained in terms of the general meaning of its two components in which need refers to time and desirability to place – i.e. is this the right time and is it the right place for locating the type of land-use/ activity being proposed in this application? (DEADP, 2002a).

The need and desirability of an application must be addressed separately and in detail answering inter alia the questions below (DEADP, 2010a).

4.3.1 Need (timing) Is the land use (associated with the activity being applied for) considered within the timeframe intended by the existing approved Spatial Development Framework (SDF) agreed to by the relevant environmental authority? (i.e. is the proposed development in line with the projects and programmes identified as priorities within the credible Integrated Development Plan (IDP).

The Drakenstein IDP specifically lists the proposed project namely a waste to energy project whereby waste will be used to generate energy and in the same instance valuable air space will be saved at the landfill site and has included the project in their budget assumptions for refuse removal revenue.

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Should development, or if applicable, expansion of the town/area concerned in terms of this land use (associated with the activity being applied for) occur here at this point in time?

Please refer to the locality map in Chapter 2 (Baseline) which confirms the locality of the candidate sites to be considered.

Both candidates site are located within the build – up area surrounding the existing Wellington landfill site and is a logical location for extended waste management practises due to there proximity to said landfill site.

Does the community/area need the activity and the associated land use concerned (is it a societal priority)? This refers to the strategic as well as local level (e.g. development is a national priority, but within a specific local context it could be inappropriate).

The proposed facility is of regional importance and can be considered a societal priority as it will treat the waste from the Drakenstein Municipal area and surrounds. Current management options are not sustainable and the No-Go Alternative is also not sustainable. The No-Go alternative would also be associated with a number of negative impacts and is likely to result in non compliance with future waste regulations (Refer to Chapter 6).

If Waste management practises continue as is the Wellington waste disposal site will reach capacity in the 2016/2017 financial year and then needs to be rehabilitated and closed. Waste will then have to be transported to the City of Cape Town’s waste disposal site and to cover these transport and disposal costs refuse removal tariffs will have to increase by 41.3% and 30.5% in the 2016/2017 and 2017/2018 financial years. This practice will not be sustainable over the long-term.

In addition the opportunity to reuse a fuel source (methane from anaerobic digestion and heat from combustion of waste) would be lost.

With regards to the appropriateness of the facility on a local level; the proposed site is located adjacent to the existing landfill site and would be a logical location for the proposed extended waste management activities.

Cognizance must also be taken of the Drakenstein & Stellenbosch Critical Biodiversity Mapping and a Botanical Screening will be undertaken as a groundtruthing exercise.

Are the necessary services with adequate capacity currently available (at the time of application), or must additional capacity be created to cater for the development?

The proposed sites are not currently serviced by the Municipality; and the required bulk infrastructure (e.g. stormwater) will need to be provided as part of the development application. More detail regarding existing infrastructure will be provided in the draft EIR.

Is this development provided for in the infrastructure planning of the municipality, and if not what will the implication be on the infrastructure planning of the municipality (priority and placement of services and opportunity costs)?

The Drakenstein Municipality has entered into a Public Private Partnership (“PPP”) agreement with Interwaste in order to realise this project and is thus fully aware of and supportive of the application.

Is this project part of a national programme to address an issue of national concern or importance?

This project is not part of a national programme; but is of regional and local importance. Further the project will reduce the reliance of the Municipality on fossil fuel and make use of green energy

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4.3.2 Desirability (Place) Is the development the best practicable environmental option (BPEO) for this land/site?

The proposed site is located adjacent to the existing landfill site and would be a logical location for the proposed extended waste management activities. The land is currently zoned for Municipal use and will be able to accommodate the proposed facility with out the need to apply for a Land Use Departure.

Cognizance must also be taken of the Drakenstein & Stellenbosch Critical Biodiversity Mapping and a Botanical Screening will be undertaken as a groundtruthing exercise.

Would the approval of this application compromise the integrity of the existing approved and credible municipal IDP and SDF as agreed to by the relevant authorities?

Based on a review of the approved municipal IDP and SDF, the proposed project will not compromise the integrity of the existing planning framework. The project has been included in the IDP and the IWMP for the Municipality as a measure to reduce waste to landfill and generate “green” energy.

Would the approval of this application compromise the integrity of the existing environmental management priorities for the area (e.g. as defined in EMFs), and if so, can it be justified in terms of sustainability considerations?

The site has been highly degraded and little to no vegetation remains. A Botanical Screening will be undertaken to identify a suitable footprint area for the proposed facility and to investigate whether any further studies are required.

Do location factors favour this land use (associated with the activity applied for) at this place? (this relates to the contextualisation of the proposed land use on this site within its broader context).

Location factors do favour this portion of land due to the surrounding waste management and light industrial activities.

How will the activity or the land use associated with the activity applied for, impact on sensitive natural and cultural areas (built and rural/natural environment)?

Environmental issues and potential impacts identified to date are elaborated on in Chapter 7.

A response from Heritage Western Cape on the submission of a Notice of Intention to Develop (NID) will determine the type of and level of assessment(s) required in the EIA Phase.

See above for discussion on natural areas.

How will the development impact on people’s health and wellbeing (e.g. in terms of noise, odours, visual character and sense of place, etc)?

The impact on health and well-being will depend on measures put in place to avoid, reduce or mitigate impacts. The facility is however, likely to have a visual impact. It is important to understand that there are certain regulatory and management standards (air quality, water quality, occupational health and safety) that would need to be adhered to and provide a benchmark for the project. It is unlikely to affect character or sense of place of the location.

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Will the proposed activity or the land use associated with the activity applied for, result in unacceptable opportunity costs5?

A key part in considering opportunity costs is to comparatively consider and assess the different alternatives in terms of the benefits and/or disadvantages associate with each alternative (DEADP 2013).

The proposed management options (including the No-Go Alternative) will be assessed in the EIA Phase and the suitability of the location option will need to be considered in relation to current land use expectations and opportunities within the study area.

The proposed development will be making use of a resource that would other wise be discarded as waste.

Will the proposed land use result in unacceptable cumulative impacts6?

Cumulative impacts may result when the proposed facility is considered together with existing and other proposed developments in the area. Cumulative impacts may be “additive” i.e. air pollution resulting from various activities in the area over time (landfill sites, etc) and traffic congestion. Refer to Chapter 7 for identified issues and impacts.

Cumulative impacts will be elaborated on in the EIA Phase, once specialist studies have been undertaken.

5 Opportunity costs can be defined as the net benefit that would have been yielded by the next best alternative (DEADP 2010a). 6 Cumulative impacts can be defined as: • Additive: the simple sum of all the impacts; • Synergistic effects occur where impacts interact with each other to produce a total effect greater than the sum of the individual effects. These effects often happen as habitats or resource approach capacity; • Time crowding effects occur where frequent, repetitive impacts occur on a particular resource at the same time; • Neutralising effects occur where the impacts may counteract each other to reduce the overall effect; • Space crowding effects occur where we have a high spatial density of impacts on a particular ecosystem; • Externalization of disadvantages occurs when there is no or insufficient consideration given to the associated social costs that will be borne by the public (DEADP 2013)

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5. PROJECT ALTERNATIVES

5.1 Introduction Only location alternatives have been identified at this stage as the project feasibility study undertaken prior to the application (Annexure E) has clearly indentified the proposed combination of Waste recovery, Beneficiation and Energy activities as the being most feasible to achieving the objectives of the project as set out by the Drakenstein Municipality. Two of the main objectives for the Waste to Energy project as necessitated by the DM contract are: . The generation of Renewable Energy from Municipal Solid Waste, and . Reduction of Municipal Solid Waste to Landfill.

The Scoping Phase requires that feasible and reasonable alternatives be identified; whilst the proposed alternatives will be assessed during the Impact Assessment Phase to determine which alternative/s is the most feasible.

64 5.2 Description of the Proposed Alternatives 5.2.1 Location Alternatives Location Alternative 2

Refer to Figure 18 below.

Figure 9: Proposed Location of Site Alternative 2. The proposed Integrated Waste Management facility (IWMF) would be located in the North eastern corner of Erf 34, where the current Drakenstein Municipality green waste and builders rubble facilities are located, with the Drakentein Municipality (DM) Wastewater Treatment Works (WWTW) located to the west, the Wellington landfill site to the south, the DM recycling facility and industrial properties to the east and the Proposed Eco- corridor for the Wellington Industrial Park to the south.

The southern border of the site is classified as a CBA and an Eco-corridor has been proposed for the natural area within the Wellington Industrial Park. The proposed Eco-corridor Wellington Industrial Park that borders the site contains wetlands and the border of the site will be within 100m of these features.

The site is currently utilised for green waste chipping and building rubble crushing and may need some preparation works before construction can commence. The Drakenstein Municipality will have to relocate the existing chipping & crushing facilities (most likely to Location Alternative 1).

The Preferred Location Alternative is Alternative 1.

Location Alternative 3

Taking the environmental sensitivity map as prepared during the Klapmuts North SEA process the proposed location areas for the Integrated Waste to Energy facility are shown in Figures 19 and 20 below.

Figure 10 & 20: Proposed Location Areas for Site Alternative 3. 5.2.2 No-Go Alternative The No-Go Alternative is the option of not implementing the activities and will result in the status quo being maintained.

The No-Go Alternative is presently not considered feasible since no beneficiation of organic waste will take place, no minimisation of waste disposed of to landfill and no “green” energy production will take place. Waste management practises will continue as is and the the Wellington waste disposal site will reach its useful life in the 2016/2017 financial year and then needs to be rehabilitated and closed. Waste will then have to be transported to the City of Cape Town’s waste disposal site and to cover these transport and disposal costs refuse removal tariffs will have to increase by 41.3% and 30.5% in the 2016/2017 and 2017/2018 financial years. This won’t be sustainable over the long-term.

In addition the opportunity to reuse a fuel source (methane from anaerobic digestion and heat from combustion of waste) would be lost.

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6. SCOPING PROCESS AND METHODOLOGY

6.1 Objectives of Scoping The scoping phase requires that feasible and reasonable alternatives be identified; whilst the proposed alternatives will be assessed during the impact assessment phase to determine which alternative/s is the most feasible. All significant environmental issues and potential impacts identified need to be addressed during the impact assessment phase of the project.

The contents of a scoping report, as per the NEMA EIA Regulations, 2010, are as follows:

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. details of - i. the EAP who prepared the report; and ii. the expertise of the EAP to carry out scoping procedures; b. a description of the proposed activity; c. a description of any feasible and reasonable alternatives that have been identified; d. a description of the property on which the activity is to be undertaken and the location of the activity on the property, or if it is - i. a linear activity, a description of the route of the activity; ii. an ocean based activity, the coordinates where the activity is to be undertaken; e. a description of the environment that may be affected by the activity and the manner in which activity may be affected by the environment; f. an identification of all legislation and guidelines that have been considered in the preparation of the scoping report; g. a description of environmental issues and potential impacts, including cumulative impacts, that have been identified; 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 55 as 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; i. a description of the need an desirability of the proposed activity j. a description of the 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 k. copies of any representations, and comments received in connection with the application or the scoping report from interested and affected parties l. copies of the minutes of any meeting held by the EAP with interested and affected parties and other role players which record the views of the participants; and m. any responses by the EAP to those recommendations and comments and views; 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;

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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; and o. any specific information required by the competent authority; and p. any other matters required in terms of section 24(4)(a) and (b) of the Act. 2) In addition, a scoping report must take into account any guidelines applicable to the kind of activity which is the subject of the application. 3) The EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or feasible alternatives, as contemplated in subregulation (1)(c), exist.

6.2 Content of scoping report The content of a Scoping Report is outlined in Regulation 28 of the NEMA EIA Regulations, 2010. Table 9 below indicates where in the Draft Scoping Report the required information is provided.

Table 9: Contents of Scoping Report

Regulation Location in Draft Content of Scoping Report 28 Scoping Report A scoping report must contain all the information that is necessary for a proper understanding of the nature of (1) issues identified during scoping, and must include: details of - (a) (i) the EAP who prepared the report; and Chapter 1 (ii) the expertise of the EAP to carry out scoping procedures; (b) a description of the proposed activity; Chapter 3 (c) a description of any feasible and reasonable alternatives that have been identified; Chapter 4 a description of the property on which the activity is to be undertaken and the location of the activity on the property, or if it is - (d) Chapter 2 (i) a linear activity, a description of the route of the activity; (ii) an ocean based activity, the coordinates where the activity is to be undertaken; a description of the environment that may be affected by the activity and the manner in (e) Chapter 2 which activity may be affected by the environment; an identification of all legislation and guidelines that have been considered in the (f) Chapter 3 preparation of the scoping report; a description of environmental issues and potential impacts, including cumulative (g) Chapter 7 impacts, that have been identified; 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 Public Participation (h) and affected parties of the application have been displayed, placed or given; Report, Annexure A (iii) a list of all persons or organisations that were identified and registered in terms of regulation 55 as 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; (i) a description of the need an desirability of the proposed activity Chapter 4 a description of the identified potential alternatives to the proposed activity, including (j) advantages and disadvantages that the proposed activity or alternatives may have on Chapter 4 the environment and the community that may be affected by the activity copies of any representations, and comments received in connection with the Public Participation (k) application or the scoping report from interested and affected parties Report, Annexure A copies of the minutes of any meeting held by the EAP with interested and affected Public Participation (l) parties and other role players which record the views of the participants; and Report, Annexure A Public Participation (m) any responses by the EAP to those recommendations and comments and views; Report, Annexure A

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Regulation Location in Draft Content of Scoping Report 28 Scoping Report 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 Plan of Study for (n) manner in which such tasks will be undertaken; EIA, Annexure B (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; and (o) any specific information required by the competent authority; and - (p) any other matters required in terms of section 24(4)(a) and (b) of the Act. - In addition, a scoping report must take into account any guidelines applicable to the (2) Chapter 3 kind of activity which is the subject of the application The EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and (3) - motivation if no reasonable or feasible alternatives, as contemplated in subregulation (1)(c), exist.

6.3 Scoping Process The generic Scoping & EIR process flow diagram is shown in Figure 21. The diagram provides some insight into the applicable time frames for various activities; including time frames for the submission of comments by registered stakeholders.

6.3.1 Availability of Background Information Document The first step in the Scoping Process was to make a Background Information Document (BID) available to potential stakeholders within the area of the Wellington Industrial Precinct and stakeholders that requested a copy of the BID based on the advertisements placed in the Paarl Post and Die Burger.

The BID was made available for review and comment from Thursday 7 August 2014 – Friday 29 August 2014 at the Wellington and Paarl Public Libraries and electronically on the RMS website www.rmsenviro.co.za. The BID was also distributed to neighbouring land occupiers and owners via registered post and letter drop. The BID provided an overview/ summary of the S&EIR process for the proposed project (Annexure A).

It is important to state that the decision to include Site Alternative 3 as a further site locality alternative in the process was taken on completion of the BID process.

6.3.2 Availability of Draft Scoping Report (DSR) The Draft Scoping Report is available for review and comment for a period of 40-days from Monday 3 November 2014 to Friday 12 December 2014. Representations (i.e. comments) received on the BID have been incorporated into the Comments and Responses Table (Annexure A). Refer to the Public Participation Report.

It is important to state that the decision to include Site Alternative 3 as a further site locality alternative in the process was taken on completion of the BID process.

6.3.3 Public and Authorities Meetings A Public Open Day and or Meeting and Authorities Meeting will be held during the Draft Scoping and Draft Environmental Impact Report commenting period. Refer to the Public Participation Report (Annexure A).

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6.3.4 Availability of Final Scoping Report Comments on the Draft Scoping Report will be incorporated in to the Final Scoping Report (FSR) and any applicable changes will be made. The FSR will be made available for a 21-day review and comment period before being submitted to DEA and DEADP. Registered I&AP’s will be notified via post or email of the availability of the FSR.

Comments on final reports do not have to be responded to, but the comments must be attached to the final report on submission to DEA and DEADP.

6.3.5 Submission of Final Scoping Report to DEA and DEADP RMS will submit the Final Scoping Report to DEA and DEADP, together with:

• Copies of any representations, and comments received in connection with the application or the scoping report from I&AP’s; • Copies of the minutes of any meeting held by RMS with I&AP’s and other role players which record the views of the participants; • Any responses by the EAP to those representations and comments and views.

6.3.6 Consideration of Final Scoping Report by DEA DEA must within 30 days of acknowledging receipt of a scoping report:

a) accept the report; or b) request RMS to make such amendments to the report as DEA and/or DEADP may require; c) reject the scoping report if it – (i) does not contain the information required in terms of the NEMA EIA Regulations; (ii) has not taken into account guidelines applicable in respect of scoping reports and plans of study for environmental impact assessment.

In the event that the FSR and Plan of Study is accepted; DEA will advise RMS to proceed with the tasks contemplated in the Plan of Study for EIA (Annexure B), including the public participation process and prepare an environmental impact assessment report in respect of the proposed activity.

In the event that DEA rejects the FSR or requests RMS to make amendments to the report; it may be amended and resubmitted.

The environmental impact reporting phase is outlined in the Plan of Study for EIA, attached as Annexure B.

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Figure 21: EIA Process Diagram.

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6.4 Public Participation Process The public participation process aims to identify issues, concerns and queries related to the proposed development. During the scoping phase, it is important that potential interested and affected parties (I&AP’s) are identified. Notification and identification of potential I&AP’s is done by means of a site poster/s, advertisements in a local/ regional newspaper/s and notification7 to landowner/s, occupiers of the site, neighbouring land owner/s, the municipal councillor, ratepayers association/s and any other relevant municipal officials and organs of state having jurisdiction with respect to any aspect of the proposed activity. The public process could also include public meetings and/or open days; authority’s meeting/s; and one-on-one meeting with potentially affected residents and/or landowners. The public participation process to date is described in Annexure A.

A Registered Interested and Affected Party is entitled to comment, in writing, on all written submissions made to the competent authority by the applicant/ EAP managing the application. This includes, but is not limited to, the following written submissions: • Background Information Document (BID); • Draft Scoping Report (including Plan of Study); • Final Scoping Report (including Plan of Study); • Draft EIR (including specialist studies and draft EMP); and • Final EIR

The list of Registered Interested and Affected Parties and State Departments to be notified can be found in Annexure A, Appendix A.

This Draft Scoping Report is available for review and comment from Monday 3 November 2014 to Friday 12 December 2014 on the RMS website (www.rmsenviro.co.za); and in hard copy at the following locations: • Wellington Public Library; and • Paarl Public Library (Meul Street, Paarl).

All registered I&APs will be notified of the date and location of the Open Day to be held at XX on XX 2014.

6.5 Overview of the Scoping Process to date The activities undertaken during the scoping phase to date are summarised in Table 10 below.

Table 10: Overview of the Scoping Process to date Activity Date Submit Application to DEA 4 July 2014 Acknowledgement of Receipt of Application (DEA) 1 August 2014 Advertising the availability of a Background Information Document (BID) and 21-day I&AP Thurs 7 August – Friday 29 Aug registration & commenting period in one (1) local newspaper (PaarlPost) and one (1) 14 regional newspaper (Die Burger) Advertising the availability of a Draft Scoping Report (DSR), Public Open Day and 40-day I&AP registration & commenting period in one (1) local newspaper (PaarlPost) and one (1) Week of 27 October 2014 regional newspaper (Die Burger) Notification via registered and electronic mail to neighbouring landowners and stakeholders Week of 27 October 2014 on preliminary stakeholder database - Posters placed at the entrance to the site 40-day review and comment period on Draft Scoping Report Mon 3 Nov to Friday 12 Dec 2014 Final Scoping Report to be circulated for 21 day review and comment January - February 2015 Final Scoping Report submitted to DEA February 2015

7 Via registered, normal or electronic mail

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7. DESCRIPTION OF IDENTIFIED ISSUES AND IMPACTS

7.1 Issues/ Impacts raised during scoping by I&AP’s The potential significant impacts which have been identified by the EAP, applicant and I&AP’s and which need to be assessed in the EIR Phase include: • Botanical impact relating to the removal of natural vegetation for the construction of the facility; • Potential Noise impact of the facility on surrounding areas; • Suitability of on-site services • Potential Health Risks associated with the operation of the proposed waste management facility; • Socio-Economic Impacts that may result from the construction and operational phases of the proposed facility – the emphasis being on the social impact; • Potential Visual Impact of the proposed facility on surrounding areas; • Potential Air Quality Impacts especially emissions, odour and dust; • Potential Traffic Impact on the surrounding road network due to the increase in the number of vehicles entering and exiting the site; and • The proposed site may have resources of heritage or archaeological value.

The SEA studies completed for those areas within which all 3 site alternatives are located also formed an important source of information for the verification of specialist studies that are required. The opportunity of making use of amended specialist studies based on specialist studies already completed within the site locality areas will be considered.

The specialist studies to be undertaken during the impact assessment phase are required to recommend suitable mitigation measures for the issues identified above.

The assessment will also be supported by the completion of an Engineering Services Report.

8. CONCLUSIONS AND RECOMMENDATIONS

8.1 Conclusions and Recommendations The following specialist studies have been identified (based on the issues/ impacts identified in Chapter 7) and will commence during the impact assessment phase. • Botanical Constraints Assessment; • Noise Impact Assessment; • Health Risk Assessment; • Socio-Economic Impact Assessment; • Visual Impact Assessment; • Air Quality Impact Assessment (including odour and dust); • Traffic Impact Statement; • Archaeological and Heritage investigation; and a • Major Hazardous Installation investigation.

Specialist Studies will need to take into account the immediate and long term significance, geographic extent, duration, permanency of the impacts that are being assessed. The Plan of Study (PoS) for EIA is attached as Annexure B.

75 DRAFT SCOPING REPORT: INTERWASTE (Pty) Ltd OCTOBER 2014

9. References

DEADP (2013a) Guideline on Need and Desirability, EIA Guideline and Information Document Series, Western Cape Department of Environmental Affairs & Development Planning (DEA&DP) DEADP (2013b) Guideline on Public Participation, EIA Guideline and Information Document Series, Western Cape Department of Environmental Affairs & Development Planning (DEA&DP) DEADP (2013c) Guideline on Alternatives, EIA Guideline and Information Document Series, Western Cape Department of Environmental Affairs & Development Planning (DEA&DP) DEAT (2002a) Scoping, Information Series 1, Department of Environmental Affairs and Tourism (DEAT), Pretoria. DEAT (2002b) Stakeholder Engagement, Integrated Environmental Management, Information Series 3, Department of Environmental Affairs and Tourism (DEAT), Pretoria. XX

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ANNEXURE A: PUBLIC PARTICIPATION REPORT

ANNEXURE B: PLAN OF STUDY FOR EIA

ANNEXURE C: AUTHORITY CORRESPONDENCE

ANNEXURE D: MAPS OF PROPOSED WASTE MANAGEMENT FACILITY

ANNEXURE E: PROJECT FEASIBILITY REPORT